Frequently Asked Questions

Firms can assess if they meet the criteria outlined in Article 29a of the amended Solvency II Directive. EIOPA has published a technical specification that provides guidance to firms to identify eligibility for SNCU status. 

It is up to firms, in the first instance, to determine if they meet the criteria in Article 29a, and we are happy to engage directly with firms where they have queries on their status.

The Central Bank does not have any leeway in allowing firms to be SNCUs where they do not meet the criteria, but these firms can apply for the non-SNCU proportionality measures.

For captives, there are two ways to qualify as an SNCU. The first is by meeting the criteria outlined in the first sub-paragraph of Article 29a of the amended Solvency II Directive based on the previous two financial years.

The second is based on the type of business written in the previous two financial years: insured persons and beneficiaries must be legal entities of the group of which the captive is part, or natural persons eligible to be covered under that group’s insurance policies (and the business covering natural persons is below 5% of technical provisions), and the business does not include insurance or reinsurance of any compulsory third-party liability.

It is up to captives, in the first instance, to determine if they meet the criteria in Article 29a, and we are happy to engage directly with firms where they have queries on their status.

It is up to captive firms, in the first instance, to determine if they write or reinsure any compulsory third-party liability insurance. We are happy to engage directly with firms where they have queries on their SNCU status.

Firms that meet the criteria to be an SNCU can formally notify the Bank once the legislation transposing the amended Solvency II Directive comes into effect. For notifications received within the first six months of 30 January 2027, SNCU status takes effect four months after receipt of the complete notification (unless confirmed or opposed by the Central Bank earlier).

It is up to firms, in the first instance, to determine if they meet the criteria in Article 29a of the amended Solvency II Directive, and we are happy to engage directly with firms where they have queries on their status.

If a firm expects to meet the SNCU criteria, and one or more of the proportionality measures takes effect in the first half of 2027 that would require significant additional effort, we encourage the firm to engage with us early in the process. It should be noted that firms still need to make a formal notification, which can only be done post-transposition of the revised Solvency II Directive. Following from this, the Central Bank can only confirm or oppose a firm’s compliance with the SNCU criteria post-transposition.

For firms which have obtained authorisation within the last two financial years, compliance with the criteria in Article 29a will be assessed with reference to the last financial year prior to the classification. Where the authorisation has been obtained within the last 12 months, compliance with the criteria will be assessed with reference to the relevant scheme of operations. For a new authorisation following implementation of the amendments to the Solvency II Directive, where no historical financial data is available, the assessment will be based on the scheme of operations submitted as part of the application for authorisation.

No, the pre-application process is voluntary, but we would encourage firms that intend to apply for non-SNCU proportionality measures, to participate in the pre-application process. 

The Central Bank’s guidance on the pre-application process lists the documents that firms should provide when submitting a pre-application for proportionality measures. The intention is that firms would submit the relevant document that it has readily available. It is not the intention that firms would create or materially revise existing documents for the submission.

If the listed document isn’t available or it does not have all the detail needed, it may be possible for the firm to provide alternative quantitative or qualitative data to evidence that the non-SNCU proportionality criteria are met.

Yes, the firm can include most recent Business Plan in its pre-application submission. Firms should be mindful of the application of Article 29d(1) of the Solvency II Directive.

Once the firm has a more up to date Business Plan available after 30 January 2027, the firm can provide this in the formal application and explain the changes between the pre-application and formal application. The same applies for other documents on the pre-application checklist.

Yes, if a firm has completed an ad-hoc ORSA during the year, this should be submitted as well as the most recent full ORSA. This will give an up-to-date picture of the firm’s risk profile for assessing the pre-application.

If a firm has already submitted its ORSA or ad-hoc ORSA as part of normal supervision, these do not need to be re-submitted as part of the pre-application. Firms can indicate in their pre-application submission that the documents have already been shared with the Central Bank.

The Central Bank does not expect firms to calculate this, and it is not in the documentation checklist in our guidance for the pre-application. The Central Bank will calculate firms’ market share using data from the quantitative reporting templates (QRTs). However, if a company has a view as to its market share, it can include it in the pre-application submission.

