The European Captive Insurance and Reinsurance Owners' Association (ECIROA) has recently published its comments on CEIOPS' Issues Paper on Implementing Measures on System of Governance. ECIROA, a newly formed representative body for European captive insurers, noted in its comments that captives were generally very small companies that were "obliged to comply with the established and advanced internal control and reporting guidelines and policies imposed by the risk management functions of the parent". ECIROA claimed that imposing more than minimum control and reporting requirements on captives would therefore be disproportionate.

ECIROA's full response to the Issues Paper can be found here.