KPMG updates
Celebrating excellence in financial services
KPMG is proud to return as the main sponsor of the Financial Services (FS) Awards for the fourth consecutive year, continuing our commitment to recognising innovation, leadership, and transformation across Ireland’s financial services sector.
Held on 23 October 2025, in the iconic Round Room at The Mansion House, Dublin, the FS Awards celebrate the achievements of individuals and organisations driving progress in areas such as Fintech, ESG, Compliance & RegTech, AI, and more.
The climate reality check
KPMG’s Sustainable Futures team, led by Russell Smyth (Partner and Head of Sustainable Future and Corporate Finance), explains how a 2.4°C rise in global temperatures isn’t just a missed target — it’s a fundamentally different world. One where physical climate risks become systemic, and the cost of inaction becomes unmanageable.
The likelihood of simultaneous climate events — drought, flooding, crop failure — could potentially increase significantly, with cascading effects on global trade, migration, and financial systems.
Central Bank Updates
Sector specific money laundering/terrorist financing Risk Evaluation Questionnaire
Over a phased timeframe, the CBI is replacing the current AML/CFT Risk Evaluation Questionnaire (‘REQ’) with sector specific REQs to capture more detailed and pertinent risk data, to better inform decision-making and supervisory strategy. The CBI published the revised REQ templates and guidance for credit institutions and payment institutions/electronic money institutions, and announced it would be introducing new sector specific REQs for other sectors in H2 2025 and over 2026.
European Insurance and Occupational Pensions Authority Updates
EIOPA publishes Opinion on AI governance and risk management
On 6 August EIOPA published an ‘Opinion on AI Governance and Risk Management’. Addressed to National Competent Authorities, the Opinion articulates the supervisory expectations in relation to the fair, ethical and responsible use of AI, within the context of not only the Artificial Intelligence Act, but also the Solvency II Directive, the Insurance Distribution Directive, and the Digital Operational Resilience Act.
UK Updates
FCA: Response to the Cost Benefit Analysis (CBA) Panel’s Interim Annual Report
On 04 July 2025, the FCA released recommendations on the use of CBAs and 3 specific, strategic areas where they recommend CBA policy and practice should be developed.
FCA: FCA outcomes and metrics 2022 to 2025
On 10 July 2025, the FCA reported on the final outcome of Strategy 2022 – 2025 which has now come to an end.
FCA: Home and travel claims handling arrangements
On 22 July 2025, the FCA published good practice and areas for improvement for home and travel insurers’ claims handling arrangements.
FCA: Premium Finance Market Study Update Paper
On 22 July 2025, the FCA published an update paper which outlines the initial findings of the their premium finance market study, launched in October 2024.
FCA: General insurance pricing practices (GIPP) remedies
On 22 July 2025, the FCA published the results of their evaluation of GIPP designed to address harm to consumers.
FCA: Roadmap for retail insurance
On 22 July 2025, the FCA published a package of reports on how the retail insurance market is working and set out actions on how specific issues should be addressed.
FCA: Motor insurance claims analysis
On 22 July 2025, the FCA published findings on the causes of increased premiums, particularly increased claims costs, to support the work of the Motor Insurance Taskforce.
PRA: Speeches
In July 2025, the PRA published the following speeches:
- The meaning of reserve currency – remarks by Andrew Bailey
- Weathering the storm: stability in a changing climate - speech by Sarah Breeden
- Getting liquidity where it is needed – speech by Nathanaël Benjamin
PRA: Regulatory Digest
On 01 July 2025, the PRA published their regulatory digest for June 2025.
PRA: Lloyd’s managing agent authorisation process to be streamlined
On 07 July 2025, the PRA published a report on how Llyod’s managing agent authorisation process is to be streamlined to support growth.
PRA: HM Treasury’s captive insurance consultation response
On 15 July 2025, the PRA published a joint statement by the PRA and FCA which backs HM Treasury’s plans to grow the UK’s captive insurance market. They aim to create a proportionate regulatory regime reflecting the lower risks of captive insurers.
PRA: CP18/25 – Review of the Senior Managers and Certification Regime (SM&CR)
On 15 July 2025, the PRA announced a consultation paper, outlining the initial proposed changes to the SM&CR. This paper will close to responses on 07 October 2025.
PRA: CRR and Solvency II requirements in PRA Rulebook
On 17 July 2025, the PRA published a restatement of CRR and Solvency II requirements in PRA Rulebook – 2026 implementation. The implementation date for final rules and policy material reflecting the policy changes set out in this policy statement is 01 January 2026.
PRA: 2026 Dynamic General Insurance Stress Test
On 18 July 2025, the PRA published an update on the 2026 Dynamic General Insurance Stress Test (DyGIST).
PRA: Accelerated authorisations for UK Insurance Special Purpose Vehicles (ISPV)
On 25 July 2025, the PRA announced authorisations for UK ISPV will be accelerated as part of the PRA’s ongoing intention to reform the functioning of the UK ISPV regulatory regime.
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.
11 July: S.36.04
EIOPA clarifies in Q&A (#3094) what information must be included in the column 'Maximum cover by transaction' (C0150) in S.36.04.
11 July: S.36.05
EIOPA clarifies in Q&A (#3090) the overlap between S.36.01/S.36.02 and S.36.05.
11 July: FC.06, S.37.01
EIOPA clarifies in Q&A (#3050) the information that must be included in cell C0320 of S.37.01.
15 July: S.14.03
EIOPA clarifies in Q&A (#3361) what claims information must be disclosed in columns C0110 and C0120 of S.14.03.
15 July: S.04.04, S.04.05
EIOPA clarifies in Q&A (#3340) the difference between S.04.04 and S.04.05.
24 July: DORA Art. 8(7)
EIOPA clarifies in Q&A (#2996) the requirements of Art. 8(7) of DORA with regards “connection of technologies”.
24 July: Article 171(a)
EIOPA clarifies in Q&A (#3325) whether solo insurance entities using a partial internal model to model underwriting risks can apply the standard formula equity shock of 22% for long-term equity investments.
24 July: Article 28
EIOPA clarifies in Q&A (#3210) the requirements on the identification of subcontractors providing ICT services to entities within the scope of DORA.
29 July: Annex I: Part A
EIOPA clarifies in Q&A (#3144) the type of risks covers by Class 10 – Motor vehicle liability, compared to those cover by Class 7 – Goods in transit.
29 July: Article 29(2)
EIOPA clarifies in Q&A (#2459) how Article 29(2) of the Insurance Supervision Directive should be applied or implemented.
29 July: S.06.02
EIOPA clarifies in Q&A (#3326) what CIC category must be applied to instruments that are fully, unconditionally and irrevocably guaranteed by non-EU/EEA central governments.
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.