The size of the market will be calculated by the Central Bank in accordance with the EIOPA Guidelines on market share for reporting. This can be derived from published EIOPA Statistics or alternatively from the Central Bank’s SFCR repository.

Under the amended Solvency II Directive , the frequency of the RSR is every three years for non-SNCUs.

If deemed necessary, the Central Bank could require firms to report the RSR more frequently (e.g. every one year or two years).

Only if the Central Bank decides to set the frequency of the RSR at one year or two years for non-SNCUs, would it make sense for a firm to apply for less frequent RSR reporting (i.e. to have a 3-year RSR cycle rather than every 1 or 2 years).

We plan to communicate our position to industry before the end of this year.

In the meantime, companies are welcome to include the proportionality measure for the RSR in the pre-application submission. 

We expect to respond to firms engaged in the pre-application process in Q4 2026. However, the timing of the Central Bank’s response depends on when a firm submits its pre-application and the complexity of the submission.

The Central Bank will respond to all firms that participate in the pre-application process, either seeking additional information or confirming we do not need additional information

If a firm has concerns about whether it will meet the SNCU criteria when 2026 data is taken into account, it can consider taking part in the pre-application process for non-SNCU proportionality measures. Their pre-application will be reviewed, similar to all other pre-applications received between 1-30 September.

Yes, that is correct. 

Yes, similar to other types of post authorisation applications such as a Change of Business Plan, we encourage firms to engage early with the Central Bank in advance of submitting a formal application for non-SNCU proportionality measures.  

Firms intending to submit a formal application after 2027, are encouraged to refer to the Central Bank’s guidance on applications for non-SNCU proportionality measures (which is due for publication in Q4 2026) and talk to their supervisor.

Non-SNCU firms wishing to seek approval to use proportionality measures can submit a formal request in writing to the Central Bank once the legislation transposing the amended Solvency II Directive comes into effect. This means that firms can submit an application for non-SNCU proportionality measures from 30 January 2027, subject to the amended Solvency II legislation being transposed by that date. 

A firm can use the non-SNCU proportionality measures from the date the Central Bank informs the firm of its approval (which may have terms and conditions attached).

We plan to publish guidance for industry on formal applications for non-SNCU proportionality measures. Details will follow in Q4 2026. 

We are offering a pre-application assessment process where non-SNCU firms can engage with the Central Bank on their proposed use of proportionality measures, in advance of the formal application in 2027. The window for pre-applications to be submitted is from 1-30 September 2026.  

The pre-application process will not result in the pre-approval of any of the proportionality measures. Once a pre-application is submitted and reviewed, the Central Bank will indicate whether further information is required during Q4 2026.  Approval for use of proportionality measures can only be granted following receipt of a formal application after Directive (EU) 2025/2 has been transposed into Irish law and come into effect.

An external guide for firms intending to submit a pre-application is on our website here, on our website, explaining how the process will work and it contains a checklist of documents for inclusion in the submission.

No, the use of non-SNCU proportionality measures is subject to prior approval by the Central Bank.

The timelines for approval are within four months from the date of submission of a complete application received before 31 July 2027, or two months if the application is received after 31 July. These timelines may be suspended where the Central Bank requires further information in order to complete its assessment – in such a case the timeline for approval would be suspended for the period between the date of the Central Bank’s first request for information and the receipt of the response to that request (suspension applies only to a first request for information). 

A firm can use the proportionality measures once it receives prior approval from the Central Bank, not from the date of submission of the formal application.

The Central Bank can only confirm or oppose a firm’s application of non-SNCU proportionality measures post-transposition. Hence, a firm can use the non-SNCU proportionality measures from the date the Central Bank informs the firm of its approval, but not before that. 

Non-SNCU firms can apply for prior approval for some, or all of the proportionality measures listed in Article 29d of the amended Solvency II Directive.  A firm should list the individual proportionality measures it proposes to use in its application to the Central Bank.

