Recovery plans to cover insurers with 60 percent market share
Mary-Elizabeth McMunn, Deputy Governor of the Central Bank of Ireland, set out insurance reforms at Insurance Ireland in Dublin on October 22, 2026. She stressed operational resilience, responsible AI use and consumer protection.
Simpler rules retain policyholder safeguards
Revised Solvency II rules apply from January 30, 2027, with tailored requirements for eligible smaller, non-complex insurers.
The central bank offered voluntary pre-applications, published FAQs and held workshops; formal application guidance is planned for Q4 2026.
A compatibility review covers more than 25 domestic instruments, with amendments, consolidation or removal to eliminate overlap.
When the Insurance Recovery and Resolution Directive is implemented in January 2027, the existing pre-emptive recovery plan requirement will end.
Recovery planning will then apply only to a small number of firms covering 60 percent of the market.
McMunn said simplification is not deregulation: supervisory objectives and consumer safeguards remain unchanged.
Digital dependencies meet climate exposure
McMunn urged insurers to map critical technology dependencies and test recovery arrangements, using the Digital Operational Resilience Act framework.
Boards remain accountable for AI decisions, including fair premiums and claims outcomes; the AI Act treats life and health insurance pricing and risk assessment as high-risk uses.
Climate exposures include catastrophe losses, reinsurance costs and litigation.
Central bank research in 2024 estimated that approximately 1 in 20 buildings had difficulty accessing flood insurance.
Trust requires accountable boards
McMunn framed regulatory clarity and resilience as supports for competitiveness, not constraints on growth.
Ireland has the EU's fourth-largest life and non-life insurance sector, with over 170 authorised insurers and reinsurers.
She said boards must understand cross-border risks and meet obligations wherever customers live.