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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.

The ESAs DORA guide explains the framework's objectives, principles, structure, activities, processes, and expected outcomes. It covers CTPP designation based on criticality, risk assessment, and detailed oversight activities including ongoing monitoring, requests for information, general investigations, and inspections. The document also outlines the issuance of non-binding recommendations for identified deficiencies and subsequent follow-up procedures to ensure compliance, ultimately aiming to enhance digital operational resilience and financial system stability across the EU.

A 2024 DORA Dry Run, involving ~1,000 EU financial entities, showed promising data quality for information registers. 6.5% passed all checks, and 50% passed most. The ESAs, aiming for high-quality registers by 2025, provided support tools and feedback, and will continue workshops to ensure compliance.

“In its Opinion EIOPA is calling on the European Commission to take the necessary actions to avoid disproportionate compliance efforts from small insurance undertakings in the transition period prior to the application of the revised Solvency II Directive.”

Financial institutions must enhance cyber defenses and regulatory frameworks must adapt to new risks. International agencies are creating coherent cybersecurity standards, exemplified by the EU's Digital Operational Resilience Act (DORA). Effective defense also requires robust institutional governance and sector-led standards.