Insurance Europe responds to EIOPA's IRRD public consultations
These responses from Insurance Europe to various consultations by EIOPA concerning the Insurance Recovery and Resolution Directive (IRRD) outline the insurance industry's feedback on guidelines for identifying critical functions, removing impediments to resolvability, criteria for pre‑emptive recovery planning and market share determination, and the content of both recovery and resolution plans, as well as resolvability assessments. A recurring theme across these responses is the industry's call for proportionality, flexibility, and reduced administrative burden, emphasizing that the IRRD's application should consider the unique characteristics of the insurance sector, distinguishing it from banking. The responses also frequently highlight concerns about duplication with existing DORA and Solvency II requirements and the lack of quantitative cost assessments for proposed regulations.