It is possible that a non-SNCU firm could receive approval to use some of the proportionality measures but an objection to use other proportionality measures that were requested in the application. 

Firms that would like to engage in a pre-application process can submit it to the Central Bank between 1 and 30 September 2026.

The volatility adjustment is not one of the new proportionality measures introduced by Solvency II amendments. Following transposition of the amended Solvency II Directive, firms will be able to apply to use a new Volatility Adjustment (VA), or apply for undertaking specific adjustments to the VA. We are open to early engagement in 2026 with firms that are planning to submit a VA application, in advance of the formal application.

Similar to the non-SNCU proportionality measures, the VA is a measure that requires prior supervisory approval for firms to be able to use it.

While the pre-application for non-SNCU proportionality measures is open for submissions between 1 and 30 September, early engagement on the VA is welcome at any time before the formal submission.

If a firm currently has approval for an individual to perform more than one key function holder role, or any other proportionality measure that corresponds to existing measures under the Solvency II Directive, prior to 28^th January 2025, it will be permitted to keep using that measure for up to a further four financial years after that date or until the expiry of the period of permitted use under the current regime, if earlier.

Within that period, we would expect the firm to apply to the Central Bank to use the proportionality measure as a non-SANCU. Otherwise, when the four-year period ends or the period of permitted use under the current regime has expired, the firm will need to stop using that measure.

If a firm currently has time-limited permission to use a proportionality measure under the current regime, and it perceives there will be issues with timings, it should engage with its supervisory contact before January 2027. 

Firms can apply for non-SNCU proportionality measure (including combining key functions) following transposition of the amending Solvency II Directive and should apply before its approval under the current regime expires or before 28 January 2029 (whichever comes first), to be able to continue combining key function holders. 

As the new proportionality measures in Article 29 of the amended Solvency II Directive are not applicable for Third Country Branches (TCBs), we are not proposing to incorporate these proportionality measures into the Central Bank’s TCB regime.

Approval to use non-SNCU proportionality measures may be amended or withdrawn by the Central Bank at any point in time if the firm’s risk profile has changed, as referenced in the Amended Solvency II Directive, Article 29d (5). Where this is the case, the Central Bank would communicate its decision in writing to the firm, stating the reasons.

We anticipate that a firm would get advance notice of our intention to amend or withdraw approval, as part of our regular supervisory engagement.

In general, a firm’s approval to use non-SNCU proportionality measures will be withdrawn if any of the conditions in Article 327 b-f of the amended Delegated Acts are no longer met. This will be the case unless any exception outlined in the Delegated Acts applies.

If the Central Bank applies Terms and Conditions (T&Cs) to the formal approval for a firm to use non-SNCU proportionality measures, the T&Cs would be included in the decision letter from the Central Bank in relation to the application for proportionality measures.

In general, we do not anticipate needing to amend firms’ conditions of authorisation due to approval of proportionality measures. However, there could be some instances where this would be necessary (for instance, if a condition of authorisation imposed on a firm relates to the proportionality measure(s) applied for).

The amended Solvency II regime is applicable from 30 January 2027 for all firms. As the majority of firms have financial year-ends that align to the calendar year end, first reporting under the amended regime will generally be the Q1 2027 quarterly returns.

EIOPA has submitted its final report on supervisory reporting and public disclosure requirements under Solvency II to the European Commission for adoption. The decision on adoption by the EU Commission is required by 27 January 2027. While the QRT changes are not formally finalised until after this adoption, we encourage firms to start their preparations based on the latest draft reporting.

The effective date of 30 January 2027 applies uniformly to all firms, regardless of whether a firm operates on a non-calendar year-end basis for financial reporting. This means that all firms must be prepared to comply with the revised regulatory framework from 30 January 2027.

In the draft revised QRT instructions, EIOPA have proposed that certain templates shall not be reported for Annual QRTs with effect from 31 December 2026 (see proposed Annex VII on ITS Reporting Legal Act, Article 40 Transitional Provisions).

