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KPMG updates

Insurance Accounting Advisory Quarterly

The KPMG Insurance team (Led by Niall Naughton, Partner, Head of Insurance) have published its Insurance Accounting Advisory Quarterly that offers key insights into insurers' second year of reporting under IFRS 17 and IFRS 9. The report noted that while fundamental measurement principles have remained stable, insurers are refining their accounting policies, judgments, and disclosures to increase clarity and comparability across the industry. The report also explores the evolving integration of IFRS 17 elements into key performance indicators and the early consideration of how IFRS 18 might impact future performance reporting.

Insurers’ sustainability-related disclosures

The KPMG International Audit team (led by Mark Taylor, Audit Quality Leader – Insurance, KPMG International Standards Group) examines the evolving landscape of sustainability reporting in the insurance industry. The report benchmarks the disclosures of major insurers—focusing on key aspects such as transition and extreme weather action plans, financed and insurance-associated emissions, nature and biodiversity considerations, consumer impacts, and business conduct. The analysis reveals that while insurers are adapting to rising regulatory and investor expectations by enhancing their reporting practices, challenges remain in achieving integrated, comparable, and high-quality disclosures that align with frameworks such as IFRS Sustainability Disclosure Standards and the TCFD recommendations.

Dublin 2040

The KPMG Dublin 2040 team (led by Ryan McCarthy, Managing Partner, KPMG Ireland) published its Dublin 2040 report that produced a blueprint to transform Dublin into a globally competitive and sustainable capital by 2040. The report was launched by Minister Jack Chambers (Minister for Public Expenditure, National Development Plan Delivery and Reform) at an event that brought together government leaders, business experts, and industry stakeholders to address the city's urgent infrastructure challenges, especially in affordable housing, transport, energy, and water, highlighting an estimated need for a approximately €70 billion in investment.

Central Bank Updates

Annual Report and Annual Performance Statement

The Central Bank of Ireland (the Central Bank) has published its Annual Report 2024 and Annual Performance Statement 2024 – 2025. The report describes the Central Bank’s progress in executing its refreshed strategic framework amid a challenging economic environment. The report reviews how the Central Bank is upholding its key mandates (maintaining price and financial stability, enhancing regulatory oversight, and modernizing operational capabilities) while responding to global uncertainties and domestic economic shifts. It also outlines the progress made under its long-term strategy (extended to 2027) and provides insights into operational and financial performance.

Insurance Newsletter June 2025

The Central Bank published its Insurance Newsletter June 2025 which includes an introduction to the Introduction to EU AML Package and the Anti-Money Laundering Authority; refers to the planned launch of a public consultation on the Insurance Recovery & Resolution Directive; describes the existing protected disclosures regime; and provides an overview of recent publications and events, such as the 17 June Webinar: the application of the SEAR to (I)NEDs and the cross-sectoral information note entitled “Planning for the Transition to Net Zero: Our Perspective”. 

Quarterly Bulletin 2025:2 – Slower pace of domestic growth amid trade tensions and global uncertainty

The Central Bank published its Quarterly Bulletin 2025:2 which highlights that while the Irish economy is expected to continue growing, its pace is set to slow due to persistent trade tensions and global economic uncertainty. The bulletin underscores that these external challenges are dampening domestic demand and investment, prompting a more cautious economic outlook that will likely influence both policy responses and market strategies in the near to medium term.

European Insurance and Occupational Pensions Authority Updates

Financial Stability Report 2025

EIOPA published its Financial Stability Report for June 2025. The report assesses Europe’s insurance, reinsurance, and occupational pensions sectors amid a volatile macroeconomic landscape. The report details that despite the sectors remaining robust and well-capitalised under the current framework, it highlights emerging risks from fluctuating exchange rates, interest rates, and equity valuations, alongside increased exposure to geopolitical challenges and cyber threats. EIOPA within the report underline the need for enhanced vigilance and proactive risk monitoring to sustain financial stability across the EU.

Annual Report 2024

EIOPA published its Annual Report for 2024 that outlines the authority’s achievements over a year it characterised as having rapid technological change, geopolitical uncertainty, and evolving risks. EIOPA highlighted significant progress in reinforcing sustainable insurance and pensions by addressing protection gaps, advancing digital transformation and digital resilience, and ensuring robust prudential supervision.

