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Bolder, Simpler, Faster – Strong Promises from EIOPA, but What Might It Mean in Practice?
Gary is a Principal Consultant within our insurance practice in Dublin. He has 16 years of experience within the life and non-life (re)insurance sectors covering industry, audit and consultancy roles. His expertise covers financial reporting, prudential and conduct risk management, and assurance activities. Gary has provided outsourced actuarial, risk, compliance, and internal audit function services for a wider range of insurers, reinsurers and captives.
Bolder. Simpler. Faster. One would be forgiven for thinking that this could be the title of a new Daft Punk track. It is in fact the latest publication from the European Insurance and Occupational Pensions Authority (‘EIOPA’).
As political priorities shift across Europe, the call to lighten regulatory burdens has grown louder. In this context, competitiveness has surged to the top of the agenda.
In its new paper, the Authority outlines its vision for streamlining rules and reducing the administrative load. But what does this mean in practical terms?
A Changing Landscape
EIOPA has long championed greater harmonisation across member states, and its latest publication reaffirms that stance. It explicitly highlights the issue of “unnecessary regulatory divergence (gold-plating)” which it argues leads to “fragmentation of the Single Market.”
While EIOPA is quick to clarify that promoting competitiveness is not part of its core mandate, EIOPA “acknowledges the new political priorities of the European Union.” The Authority cites the European Commission’s goal of slashing reporting obligations by at least 25% across all companies as a driving force behind this renewed push for regulatory efficiency.
"EIOPA acknowledges the new political priorities of the European Union."
Despite the rhetoric, EIOPA stops short of advocating for the kind of sweeping deregulation seen in some other jurisdictions of late. Instead, it suggests that better use of technology, data, and automation can make supervision more efficient — without compromising prudence.
Prudential Reporting: Time for a Reset?
Financial reporting has long been viewed as a necessary evil in the insurance sector. EIOPA is aiming to ease this burden through revisions to the Implementing Technical Standards (‘ITS’), targeting:
- Removal of certain templates, tables, and data points;
- Reduced reporting frequency;
- Enhanced proportionality via updated materiality thresholds; and
- Simplified instructions and templates.
Additionally, the Authority has initiated work to streamline all Level 3 texts, with an ambitious goal of cutting the number of articles by a staggering 25%.
A Clearer Proportionality Framework
Perhaps the clearest signal of EIOPA’s new approach came in January 2025, with its Technical Advice to the European Commission on proportionality. While the updated Solvency II Directive defines “small and non-complex undertakings” eligible for tailored regulatory treatment, EIOPA goes further.
Its advice provides more detailed guidance on how proportionality measures could be applied to a broader range of small and mid-sized insurers that don’t fall under the formal “small and non-complex” definition.
Streamlining the Green Agenda
The Solvency II review introduces new obligations for insurers to develop specific sustainability risk plans. However, EIOPA has emphasised that these should build upon existing data and processes — such as Own Risk & Solvency Assessment (ORSA) scenarios and Corporate Sustainability Reporting Directive (CSRD) / European Sustainability Reporting Standards (ESRS) disclosures. A core principle, the Authority notes, is to “ensure that these data points can be used again.”
EIOPA also voiced support for the European Commission’s Sustainability Omnibus package, which aims to simplify the EU’s complex sustainability reporting framework. EIOPA has committed to contributing, where appropriate.
Digitalisation and AI: Modern Tools, Streamlined Supervision
Under the revised Solvency II Directive, EIOPA has been tasked with drafting a report on integrated data reporting. Its stated aim is to “reduce the area of duplications and inconsistencies between the reporting frameworks in the insurance sector and other sectors.”
A central pillar of this effort is the European Single Access Point (‘ESAP’), which will consolidate data from a variety of EU regulations into a single, structured platform. If effectively implemented, ESAP could enable automatic data extraction and support RegTech innovation, easing the burden on firms.
In parallel, EIOPA has launched a public consultation on its “Opinion on AI Governance and Risk Management,” focusing on proportionate risk oversight and mapping existing insurance regulations onto the evolving AI landscape — rather than creating new prescriptive rules.
Financial Stability Efficiencies
Stress testing requirements have already been made more manageable, with EIOPA reducing the frequency of insurer stress tests to a three-year cycle. It is also expanding its use of top-down analysis, aiming to extend bottom-up stress tests to a four-year cycle or longer.
