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      KPMG updates

      DORA: ICT Third-Party Service Providers


      In this article, the KPMG Technology Risk Team (led by Jackie Hennessy, Partner – KPMG Technology Risk Consulting)       explores how the Digital Operational Resilience Act (DORA) affects ICT third-party service providers in the EU financial sector.

      The article highlights key obligations for third-party providers, such as registering with regulators, complying with oversight requirements, and ensuring robust risk management practices. It also discusses the broader implications for governance, contractual arrangements, and operational processes considering DORA’s enforcement.

      KPMG: Budget 2026


      In this article, the KPMG Tax Team (led by Orla Gavin, Partner – KPMG Tax) highlights key recommendations aimed at enhancing competitiveness, supporting innovation and addressing pressing issues such as housing ahead of the 2026 Budget.

      Niall Naughton
      Niall Naughton

      Partner, Head of Insurance

      KPMG in Ireland

      Central Bank Updates

      Central Bank: Insurance Newsletter  


      The Central Bank of Ireland (the Central Bank) has published its Insurance Newsletter for September 2025. The newsletter focuses on supervisory insights and regulatory updates in the insurance sector. The newsletter highlights insights from a data request issued to a sub-set of life (re)insurance firms in May. 

      Furthermore, the newsletter presented the results of the Thematic Review of consumer treatment in health insurance that identified gaps in customer support and advised providers to improve suitability assessments, communication tools and oversight.

      Additional updates include stakeholder engagement, regulatory returns and EIOPA developments.

      European Insurance and Occupational Pensions Authority Updates

      EIOPA: Factsheet on Asset Allocation of Occupational Pension Funds


      The European Insurance and Occupational Pensions Authority (EIOPA) has published a factsheet on institutions for occupational retirement provision (IORPs) in the European Economic Area (EEA).

      The factsheet covers approximately €2.7 trillion in assets under management, with a focus on government bonds, corporate bonds, equities, and investment funds, together accounting for 92% of IORPs’ portfolios.

      The factsheet includes visual data on trends in pension fund membership, contributions, and benefits over recent years, providing a snapshot of the evolving landscape of occupational pensions in Europe.

      Other European and International Supervisory Authority Updates

      ESAs: Principle Adverse Impact Disclosures under the Sustainable Disclosure Regulation


      A joint committee report on principle adverse impact (PAI) disclosures under the Sustainable Finance Disclosure Regulation (SFDR) is the fourth annual assessment by the European supervisory authorities (ESAs - EBA, EIOPA, ESMA).

      The ESAs found steady improvement in the quality and completeness of voluntary PAI disclosures at both the entity and product levels. The ESAs also note firms have adopted good practices from previous years’ recommendations, and it includes new guidance for National Competent Authorities (NCAs) to enhance supervision.

      ESAs: Risks and Vulnerabilities in the EU Financial Risk System


      The ESAs released its joint committee report on risks and vulnerabilities in the EU financial system. The report highlights the impact of new US tariffs and growing transatlantic uncertainty, which have contributed to a weaker economic outlook.

      Despite resilience in banks, insurers, and pension funds, the ESAs urge financial institutions to remain vigilant, strengthen provisions, and embed geopolitical and cyber risks into their risk frameworks. They also stress the need to monitor crypto market contagion and support the Savings and Investments Union initiative responsibly.

      EIOPA Q&A Updates

      06 Aug: FC.00

      EIOPA clarified in Q&A (#FICOD031 - 3388) which intra-group transaction ID should be reported in case the transaction is part of a single economic transaction.

      06 Aug: FC.06

      EIOPA clarified in Q&A (#FICOD027 - 3387) shall exposures with the same external counterparty that are labelled in different currencies should be reported in separate lines.

      06 Aug: FC.01

      EIOPA clarified in Q&A (#FICOD029 - 3386) should equity securities be reported at a consolidated value or social value.

      06 Aug: FC.01

      EIOPA clarified in Q&A (#FICOD028 - 3385) in which category must be reported investments in funds (FC01/FC0120/Instrument).

      06 Aug: FC.06, FC.07, FC.08, S.37.01, S.37.02, S.37.03

      EIOPA clarified in Q&A (#FICOD030 - 3141) a number of questions on the topic of reporting templates on risk concentrations and intra-group transactions for conglomerates.

      06 Aug: S.36.01, S.36.02, S.36.03, S.36.04

      EIOPA clarified in Q&A (#FICOD032 - 2945) additional detail regarding the inclusion of intragroup transactions within a single economic operation.

      08 Aug: Article 28(5)

      EIOPA clarified in Q&A (#DORA188 - 3200) which standards Article 28 (5) of DORA in relation to ICT third party risk management is referring to.

      08 Aug: Article 28(3)

      EIOPA clarified in Q&A (#DORA187 - 3199) a number of questions on the Register of Information as part of DORA.

      11 Aug: S.14.01

      EIOPA clarified in Q&A (#3336) which fields in S.14.01.01.05 should report discounted values, in line with Commission Implementing Regulation EU 2023/894 and an update on the modelling.

      25 Aug: 245 of SII DirectiveS.36.01, S.36.02, S.36.03, S.36.04, S.36.05

      EIOPA clarified in Q&A (#3259) which intragroup transaction templates (S.36.01 to S.36.05) must be reported both annually and on an ad hoc basis in case of very significant transactions, as required by Article 245 of Directive 2009/138/EC.

      25 Aug: S.36.04

      EIOPA clarified in Q&A (#3093) does the description of the net receivable column in template S.36.04 include claims from reinsurance and coinsurance arrangements, as well as other transactions transferring insurance risk between group entities.

      UK Updates

      FCA: Cyber Coordination Group Insights


      On 14 August 2025, the FCA published a summary of the discussions held throughout 2024 with industry members of the FCA’s Cyber Coordination Group (CCG) programme.

      FCA: Life insurers’ pension transfer process


      On 10 July 2025, the FCA reported on the final outcome of Strategy 2022 – 2025 which has now come to an end.

      PRA: Speeches


      In July 2025, the PRA published the following speech entitled Five ‘C’s for Central Bank research – speech by Catherin L. Mann.

      PRA: Regulatory Digest


      On 01 August 2025, the PRA published their regulatory digest for July 2025.

      PRA: Review of the analytical framework supporting financial policy at the Bank of England


      On 19 August 2025, the PRA published Financial Stability Paper No. 52, covering their review of the analytical framework supporting financial policy at the Bank of England.

      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
      Niall Naughton

      Partner, Head of Insurance

      KPMG in Ireland

      Tackle complex challenges in a world of regulatory change, operational pressures and digital transformation
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