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      KPMG updates

      Inside Insurance - Conversation with Michael Leahy from Insurance Ireland

      In the latest episode of Inside Insurance, KPMG's Jean Rea sits down with Michael Leahy, President of Insurance Ireland, for a wide-ranging discussion on some of the most important developments affecting the sector today.


      Their conversation explores topics including:

      • The introduction of the new Personal Investment Account (PIA) and its potential impact on long-term savings and investment behaviour
      • The industry's implementation of the Right to be Forgotten framework for cancer survivors
      • Progress on flood insurance and improving protection for communities at risk
      • Ireland's strong role in the international and speciality insurance market

      Watch or listen to the full interview here.

      Niall Naughton

      Partner, Head of Insurance

      KPMG in Ireland


      Central Bank of Ireland updates

      Central Bank of Ireland: Guidance on Prohibition Notices Under the Fitness and Probity Regime

      The Central Bank of Ireland has published Supplemental Guidance on Prohibition Notices under the Fitness & Probity Regime, providing greater clarity on the factors considered when determining the nature, scope and duration of a prohibition notice. The final guidance incorporates stakeholder feedback from the consultation process, including additional clarification on prohibition decisions and publication practices, with the aim of enhancing transparency, consistency and confidence in the CBI’s decision-making framework while retaining flexibility to consider individual circumstances.

       

      Central Bank of Ireland: Updated Solvency II Review and IRRD FAQs

      On 24 July, the Central Bank hosted a webinar event on the Solvency II pre-application process for non-SNCU proportionality measures. Following this event, the Central Bank refreshed the frequently asked questions available on its website on 7 August, providing additional clarity on key elements of the Solvency II Review and IRRD implementation.


      European Insurance and Occupational Pensions Authority Updates

      EBA, EIOPA and ESMA call for enhanced governance and consistent supervision to mitigate ICT risks from frontier AI models in the EU financial sector

      On 31 July, the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) published a statement calling for a cross-sectoral, risk-based and consistent supervisory approach to mitigate the ICT risks stemming from frontier AI models.

      EIOPA: Insurance Risk Dashboard

      On 30 July, EIOPA published its Insurance Risk Dashboard. The main findings show that risks in the European insurance sector are stable at a medium level, although increasing cyber threats and a more uncertain macroeconomic environment require continued vigilance from firms and supervisors.

      EIOPA: Risk Dashboard for Occupational Pension Funds

      On 30 July, EIOPA released its Risk Dashboard for institutions for occupational retirement provision (IORPs), highlighting that persistent geopolitical uncertainty and evolving global market conditions continue to shape the risk landscape for the European occupational pensions sector.


      Other European and International Supervisory Authority Updates

      Insurance Ireland: Proposal for national solution to close Ireland’s flood insurance protection gap

      On 28 August, Insurance Ireland published a proposal for a national flood insurance framework to address the growing flood insurance protection gap in Ireland, recognising that increasing flood risk, including from climate change, is making flood cover unavailable or unaffordable for some homeowners and creating wider housing and financial stability concerns. The proposal includes a Homeowner Flood Adaptation Scheme, a Sustainable Flood Insurance Fund, stronger flood-resilient planning measures, and continued investment in flood defences, with a dedicated Flood Agency overseeing the framework.


      EIOPA Q&A Updates

      Article 209

      EIOPA gave guidance in Q&A (#3213) on SCR considerations for independent companies entering into pooled reinsurance agreements.

      SII Directive

      EIOPA clarified in Q&A (#3553) which RTS and ITS are under review as part of the revised Solvency II Directive.

      SFCR

      EIOPA clarified in Q&A (#3593) that there are no language requirements of the insurance and reinsurance undertaking’s SFCR under Solvency II. Therefore, the language of the SFCR is subject to the requirements set out in national law.

