Recovery planning for (re) insurers: a new regulatory landscape

The Central Bank of Ireland, on the 25th of June, published its long-awaited consultation paper on regulations, and guidelines, for pre-emptive recovery planning for (re) insurers. The consultation paper points to a substantive change in the regulatory landscape for (re) insurers in Ireland given: (i) the current absence of regulatory requirements; and (ii) the limited amount of existing formalised guidance at an Irish and European level.

The prospective regulations will have a material impact on (re) insurers operating in Ireland, with implications and challenges for risk management frameworks, solvency and liquidity planning, governance structures and senior executive and Board member responsibilities and accountabilities.

The launch of the Central Bank of Ireland consultation paper signifies a material shift in supervisory expectations for (re) insurers in relation to pre-emptive recovery planning. The prospective regulations will set a new standard for firms operating in Ireland, providing a clear framework which requires firms to develop, maintain and ensure appropriate governance of pre-emptive recovery plans. The consultation paper can also be seen as a first step on the road to harmonisation with other European jurisdictions, although progress remains slow compared with the banking and investment firm sectors.

Our article:

• Outlines the key components of the proposed regulatory framework;
• Compares the prospective requirements with other sectors; and
• Highlights some of the key challenges arising for firms. 

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