At the same time, the industry raised serious concerns about the approach of the European Insurance and Occupational Pensions Authority (EIOPA) and the European Systemic Risk Board (ESRB) towards the review of Solvency II, which would needlessly undermine insurers' abilities to do so.
EIOPA is currently drafting its final advice to the Commission on the review. While EIOPA has said it is aiming for a "balanced outcome", its current approach would actually lead to a significant increase in capital requirements for insurers, make insurers' solvency ratios even more volatile, especially during periods of crisis, and trigger more pro-cyclical behaviour.
At the same time, the ESRB - the governance of which EIOPA forms a part of - has made proposals for new macroprudential tools and measures that would create unnecessary additional capital and operational burdens for insurers. This would make it harder for insurers to make the long-term investments that are needed to boost economic recovery and growth in Europe.
Instead, the review of Solvency II should focus on improving existing instruments to fully reflect insurers' long-term business model, to mitigate artificial volatility and to reduce unnecessary operational burdens. This would avoid unnecessary costs for customers and help insurers to support the Commission in delivering on the objectives it has set out in the EU Green Deal and the CMU.
The other signatories were the Pan-European Insurance Forum, the CFO Forum, the CRO Forum and the Association of Mutual Insurers and Insurance Cooperatives in Europe.