Specifically, Annex VII proposes that the annual quantitative templates S.21.01, S.21.02, S.21.03, S.23.02, S.23.03, S.29.01, S.29.02, S.29.03, S.29.04, S.30.01 and S.30.02 of Annex I to Implementing Regulation (EU) 2023/894 for individual firms and the annual quantitative templates S.23.03 and S.37.03 of Annex I to Implementing Regulation (EU) 2023/894 for groups shall not be reported with effect from 31 December 2026.

The QRT changes are not formally finalised until after their adoption by the European Commission. If adopted, under the existing QRT taxonomy, 2.8.2, firms would not have to report these templates in their annual return from 31 December 2026.

2026 SFCRs and RSRs will be under the existing Solvency II regime.

Regarding SE.06.02 (list of assets) and S.08.01 (open derivates) reporting frequency, there is no change to the existing instructions for Annual 2026 reporting. Hence, they do not need to be reported in the Annual 2026 return unless they were exempted from quarterly reporting in line with Regulation 34(6) of the European Union (Insurance and Reinsurance) Regulations 2015 (S.I. 485 of 2015).

There is no change for quarterly QRT submission deadlines, which remain at 5 weeks after the reporting date. For example, a firm with a 31 December financial year end would submit their Quarterly Q4 2026 QRTs by 4 Feb 2027 under the existing taxonomy and their Quarterly Q1 2027 QRT by 5 May 2027 under the new taxonomy.

EIOPA plans to publish term structures using the new methodology in a preparatory phase this year. More details will be released by EIOPA in due course.​ See Q 3596 of EIOPA’s Q&A.

In May, EIOPA published three helpful calculation examples to supplement the Technical Documentation in respect of the amended approach to calculating the risk-free interest rate term structures, that will apply to firms from January 2027 onwards. These can be found under “Background Material” on EIOPA’s webpage covering the risk-free rate term structures.  

EPIFF is required to be reported in the SFCR and in the Regular Supervisory Report (RSR). It does not appear in the draft versions of the new QRT taxonomy 2.10.0.

EIOPA published the QRT taxonomy 2.10.0 on 3 July 2026. View the QRT reporting packages (including Annual templates) and timeline. EIOPA intend for this new taxonomy to be used for reporting dates from 30 Jan 2027, i.e. in line with the wider changes to the Solvency II regime coming into force.

Reinsurance firms may choose not to disclose the part of the SFCR targeted at policyholders and beneficiaries. This derogation is provided for in Article 51 (5) of the amended Solvency II Directive.

Captive reinsurers are not required to disclose the part of the SFCR targeted at policyholders and beneficiaries and they shall only be required to include in the part targeted at market professionals the quantitative data required by the implementing technical standards on public disclosure requirements, provided that the conditions in Article 51 (4) of the amended Solvency II Directive are met.

The scope of the sustainability risk plan is in accordance with the amended Solvency II Directive and is independent of the CSRD – and so it is possible for a firm to be in scope for preparing a sustainability risk plan under Solvency II and out of scope under CSRD.

Until the final report on the Regulatory Technical Standard is published by EIOPA, firms may refer to the draft RTS that was issued for consultation by EIOPA, as being a rough indication as to how to comply with the requirements for Sustainability Risk Management Plans in the amended Solvency II Directive.

The Central Bank will also update its Guidance for (Re)insurance Undertakings on Climate Change Risk as part of its Compatibility Review to ensure consistency with the amended Solvency II regulations. The changes to the Bank’s guidance are expected to focus on updates to regulatory references and we do not plan to widen the scope to broader sustainability risk considerations at this point.   The planned publication date of the revised Central Bank guidance is January 2027, to coincide with the transposition.

The Central Bank has no plans to require a separate standalone document for the Sustainability Risk Plan but will expect the requirements of Article 44 (2b) of the amended Solvency II Directive to be clearly documented for both internal governance purposes and supervisory review.

Firms which are covered by a group Sustainability Risk Management Plan and are in the scope of group supervision in accordance with Article 213 (2)(a) or (b), are exempted from drawing up a plan at individual level, under Article 44 (2e) of the amended Solvency II Directive.

