Insurance recovery plans to cover firms with 60 percent market share
Recovery-plan requirements will narrow to insurers covering 60 percent of Ireland's market from January 2027, Central Bank of Ireland Deputy Governor McMunn said at Insurance Ireland on October 22, 2026. Simplification will retain policyholder safeguards.
Fewer plans, unchanged safeguards
McMunn said the Insurance Recovery & Resolution Directive's implementation in January 2027 will replace the current pre-emptive recovery-plan requirement.
Plans will apply only to a small number of firms covering 60 percent of the market.
Revised Solvency II rules apply from January 30, 2027, with tailored treatment 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.
It is reviewing more than 25 domestic instruments for amendment, consolidation or removal.
These measures follow its December 10, 2025 roadmap.
McMunn said simplification means clearer, proportionate requirements, not deregulation or weaker protection.
Digital dependencies meet flood exposure
McMunn urged insurers to test recovery arrangements and understand dependencies on cloud and technology providers, using DORA to manage operational risks.
Boards remain accountable for AI, including fair premiums and claims decisions; the AI Act covers high-risk life and health insurance pricing and risk assessment.
Climate risks include catastrophe losses, reinsurance costs and litigation.
Central bank research in 2024 found about 1 in 20 buildings struggled to access flood cover; it supports the Department of Finance and the Flood Insurance Working Group.
Cross-border scale demands accountability
Ireland has the EU's fourth-largest life and non-life insurance sector, with over 170 authorised insurers and reinsurers.
McMunn said boards must understand risks and meet obligations across borders.
European supervisory priorities for 2027–2029 include insurer resilience and conduct, with continuity planning a focus for 2027.