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This position paper from Insurance Europe outlines their response to the European Commission's consultation on supplementary pensions, specifically addressing pension tracking systems, pension dashboards, auto-enrolment, and a review of the Pan-European Personal Pension Product (PEPP) Regulation and the Institutions for Occupational Retirement Provision (IORP II) Directive. The document emphasizes the importance of national diversity in pension systems, advocating against "one-size-fits-all" EU-level measures. It provides feedback on the effectiveness and challenges of existing frameworks, offering suggestions for improvement while consistently highlighting the need for flexibility, proportionality, and respect for national specificities in any proposed reforms. The paper also discusses the limited uptake of PEPP due to its complex and restrictive design, and offers insights into optimizing IORP II for long-term investment and member protection.

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 position paper underscores insurance’s central role in financial resilience, noting that roughly 90% of EU consumers hold at least one insurance product. It urges that the new Agenda:
• formally recognize insurance as a strategic enabler of economic and social stability;
• simplify and align regulation to insurance’s specific characteristics;
• support innovation in digitalization and AI with coherent rules;
• streamline consumer disclosures and enhance financial and insurance literacy to aid informed decision‑making.

The European Commission’s AI Continent Action Plan emphasizes the need to significantly expand cloud and data center capacity across the EU to support AI and digital infrastructure goals. The Cloud and AI Development Act aims to incentivize investment and triple current capacity within seven years. The insurance sector supports this approach but warns against restrictive sovereignty measures that could exclude non-EU providers without viable alternatives. It advocates for flexible, risk-based cloud definitions and support for hybrid strategies. The sector stresses that capacity-building, not protectionism, is key to achieving digital sovereignty while maintaining innovation, competitiveness, and international interoperability.

Insurance Europe advocates for simplifying EU digital regulations, including the Cybersecurity Act and upcoming digital omnibus initiatives, to alleviate compliance burdens. The organization seeks to reduce overlaps and duplications in cybersecurity reporting, particularly under DORA, GDPR, and other horizontal legislations. They propose aligning cyber reporting mechanisms and centralizing notifications to multiple national agencies. Additionally, Insurance Europe supports stakeholder involvement in cybersecurity certification development, emphasizing that certification should remain voluntary. Concerns have been raised regarding the European Cybersecurity Certification Scheme for Cloud Services (EUCS), specifically regarding a lack of transparency and the inclusion of sovereignty requirements that could limit service provider choice and increase costs for insurers.

Europe faces a transformative era with political shifts, aging populations, climate crises, and technological disruptions. The 2024 elections highlighted polarization, while war and trade tensions expose vulnerabilities. Insurance Europe emphasizes insurance’s role as a stabilizing force, urging smarter, proportionate regulations. Their strategic reset aligns with EU priorities, focusing on savings, natural disaster protection, AI, and insurance’s societal value to boost competitiveness and resilience.

Insurance Europe responded to the EBA’s consultation on EU anti-money laundering Regulatory Technical Standards, supporting a harmonized, data-driven risk assessment but urging proportionality. They advocate for minimal, targeted data collection, reasonable transition periods, and revised data points to ease burdens, particularly for low-risk products. The federation opposes excessive customer data requirements, supports remote identification, and proposes event-driven updates for low-risk life insurance and simplified due diligence for pensions and pure risk policies. Insurance Europe commits to collaborating for an effective, risk-based AML/CFT framework.

A Europe-wide survey by Insurance Europe and the European Youth Parliament, involving 651 young people from 33 countries, revealed that young Europeans value insurance for protection but find the purchasing process complex and paperwork-heavy. They demand simpler, more digital, and user-friendly solutions. Insurance Europe urges EU policymakers to simplify processes for young consumers.

Insurance Europe urges a simpler, phased approach to the EU’s Financial Data Access (FIDA) framework to boost competitiveness. They highlight the need for clarity on data scope to protect sensitive information and a realistic timeline beyond the proposed 18 months for effective implementation.

Insurance Europe responded to EIOPA's draft Opinion on AI governance in insurance, supporting clarity on existing rules but raising concerns over potential new obligations. It cautioned that the draft's language might lead to supervisory expectations being misinterpreted as binding requirements, conflicting with the EU's simplification goals for smaller firms. Insurance Europe also highlighted risks of dual supervision in some regions and emphasized the need for clear distinctions between different AI types and user roles. It urged EIOPA to focus on aligning the Opinion with established frameworks like Solvency II and GDPR for effective oversight.