Article 44 (2b) of the amending Solvency II Directive, which comes into effect on 30 January 2027, requires firms to have sustainability plans.

EIOPA’s draft RTS on the management of sustainability risks provides that the SRMP should be part of the information submitted to supervisory authorities under Article 35(1); however, the draft RTS has not yet been finalised or adopted.  

In the interim, the Central Bank will consider, in collaboration with other National Supervisory Authorities, if submission of the SRMP will be required and if so, the frequency of submission and will provide further clarity to industry in due course.

The Solvency II Review formally incorporates sustainability risks, which covers environmental, social or governance (ESG) risks, of which climate risk is an element.

The sustainability risk management plan in the amended Solvency II regulations, provides a holistic view on how ESG risks are identified, measured, managed, and monitored in the short, medium and long-term.

Article 144a of the amending Solvency II Directive, which comes into effect on 30 January 2027, requires firms to draw up and keep up to date a liquidity risk management plan. Hence, the requirement to have a LRMP in place is due to begin from 30 January next year. 

This Article also requires firms to submit the liquidity risk management plan to the supervisory authority. The Central Bank will consider, in collaboration with other National Supervisory Authorities, how it will implement this in practice and provide further clarity to industry in due course.

We anticipate that the LRMP would be submitted as a standalone artefact, in addition to submission of other information to the Central Bank, such as the ORSA, Regular Supervisory Report and Solvency and Financial Condition Report.

EIOPA’s final report on the draft Regulatory Technical Standards on Liquidity Risk Management Plans, specifies the content and structure of the LRMP.

As per Article 144a (5) of the amended Solvency II Directive, firms that use the Volatility Adjustment (VA) or Matching Adjustment (MA) may combine the LRMP with their liquidity plans that take into account the use of the VA or MA.

EIOPA’s draft Regulatory Technical Standard on liquidity risk management plans includes criteria for defining which undertakings and groups should include liquidity analysis over the medium and long term. The criteria include assessing both the size of the firm and its liquidity risk exposure.

We plan to engage with firms before year end 2026, if we intend to request that they complete medium and long-term liquidity analysis, when the amended Solvency II regime is implemented. The list of firms requested to complete medium and long-term liquidity analysis will be kept under review.

Firms that have been given approval to use the VA prior to 29 January 2026 are permitted to continue to use it, so long as they continue to comply with the conditions for approval. These firms are permitted to update their calculation in line with the revised Solvency II regulations, including applying the new Credit Spread Sensitivity Ratio (CSSR) adjustment, the macro volatility adjustment and country adjustment factor, without needing to re-apply to the Central Bank.

However, firms that received approval to use the VA on or after 29 January 2026, firms that currently don’t have approval to use the VA and wish to apply, or firms with an approved VA that wish to use an undertaking specific adjustment to the risk corrected spread (Article 77d, 1c), need to submit an application for prior approval to the Central Bank, following transposition of the amendments to the Solvency II Directive. We are open to early engagement with firms at any stage, prior to a formal application.

EIOPA published technical documentation on the method to derive the risk-free interest rate term structures in May, which incorporates Solvency II changes to the Volatility Adjustment (see Sections 9 and 10).

EIOPA also published risk-free interest rate (RFR) extrapolation and Volatility Adjustment (VA) calculation tool to supplement the Technical Documentation in respect of the amended approach to calculating the risk-free interest rate term structures, that will apply to firms from January 2027 onwards. These can be found under “Background Material” on EIOPA’s webpage covering the risk-free rate term structures.  

The IRRD is an EU regulatory framework established to manage failing (re)insurers effectively and with the aim of protecting public funds and maintaining financial stability of the wider market. The Central Bank has commenced its own preparations in order to be ready for the EU transposition deadline of January 2027 when we expect to be designated as National Resolution Authority (NRA) for the insurance sector. Part of this preparation includes interacting with EU NRAs to understand different perspectives and to explore how cross-border groups in scope of recovery and resolution planning might be managed under the IRRD. There will be no requirements placed on (re)insurance firms ahead of the legal transposition. The Central Bank will notify firms likely to be in scope of both recovery and resolution planning in Q3 of 2026, followed by a formal notification process in Q1 of 2027. The scope for recovery planning only will be communicated separately.

