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Insurance Europe has responded to a consultation by the European Insurance and Occupational Pensions Authority (EIOPA) on its proposed amendments to supervisory reporting and public disclosure documents.
While EIOPA’s proposals take
into consideration a few of the many concerns that were raised in the
past by the industry, EIOPA’s proposed changes are disproportionate and
would lead to excessive new administrative burdens and costs for
insurers (which would ultimately be passed on to customers).
This
is because, while EIOPA has made some welcome changes, it has also
introduced significant and mostly unnecessary changes to current quantitative reporting
templates (QRTs), while at the same time introducing new QRTs. This
would all place a significant extra administrative burden on insurers,
without a clear benefit for supervisors.
It would also
significantly increase costs for insurers, who would, for example, need
to set aside major resources to implement, test and validate the
required changes in their IT systems. EIOPA should, therefore, limit any
changes to the reporting package to those that are absolutely necessary
to fulfil its supervisory duties.
Moreover, the timeline
proposed by EIOPA for these extensive changes is too short. The changes
should be made as part of the wider review of Solvency II that is
currently taking place, rather than through a piece meal approach that
will lead to multiple changes being made within a short time frame,
which would further exaggerate costs.