In April 2013, we reported that EIOPA had launched a public consultation (which has now since closed) on draft guidelines for the preparation of Solvency II (EIOPA Guidelines). On 24 May 2013, the Central Bank of Ireland hosted an industry conference on the EIOPA Guidelines.
The conference opened with a presentation on the EIOPA Guidelines by Ana Teresa Moutinho of EIOPA. Ms Moutinho explained that EIOPA proposes to issue guidelines that will enable national competent authorities and the insurance industry to prepare for Solvency II in a convergent fashion. The speech focused on EIOPA’s expectations of both national competent authorities, and (re)insurers (both at company and group levels) from 1 January 2014 onwards. While EIOPA’s draft guidelines were open for public consultation, EIOPA does not expect that consultation to result in many substantive amendments.
Gareth Colgan (Deputy Head of Prudential Policy Division of the Central Bank) gave an overview of the Central Bank’s proposed approach to implementing EIOPA’s guidelines in Ireland. During his speech, Mr Colgan noted that the Central Bank will introduce its own guidelines for (re)insurers and insurance groups, but that the Central Bank’s guidelines will closely follow the EIOPA Guidelines (both in terms of content and wording).
Reflecting the preparatory nature of the EIOPA Guidelines, the Central Bank will adopt a proportionate, pragmatic and practical approach. High and medium-high impact firms (under ‘PRISM’) will be subject to the Central Bank’s guidelines from 2014. Low and Medium-Low impact firms will be subjected to a phasing-in process during 2014 and 2015.
During the interim period leading up to the implementation of Solvency II, the Central Bank’s Corporate Governance Code and Fitness & Probity regime will both continue to apply. It is expected that the EIOPA will issue finalised guidelines in Q4 2013, with the Central Bank’s guidelines to follow shortly thereafter.