Capital Markets Integration

EIOPA has published a response to the European Commission (EC) regarding their consultation on the integration of EU capital markets. EIOPA within their reply emphasised that while the single market is already functioning within the European insurance sector more effective supervision at the EU level is essential for the success of the Savings and Investments Union (SIU) initiative. EIOPA’s response focuses on three key areas the oversight of cross-border business, simplification of the supervision structure and the need for greater consistency in internal models.

UK Updates

FCA: CP25/12: Simplifying the insurance rules

On 14 May 2025, the FCA announced a consultation to seek feedback on proposals and other potential changes to simplify the rules for insurance and funeral plan firms. 

FCA: Financial Lives Survey

On 16 May 2025, the FCA released the results of the 2024 Financial Lives Survey. This includes their reports and available data.

PRA: Speeches

In May 2025, the PRA published the following speeches:

  • What if things are different? - speech by Clare Lombardelli
  • The heat is on: why monetary policy makers are increasingly focusing on the impact of climate risks - speech by James Talbot

PRA: Regulatory Digest

On 01 May 2025, the PRA published their regulatory digest for March 2025.

PRA: Modelling income risk dynamics in the UK: a parametric approach

On 30 May 2025, the PRA published a working paper which set out to develop a model of income dynamics that accounts for the broader state of the economy and successfully captures key features of the UK earnings growth distribution.

Other European and International Supervisory Authority Updates

IAIS: Guidance on transitioning to a risk-based solvency (RBS) regime

The International Association of Insurance Supervisors (IAIS) has published new guidance to support insurance supervisors transitioning to a risk-based solvency (RBS) regime. Developed with the IMF, the document outlines practical steps and key considerations for implementing an RBS framework, emphasising that the transition is a medium- to long-term process. It highlights the importance of tailoring the approach to each jurisdiction’s legal and institutional context, engaging stakeholders throughout, and managing the cultural shift required within supervisory bodies and the insurance sector.

European Commission: High-Risk AI Systems

The EC has launched a public consultation to gather input on the implementation of the Artificial Intelligence Act’s (the ‘AI Act’) provisions concerning high-risk AI systems. The consultation seeks practical examples and aims to clarify issues relating to high-risk AI systems. The EC will consider the feedback in upcoming guidelines on the classification of high-risk AI systems and their related requirements and obligations. The AI Act currently identifies two categories of high-risk systems:

  • Systems that are important for product safety under the EU’s harmonised legislation on product safety.
  • Systems that can significantly affect people’s health, safety, or fundamental rights in specific use cases listed in the AI Act.

Stakeholders are invited to participate in the consultation, which will remain open until the 18 July 2025.

EIOPA Q&A

EIOPA Q&A Updates

Please see below for EIOPA’s response to recent queries which have been raised by the public for further clarification on the Solvency II requirements. The Solvency II requirements may change or become more prescriptive over time.

08 May: PF.08.01

EIOPA clarified in Q&A (#3309) that for template S.08.01, fields C0440 and C0450 should describe the cashflow patterns of swaps, including total return swaps, credit default swaps, and swaptions. For example, a swap exchanging Euribor+0.5% for 2.3% in USD should be reported as 'Euribor+0.5%' in C0440 and '2.3% USD' in C0450.

08 May: CIC classification

EIOPA clarified in Q&A (#3270) that Development Finance Institutions (DFIs), even if fully owned and regulated by a European government, should be classified under CIC code 2 (Corporate) rather than 1 (Government).

08 May: S.06.02, S.06.04

EIOPA clarified in Q&A (#3263) that from 2025, both NACE 2.0 and NACE 2.1 codes will be reported for certain domains to ensure continuity in data series. Insurers receiving data from providers switching to NACE 2.1 must adapt accordingly. The 2025 taxonomy hotfix allows optional implementation for those needing to use NACE 2.1, with dual columns available for both versions.

08 May: S.29.01, S.29.02, S.29.03, S.29.04

EIOPA clarified in Q&A (#3055) that captive insurance and reinsurance undertakings meeting Article 4 criteria are only required to report the templates specified under Article 4(4) and 4(5), respectively. This supersedes the earlier interpretation that only S.29.01 was exempted.

08 May: S.14.01

EIOPA clarified in Q&A (#2981) that it remains valid to report multiple rows for each Product ID code in S.14.01.01.01. Although both S.14.01.01.01 and S.14.01.01.02 share the same dimension, reporting entities are not required to fill in all corresponding rows in both tables. The modelling will be improved in future taxonomy releases to address confusion.

Further information

For more on any of the items above, or any Insurance-related queries, contact Niall Naughton, Head of Insurance. We'd be delighted to hear from you.