Insurance Insights October 2025

KPMG updates

AMLA readiness: Staying ahead of the regulatory tidal wave

In this article, the KPMG AMLA Office (Written by Niclas-Andreas Mueller, Director – KPMG AMLA Office, KPMG Ireland) explains that the European Union has adopted significant anti-money laundering (AML) reforms to date through a legislative package adopted in May 2024, which will apply from July 2027.

The package includes the AML Regulation, Sixth AML Directive, AMLA Regulation, and revised Fund Transfer Regulation, aiming to harmonise rules across Member States under a single European rulebook.

The article explores the key changes which include stricter customer due diligence, enhanced beneficial ownership requirements, targeted financial sanctions compliance, and limits on outsourcing.

A new EU authority, AMLA, will oversee implementation and issue technical standards and guidelines. Firms are urged to start gap assessments, update policies, strengthen data and IT systems, and prepare for a risk-based transition to meet the new obligations.

Board Leadership Centre – Economics, ego, innovation

The KPMG Board Leadership Centre hosted its latest event in Dublin, led by Eamon Dillon, KPMG Ireland Partner and Board Leadership Centre Lead. The event featured Anthony Scaramucci, who worked with US President Donal Trump on his first election campaign and was a former White House Communications Director.

Mr. Scaramucci also had a decade-long career in finance, as a co-founder of Skybridge Capital and previously at Goldman Sachs. The focus of the event was the period of economic complexity while also emphasising the pressures on business leaders, with Irish CEOs following the KPMG 2025 Global CEO Outlook noting they are feeling greater strain than global peers, and highlighted the importance of resilient leadership during economic uncertainty.

Insurance transformation – The new agenda

The KPMG Insurance Team (led by Niall Naughton, Partner and Head of Insurance, KPMG Ireland), explores that the insurance sector is undergoing significant transformation driven by economic uncertainty, shifting customer expectations, and rapid technological change.

Based on a global survey of over 250 insurance executives and in-depth interviews with industry leaders, the report examines the strategies, opportunities, and challenges shaping the industry’s future. It provides insights from KPMG’s global insurance professionals and offers practical guidance for CEOs, CFOs, COOs, and transformation leaders seeking to deliver sustainable change.

European Insurance and Occupational Pensions Authority Updates

EIOPA: 2026 Annual Work Programme

The European Insurance and Occupational Pensions Authority (EIOPA) published its annual work programme for 2026 that sets its strategic priorities including integrating sustainability into supervision, closing protection gaps in natural catastrophe insurance, and advancing digital tools for oversight. EIOPA emphasises ethical AI use, supervisory convergence, and implementing the Retail Investment Strategy, while reinforcing financial stability through enhanced risk frameworks and crisis readiness. Internal governance, cybersecurity, and environmental sustainability remain key focus areas.

EIOPA: Guidelines on Market Share for Reporting

EIOPA has published its final report on the revised guidelines on the methods for determining the market shares for reporting. The revised guidelines will take effect on 30 January 2027, replacing those that were issued in 2015, and are intended to align the current framework with the legal changes introduced through the Solvency II review.

EIOPA: Methodology to Derive Risk-Free Interest Rate Term Structures

EIOPA has published its methodology for deriving the risk-free interest rate term structures applicable to insurance and reinsurance companies under the Solvency II framework. The document includes a comprehensive overview of the updates made since previous versions, the legal basis for the document, and the governance processes surrounding the calculation and publication of risk-free rates. The updates stem from the Deep, Liquid, and Transparency Assessment 2025 (DLT Assessment) and from Bulgaria’s adoption of the Euro. The updates will come into effect from January 2026.

EIOPA: Nominates Damian Jaworski for Executive Director

EIOPA has published a press release announcing the nomination of Damian Jaworski for the role of Executive Director. Mr Jaworski is expected to take up the position in April 2026, upon confirmation by the European Parliament. The Executive Director is appointed for a five-year term, with the possibility of a single renewal for another five years. The Executive Director will be responsible for the day-to-day management of EIOPA and the implementation of its multi-annual and annual work programmes.

EIOPA: Consultations

EIOPA has opened the following consultations in October along with the accompanying closing date listed below:

• Consultation on revised Guidelines on valuation of technical provisions – Solvency II Review – Closing 5 January 2026
• Consultation on revised Guidelines on ring-fenced funds – Solvency II Review – Closing 5 January 2026
• Consultation on RTS on simplified calculation of the risk margin – Solvency II Review – Closing 5 January 2026
• Consultation on revised ITS on matching adjustment approval – Solvency II Review – Closing 5 January 2026
• Consultation on revised ITS on disclosures templates to supervisory authorities – Solvency II Review – Closing 5 January 2026
• Consultation on Guidelines on powers to remedy liquidity vulnerabilities – Solvency II Review – Closing 5 January 2026
• Call for Evidence on DC pensions toolkit – Closing 28 November 2026

EIOPA Q&A Updates

• 09 Sep: 22 and 24 of 2015/35 DR; 75 and 121 of SII Directive
  EIOPA clarified in Q\&A #3349 that the calculation of Solvency Capital Requirement in internal models, including where a dynamic volatility adjustment is used, should be consistent with the principles used for the valuation of the Technical Provisions.
• 09 Sep: Article 121(2)(1)
  EIOPA clarified in Q\&A #3273 that end-period Own Funds should be discounted to the start of the period when being compared to Initial Own Funds. This is with regard to the discounting of assets and liabilities when calculating the Solvency Capital Requirement for a non-life undertaking using an internal model with uncentred risk measure and short average asset and liability durations.
• 26 Sep: S.06.02, S.25.01
  EIOPA clarified in Q\&A #3333 that investments that qualify as infrastructure but do not have an external rating should be reported as Option 2 – CQS 9.