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      KPMG updates

      2025 Insurance CEO Outlook

      The latest insights from the KPMG 2025 Insurance CEO Outlook highlight how global trends are reshaping the insurance sector. As insurers navigate technological disruption, rising climate risks, regulatory change and evolving customer expectations, the report captures CEO perspectives across major markets and offer valuable context for Irish insurers operating in a rapidly shifting environment.

      Niall Naughton

      Partner, Head of Insurance

      KPMG in Ireland


      Central Bank of Ireland updates

      Central Bank: Speech – Compliance Institute AGM

      The Central Bank of Ireland (Central Bank) has published a speech delivered by Gerry Cross, Director, Capital Markets and Funds, at the Compliance Institute AGM.

      In his speech the Director reiterated the Central Bank’s shift toward a more outcomes‑focused, risk‑based regulatory framework, with strong emphasis on securing customers’ interests as the revised Consumer Protection Code comes into force in March 2026.

      He also touched on other topics including individual accountability, simplification, resilience, leveraging technology and the Central Bank’s evolving approach to supervision.


      European Insurance and Occupational Pensions Authority updates

      EIOPA: Implementation of Generative AI

      The European Insurance and Occupational Pensions Authority (EIOPA) has published a report on the use of Generative AI (Gen AI) across Europe’s Insurance sector. The report shows that adoption is increasing rapidly, with almost two‑thirds of insurers already experimenting with Gen AI, mostly at proof‑of‑concept stage, as they seek efficiency gains, cost reductions, better customer experiences and improved decision‑making.

      Current applications focus largely on internal operational tools such as data extraction, document and content generation, and coding or underwriting support, while some firms are also developing customer‑facing chatbots and voicebots. Key challenges include data privacy, security, regulatory compliance and shortages of skilled staff, with hallucinations identified as the most significant risk.

      Insurers also rely heavily on third‑party providers, emphasising the importance of frameworks such as DORA and the AI Act in managing external dependencies. Reflecting the evolving risk landscape, nearly half of insurers have now adopted dedicated AI policies, a notable increase from 2023.

      EIOPA: Authorisation and supervision of undertakings owned by private equity firms

      EIOPA has published a consultation paper on the authorisation and ongoing supervision of (re)insurance undertakings related to private equity firms aimed at promoting consistent, high-quality and risk-based supervision across the EU. The proposed supervisory statement sets expectations for the assessment of qualifying holdings, portfolio transfers, mergers and ongoing supervisory practices, applying principles of proportionality and risk‑based oversight. The consultation remains open until April 2026.

      EIOPA: Central Bankers speech

      EIOPA has published a speech delivered by Petra Hielkema, EIOPA Chairperson, at the authority’s 15th Anniversary Conference. In her speech, Ms Hielkema highlighted its progress in strengthening EU insurance and pensions supervision and its expanded role across newer regulatory frameworks. She stressed that geopolitical tensions, demographic pressures and climate‑related risks demand deeper supervisory unity and a more resilient Single Market, supported by EIOPA’s 2030 strategy focused on convergence, protection gaps and technology‑enabled supervision. She concluded by underscoring the need for continued cooperation to ensure the sectors remain trusted, resilient and prepared for future challenges.

      EIOPA: Risk Dashboard shows a stable risk landscape

      EIOPA has published a risk dashboard for institutions for occupational retirement provision (IORPs). Overall, the risk dashboard indicates that the macroeconomic environment is stable, backed by GDP growth and lower inflation, despite geopolitical tensions in Venezuela, Iran, and Greenland. Sovereign and corporate bonds have tightened slightly, but increased public spending on defence and infrastructure may push spreads higher.

      EIOPA: Revised Single Programming Document 2026-2028

      EIOPA has published a document (PDF, 1.4MB) setting out the EIOPA’s Revised Single Programming Document 2026-2028. The plan outlines strategic priorities such as strengthening Single Market integration through aligned, risk-based supervision, strong cross-border oversight, and work on internal models; boosting resilience with systemic risk monitoring, EU-wide stress tests, implementing the Insurance Recovery and Resolution Directive (IRRD), improving cyber coordination, and providing guidance on Insurance Guarantee Schemes. It also advocates for more streamlined, proportionate regulation by leveraging data sharing, SupTech, and AI. Oversight will extend to critical third-party providers under the Digital Operational Resilience Act (DORA), with further progress in sustainability supervision and efforts to address protection gaps.

      EIOPA: Strategy t 2030

      EIOPA has published a document setting out its strategy towards 2030 and its key areas of focus in an era marked by heightened geopolitical tensions, economic fragility, as well as environmental and technological challenges. This complex landscape calls for smart regulation and impactful supervision to deliver tangible benefits for Europe’s citizens and businesses. Looking ahead to 2030, EIOPA’s top priorities will be to strengthen the single market, improve society’s resilience to risks, and enhance regulatory and supervisory effectiveness. The objectives related to greater resilience focus on strengthening risk assessment capabilities, improving both the availability of data on and awareness of critical protection gaps, including in pensions, natural catastrophes, and cyber threats, as well as enhancing cross-sectoral collaboration.

      EIOPA: Reappoints two management board members for a second term

      EIOPA has published a press release announcing the reappointment of two Management Board members for a second term. Ante Žigman, President of the Board of the Croatian Financial Services Supervisory Agency, and Teija Korpiaho, Chief Advisor of Insurance Supervision at the Finnish Financial Supervisory Authority, will continue to serve on the Board for an additional two and a half years.