The Central Bank will not goldplate its implementation of the IRRD. The Central Bank is actively taking a proportionate, pragmatic yet robust approach to implementation.

Firstly, in terms of our engagement with the Department of Finance (DoF) on the transposition of the IRRD, we have not sought additional powers than those necessary to meet the objectives of the IRRD (Article 1(2) refers).

On a practical basis, we are seeking to leverage the experience gained in the implementation of the banking sector recovery and resolution framework over the last 10-15 years, and to bring that knowledge to the implementation of the IRRD. On scope our general approach is to have the minimum number of firms in scope of resolution planning while meeting the requirements of the IRRD. On data reporting, we are undertaking a stock take of data we already have access to, and engaging with our supervisory colleagues, to avoid duplicative reporting requests. We are also working closely with peer NRAs to ensure that we are broadly aligned with the approach of other Member States. The Central Bank is focused on implementing the IRRD in an efficient and proportionate way, so that firms can have confidence in a stable, predictable regulatory environment.

An impediment can be interpreted as either an obstacle to resolvability or a substantive impediment to resolvability - namely the ability to resolve a firm. Article 15 of the IRRD provides the requirements to action a substantive impediment which is a formal process. Where relevant, the Central Bank will look to work with firms to remove obstacles to resolution in the normal course of business and only resort to the substantive impediment as a last recourse. To date the substantive impediment process has not been required under the BRRD.

The IRRD complements rather than replaces national insolvency regimes. Resolution is intended for cases where resolution objectives are met; otherwise, firms may enter normal insolvency proceedings under national law. It is true that national insolvency frameworks do currently differ, this is something identified as part of applying the BRRD.

First to note that all firms are in-scope for IRRD, but only some firms will be in scope of pre-emptive recovery or resolution planning.

While the scope of firms for recovery and resolution planning calls for a minimum of 40% and 60% of market share respectively, any failing (re)insurance firm could be resolved if it meets the conditions for resolution, including the public interest assessment that it is more beneficial to resolve the firm than put it into insolvency.

The Central Bank will be engaging with potentially in scope (re)insurance firms in H2 of this year. Those firms will be given an opportunity to meet with the supervisors and resolution authority (where appropriate) to ask questions, and to allow firms to plan accordingly and prepare for the implementation from 2027.  Formal notification of in-scope firms will commence in February 2027.

Scope will be determined by a mix of quantitative and qualitative factors. The IRRD calls for a minimum of 40% market share for resolution planning and 60% of market share for recovery planning. The industry event slides include the various criteria used to guide our assessment on scope. As an example, in terms of cross-border activity we have looked at the proportion of gross written premium (GWP) that is written by a firm outside of Ireland and the number of EU countries a firm sells into.

Small and non-complex undertakings will not be subject to recovery or resolution planning requirements.

The Irish insurance market is dynamic and there can be frequent changes to market share, product offering and other aspects of an insurance firm’s business. Consequently, the list of firms in scope of recovery and resolution planning will be kept under review. The list will be reviewed at least every two years, and more frequently in the case of material changes to a (re)insurance firm’s structure or operations. The same scoping methodology will apply.

The Central Bank will engage directly with firms being considered for a change in status (with removal or inclusion on the in-scope of planning list).

They are not aligned. The IRRD contains specific criteria when considering which firms should be in-scope for resolution and recovery planning. These are not aligned with Probability Risk and Impact System (PRISM) ratings; therefore, some PRISM high impact firms may not be in scope and vice versa.

This remains subject to an EIOPA final regulatory technical standard (RTS). The expectation is that cross-border business will still be considered when assessing significance and market coverage, and such firms may still fall within scope depending on size and risk profile.