      DORA – Register of Information

      EIOPA clarified in Q&A (#3480) that there is a typographical in the instructions for template B_02.01. In the case of intra-group contractual arrangements where the entities involved report different currencies in template B_01.02 C0100, the currency to be reported should be the currency of the financial entity making use of the ICT services (i.e., the buyer).

      DORA – ICT Risk Management

      EIOPA clarified in Q&A (#3450) that there is no intention to create a specific regime for entities subject to the simplified ICT risk management framework.

      Article 55(2)

      EIOPA clarified in Q&A (#3522) that in the case of captive insurance, where a policy is issued to the insured via a fronter, the business falls under reinsurance and should therefore be allocated to Lines of Business 13 to 24 and not the Lines of Business for direct business.

      S.06.02

      EIOPA clarified in Q&A (#3569) that CDX options should be classified under CIC code XLB9/XLC9.

      Risk Free Rate

      EIOPA clarified in Q&A (#3596) that plan to publish term structures using the new methodology in a preparatory phase this year. More details will be released in due course.​ As per Q&A (#3583), these will be run in parallel with the current monthly publications.

      Article 52(4)

      EIOPA clarified in Q&A (#3509) that making decisions on how a component or feature of a bond should be considered for its reporting should be taken from a risk perspective. Any related questions should be directed to the relevant national authority.

      Solvency II Amendments

      EIOPA clarified in Q&A (#3589) that undertakings whose financial year ends before 30 January 2027 shall apply taxonomy 2.8.0 while undertakings whose financial year ends after 30 January 2027 shall apply taxonomy 2.10.0.

      Article 35(a)

      EIOPA clarified in Q&A (#3587) that under recent revisions to Solvency II, reporting shall not be completed for year-end for templates S.06.02, S.06.03 or S.08.01, if these templates have already been reported for Q4.

      Article 15

      EIOPA gave guidance in Q&A (#3546) on the treatment of deferred tax assets (DTAs), deferred tax liabilities and net DTAs under Solvency II. EIOPA also clarified the distinction between:

      • Recognition and valuation of DTAs/DTLs,
      • Balance sheet presentation of DTAs/DTLs, and
      • Calculation of net DTAs for Own Funds purposes.

      UK updates

      FCA: CP26/29: A tailored regime for captive insurance

      On 14 July 2026, the FCA published consultation paper 26/29, setting out their proposals for establishing a tailored regime for captive insurance. The FCA, along with the PRA, propose a regulatory framework which removes or tailors several requirements that apply to conventional insurance but are not appropriate to captive insurance or its risk profile. In particular, the FCA is focused on a streamlined set of requirements that avoid unnecessary regulatory burden. Responses to this consultation paper may be submitted to the FCA before 14 October 2026. 

      FCA: General insurance value measures data 2025

      On 21 July 2026, the FCA published their fourth consecutive general insurance (“GI”) value measures data for the period from January to December 2025. This publication aims to increase market transparency and give stakeholders a common set of indicators for the sector. The highlights of the data include:

      • Both home and travel insurance are recording higher complaints per claim than other GI products. Home (7-13%) and travel (5-6%) compared to other products (0-6%).
      • Home insurance had low claims acceptance rates (62-71%) compared to other products – travel (83-86%) and motor (99%).
      • Travel insurance premiums rose by 17% but the amount of paid out in claims rose 47%.
      • Motor insurance premiums fell by 7%.

      PRA: CP12/26 – Insurance friendly societies, amalgamations and transfers

      On 22 July 2026, the PRA published a consultation paper outlining their intention to amend SoP3/15, covering the PRA’s approach to insurance business transfers. The PRA note that Part VIII Transfers under the Friendly Societies Act 1992 appear difficult complex. In response, the PRA have proposed to publish more detail and enhanced guidance to help firms navigate the Part VIII transfer process. Responses to this consultation paper may be provided to the PRA before the 22 October 2026.


      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.

      Niall Naughton

      Partner, Head of Insurance

      KPMG in Ireland

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