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The industry said it fully supports EIOPA’s intention to propose "a material reduction in the scope of quarterly reporting" and for "an increased proportionality of supervisory reporting and public disclosure".
However, while EIOPA’s proposals include some potentially helpful concepts, it will not achieve its intentions because EIOPA has also introduced significant additional reporting and proposed changes to existing templates. This means that EIOPA’s current proposals would in fact lead to an increase in the overall burden. Furthermore, no evidence has been provided that the costs of all the new reporting or changes are justified by sufficient benefits.
Therefore, EIOPA’s proposed changes need improving to: ensure any new reporting is useful and proportionate and to avoid proposals that would lead to an overall increase, rather than decrease, in both the cost and the burden of reporting. The industry also urged EIOPA to consider the cost/benefit of increased reporting requirements and of making changes to existing templates.
Full joint response on Insurance Europe