The 60% calculation is prescribed by the IRRD and relates to Gross Written Premium (GWP) for the non-life market and Gross Technical Provisions (TPs) for the life market.

The IRRD requires the establishment of a resolution fund. But it provides Member States with significant flexibility on the basis on which the fund can be established. The fund can be established on an ex-ante or ex-post basis, or a combination of these.

The funding mechanism and scope for contribution to an IRRD fund has not been finalised yet. The Department of Finance is considering options around the fund in the context of the transposition and is taking account of feedback received from the public consultation on the IRRD which closed in September of last year.

A decision will be taken by the Department of Finance on the matter of funding in due course and the Central Bank will notify firms of the processes around the fund once known.

The scope for recovery and resolution planning is set at 60% and 40% of market share for each of the life and non-life sectors, respectively.

If firms in-scope for resolution or recovery planning are part of an EU Group, and that Group is producing a plan that includes the Irish entity we will be working with the relevant NRA or – from a supervisory perspective – the relevant National Competent Authority to ensure it covers that entity in sufficient detail. If it does not, we will work to improve the Group plan but failing that we may have to resort to a local entity plan.

Third country Groups are not in scope of the IRRD. Irish subsidiaries of third country Groups that are in-scope of the IRRD are treated like primary entities in the EU. The Central Bank will engage with the relevant Group regulator but will also ensure EU level preparations are in place and they are treated on a standalone basis in this case.

The IRRD provides for both EU and non-EU or third Country cross-border business models. EIOPA may conclude non-binding framework cooperation arrangements or MOUs to establish processes and arrangements between the participating authorities for sharing information and cooperation.

The Irish entity is within IRRD scope. The treatment of the UK parent will depend on the Group structure and cross-border cooperation arrangements. Resolution Colleges may still consider the wider Group.

The IRRD is largely based on the BRRD taking differences between the two sectors into consideration.  Some key parallels include:

• The IRRD borrows the core framework established by the BRRD, requiring pre-emptive recovery plans, resolution plans, and Resolution Colleges for cross-border groups.
• Contractual recognition of resolution stay powers, just as the BRRD requires banking counterparties to acknowledge bail-in powers, the IRRD requires (re)insurance counterparties to acknowledge and accept these powers in financial contracts (e.g., derivatives).
• Both Directives apply the ’No Creditor Worse Off’ (NCWO) principle, ensuring no shareholder or creditor incurs greater financial losses in resolution than they would in a normal insolvency or liquidation proceeding; also, the concept of independent valuer is the same.

Some key differences are:

• Absence of a Minimum Requirement for Own Funds and Eligible Liabilities (MREL) that the BRRD requires banks with a resolution strategy to hold. MREL ensures firms maintain sufficient capital and bail-in-able debt to absorb losses and facilitate a smooth resolution without relying on taxpayer funds.
• Critical functions will differ in the insurance sector compared with the banking sector, in which sector services such as certain payment and deposit taking services are established critical function under the BRRD. 
• Resolution strategies are likely to be different, given the variety and number of firms in the market.  e.g. the sale of business tool could be more likely deployed in the insurance sector.
• Insurance is less sensitive to a bank run type scenario and failure may be slower which may have a bearing on actions authorities might take to manage failure.
• The Insurance sector in the EU has more organisational cross-border inter-connectedness than the banking sector, which could have a bearing on the resolution strategy for in scope firms.

Firstly, a reminder that the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1) (Recovery Plan Requirements for Insurers) Regulations 2021 remain in place for 2026, so recovery plans still need to be reviewed this year.

The number of firms in scope to produce recovery plans will be reduced in line with the IRRD requirements to meet a minimum of 60% of market share and the Central Bank’s commitment to the simplification of regulation in the EU. We will not be able to definitively confirm that a firm will not have to produce a recovery plan until the formal notification process is complete in early 2027.

Whilst emphasising that most firms will not have to produce recovery plans on an on-going basis under the IRRD we wish to acknowledge the work all firms have undertaken in developing and maintaining recovery plans to date.