      ESAs publish joint Guidelines on ESG stress testing

      The European Supervisory Authorities (EBA, EIOPA and ESMA - the ESAs) have published their Joint Guidelines (PDF, 415KB) on environmental, social, and governance (ESG) stress testing. These Guidelines provide national insurance and banking supervisors with clear guidance and standards on how to integrate ESG risks into their supervisory stress testing methodologies and outline the necessary organisational and governance arrangements.

      European Supervisory Authorities and UK financial regulators sign Memorandum of Understanding on oversight of critical ICT third-party service providers under DORA

      The European Supervisory Authorities have signed a Memorandum of Understanding (MoU) (PDF, 3.6MB) with the Bank of England (BoE), the Prudential Regulation Authority (PRA), and the Financial Conduct Authority (FCA). This agreement enhances the cooperation between the authorities to oversee critical ICT third-party service providers (CTPPs) as required by the Digital Operational Resilience Act (DORA). The MoU aims at enhancing third-party risk management and contributing to the overall operational resilience of the financial sector in the EU and UK through strong cross-border cooperation between the relevant authorities responsible for EU CTPPs/UK critical third parties oversight.


      Other European and International Supervisory Authority Updates

      Insurance Europe: Consumer Hub updated with new examples of consumer-focused insurance practices across Europe

      Insurance Europe has updated its Consumer Hub, an online tool that shows how insurers across Europe are improving products, services and protections for consumers. The Consumer Hub brings these efforts together in one place and showcases practical, real-world examples of consumer-focused initiatives from national insurance markets across the EU.


      EIOPA Q&A updates

      01 Dec: S.06.02

      EIOPA clarified in Q&A (#3434) that shares in subsidiaries (when the subsidiary is a financial institution - sector K according to the NACE code) located in a jurisdiction with a bail-in regime shall be reported in S.06.02 template in column C0293 “Bail-in rules" as “1-Yes ".

      02 Dec: PRIIPs Annex II

      EIOPA gave guidance in Q&A (#2509) on the calculation methodology for the performance of PRIIPs over certain sub-intervals, in particular justification for the inclusion of the natural logarithm.

      02 Dec: S.22.06

      EIOPA clarified in Q&A (#3443) that the threshold to C0050 for row R0040 applies also for rows R0020 and R0030.

      02 Dec: PRIIPs Annex IV

      EIOPA clarified in Q&A (#3085) that in the use of a benchmark or proxy, it is not permissible to ex ante dismiss any potential assets in the assessment of the appropriateness of the benchmark or proxy.

      02 Dec: PRIIPs

      EIOPA gave guidance in Q&A (#2593) on the classification difference between a Category 2 and a Category 3 PRIIP, particularly with regard to whether it pays out a constant multiple of the prices of the underlying investments.

      02 Dec: PRIIPs Annex IV

      EIOPA gave guidance in Q&A (#3088) taking into account if a PRIIP has credit liabilities during the assessment of the appropriateness of a benchmark or proxy.

      19 Dec: Risk-Free Interest Rate - Deep, Liquid and Transparent maturities

      EIOPA gave guidance in Q&A (#3487) on constructing risk-free rates if a given tenor is not available in observable market data. EIOPA also advises that market data providers may publish data with some delay.

      19 Dec: IDD Article 1(3)

      EIOPA gave guidance in Q&A (#3409) on whether freight forwarders should be considered ancillary insurance intermediaries under the Insurance Distribution Directive (IDD).


      UK updates

      FCA: PS25/21: Simplifying the insurance rules

      On 09 December 2025, the FCA published their list of measures aiming to simplify regulations for firms across the insurance and funeral plans sectors.

      FCA: Regulatory Initiatives Grid – December 2025

      On 11 December 2025, the FCA published their 9th edition of the regulatory initiatives grid. This outlines the FCA’s planned regulatory initiatives for the next 24 months.

      FCA: Home and travel insurance super-complaint response

      On 18 December 2025, the FCA published their response to the super-complaint sent by consumer body Which?. The complaint said consumers were being failed by the home and travel insurance markets when making claims. The FCA have outlined their response and the actions they are taking.

      PRA: Speeches

      In December 2025, the PRA published the following speeches:

      • Promoting innovation while guarding against financial stability risks − speech by Randy Kroszner
      • The evolving landscape of UK financial mutuals: every challenge is an opportunity − speech by Laura Wallis
      • Removing Frictions − speech by Nathanaël Benjamin

      Basel 3.1: Market Risk − speech by Phil Evans

      SS5/25 – Enhancing banks’ and insurers’ approaches to managing climate-related risks

      On 03 December 2025, the PRA published a supervisory statement setting out the expectations for firms’ approaches to managing climate-related risks.

      PRA: From magnifying glass to drone: using AI to spot reserving risks faster

      On 05 December 2025, the PRA published an article covering how AI can be used in a supervisory capacity to analyse and detect reserving risk faster.

      PRA: Mutuals landscape report

      On 05 December 2025, the PRA published a landscape report on the UK financial mutuals market. The PRA aims to facilitate the long-term sustainable growth of the sector and ensure that mutuals have the same opportunities to compete as other firms.

      PRA: LIAC02/25 – Low Impact Amendments

      On 19 December 2025, the PRA announced a list of low impact amendments to rules, following the consultation paper LIAC02/25. These include an amendment to the Insurance Special Purpose Vehicle (ISPV) Part of the PRA Rulebook, Solvency Requirements, Rule 2.2A(3) and others.


      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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