Whilst recovery planning will no longer be a regulatory requirement for all firms, the Central Bank would encourage each firm to consider retaining the beneficial elements of the recovery planning framework within your broader risk management and business continuity arrangements. The insights gained and structures developed through this exercise represent valuable safeguards that can continue to support your firm’s resilience.

There is no change to how the Central Bank reviews recovery plans prepared by (re)insurance firms, and this will continue to be done by your supervisory contacts in Insurance Supervision. Recovery planning in Ireland is relatively mature/advanced and no significant increase in workload for firms or supervisors is anticipated, especially with the move to a two-year cycle.

Group recovery plans may include subsidiaries. The Central Bank will engage with Group Supervisors in assessing group plans that include a subsidiary in Ireland, with the focus being on the parts relevant to the Irish firm. For resolution plans, the Central Bank will also work with relevant group authorities. Resolution Colleges will be established for EU Groups to facilitate an exchange of information and views on group resolution plans.

Our expectation is that Irish entities will be included where an EU group recovery plan exists, however this will be confirmed once guidance on coverage of subsidiaries is received. For third country groups an EU-level recovery plan is required to ensure Irish-specific risks, legal entities and recovery options are adequately covered.

The Central Bank intends to revoke the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1) (Recovery Plan Requirements for Insurers) Regulations 2021 when the measures transposing IRRD come into effect.  The existing Central Bank guidelines on those Regulations will fall away at that point. We expect EU-level guidance on recovery plans to be issued.

The 60% threshold is a minimum market coverage requirement for pre-emptive recovery planning. Supervisors can include additional firms based on their risk profile, size, business model, interconnectedness and substitutability, importance for the economy and cross-border activities. It is expected that the majority of firms will no longer have to produce pre-emptive recovery plans on a regular basis.

The IRRD will require pre-emptive recovery plans for firms that are designated by the Central Bank as in scope for recovery planning (or subject to resolution planning); it does not remove recovery planning obligations for such firms.  

Whilst recovery planning will no longer be a regulatory requirement for all firms, the Central Bank would encourage each firm to consider retaining the beneficial elements of the recovery planning framework within your broader risk management and business continuity arrangements. The insights gained and structures developed through this exercise represent valuable safeguards that can continue to support your firm’s resilience.

Given that the IRRD is due to be transposed and apply from January 2027, firms should assume the first submission after implementation may need to be substantially IRRD-aligned. The Central Bank will communicate submission dates to in-scope firms following the formal confirmation of scope for recovery planning.

It is worth noting a key difference between recovery planning and resolution planning is that the resolution authority drafts the resolution plan, not the firm. That said, authorities are reliant on the in-scope firms to provide accurate information and to assist in removing any impediments to resolvability that may be identified. Firms are essential partners in the process. Firms must ensure Board-level oversight and designate technical leads for operational engagement with the Central Bank as resolution authority. Firms will be required to complete and submit resolution templates where the Central Bank is the lead authority. Irish subsidiaries may be required to provide data within the EU group to satisfy the parent’s resolution authority. The Central Bank will engage with in-scope firms on a bilateral basis to talk through requirements and answer questions you may have.

The Central Bank will engage with in-scope (re)insurance firms to provide guidance. In addition to the structured data returns firms will be asked to provide on a biannual basis, firms could be asked to share information in order to identify any critical functions provided. Firms providing critical functions could opt to maintain an operational continuity document describing how the critical function is maintained.

Firms may consider a process to look at business contracts to ensure they are resolution-proof i.e. contain the relevant clauses to prevent cancellation in case of a resolution event.

A Critical Business Service focuses on customer/service continuity, while an IRRD Critical Function focuses on functions whose disruption could materially affect policyholders, financial stability or the wider economy during recovery or resolution. There will likely be overlap, but not a one-to-one mapping.

The IRRD is due to be transposed and apply from 30 January 2027. Initial recovery planning requests are likely to begin during 2027. We envisage that the initial resolution reporting will be in 2028, this will commence the two-year resolution planning cycle as per the IRRD.