The Authority adds that “efforts are also underway to significantly limit or replace current liquidity monitoring reporting with Solvency II data analysis for greater efficiency.”
Consumer Protection: Less is More
Outputs from EIOPA’s recent mystery shopping exercises have cast doubt on the notion that more regulation automatically leads to better consumer outcomes. While complex rules may be well-intentioned, they can sometimes hinder — rather than help — the sales process.
EIOPA notes that initiatives such as a summary dashboard in the Packaged Retail Investment & Insurance Products (PRIIPS) Key Information Document (‘KID’) could reduce the burden on intermediaries without compromising transparency.
Policy Making & Supervision: A Centralised Approach
EIOPA doesn’t mince words in its latest report when it comes to the EU legislative process.
“Greater involvement from EIOPA during Level 1 negotiations, especially for horizontal legislation, would help to ensure solid technical input to co-legislators regarding the need of specific mandates.”
“The legislative process should always strive to provide adequate consultation periods and sufficient implementation time.”
It also criticises “minimum harmonisation” approaches, warning that they can “lead to market fragmentation, barriers to entry and regulatory arbitrage.” Diverging national rules — so-called “general good” provisions — only add to the complexity.
There’s also a subtle but clear call for a stronger central mandate, with EIOPA suggesting that a more empowered Authority could prevent the inefficiencies that result from taking separate approaches across 27 Member States and seeking convergence afterwards.
A Watchful Eye on What Comes Next
EIOPA’s messaging is clear: simplification doesn’t mean dilution. With a focus on smarter, more proportionate, and digitally-enabled supervision, the Authority is aiming to modernise Europe’s regulatory landscape without compromising its core objectives. But as ever, the real test will lie in how these ideas translate into day-to-day supervisory practice across the continent.
With so many moving parts — from AI and sustainability to data reporting and consumer protection — the success of EIOPA’s “Bolder, Simpler, Faster” vision will hinge on collaboration, clarity, and commitment across all stakeholders.
It’s certainly a bold agenda. And it’s one that’s evolving quickly.
It’s safe to say: this is one to watch.
How Finalyse Can Help
In a rapidly evolving regulatory and policy landscape, Finalyse supports (re)insurers across a range of critical areas:
- Assess eligibility under the new proportionality framework, including tailored support for firms outside the ‘small and non-complex’ criteria.
- Facilitate dialogue with national supervisors to justify proportionality measures and align with supervisory expectations.
- Redesign internal processes and data flows to reflect revised reporting templates, thresholds, and digital reporting requirements.
- Integrate Environmental, Social & Governance (ESG) considerations into risk management and ORSA frameworks, leveraging existing Solvency II and sustainability disclosures.
- Develop AI risk management policies that support innovation while ensuring proportionate, principle-based governance.
- Embed liquidity risk management into ORSA and recovery planning, in line with evolving supervisory practices.
- Deliver regulatory horizon scanning and impact analysis to anticipate changes and support proactive implementation.
Please reach out to one of our experienced Finalyse consultants at insurance@finalyse.com for more information
Appendix
Frequently Asked Questions
EIOPA’s “Bolder, Simpler, Faster” paper discusses its strategy to streamline insurance regulation across the EU. It highlights reduced regulatory burdens and increased competition, without compromising prudential oversight. EIOPA aims to simplify reporting, reduce administrative complexity, and make better use of digital tools like RegTech and AI. Key focus areas include reducing ‘gold-plating’ by national regulators, updating reporting requirements under Solvency II, and promoting proportional supervision for small and non-complex insurers. The plan also seeks to align sustainability and AI governance with existing frameworks to avoid duplication. Ultimately, it’s about smarter, not weaker, regulation.
EIOPA is taking a balanced approach to AI governance by mapping existing insurance regulations onto the use of artificial intelligence, instead of creating entirely new rules. Its public consultation on AI governance (February 2025) focuses on proportional risk oversight and the responsible integration of AI in underwriting, claims, and other functions. EIOPA is also supporting the development of the European Single Access Point (ESAP), a digital platform to unify regulatory data submissions across sectors. These initiatives aim to modernise supervision, support RegTech innovation, and reduce duplication in compliance processes.
Proportionality is central to EIOPA’s updated approach. The Authority is working to ensure that smaller and mid-sized insurers—especially those not formally classified as “small and non-complex”—can still benefit from simplified supervision. Its January 2025 technical advice provides a broader interpretation of proportionality, with tailored rules, reduced reporting, and more appropriate thresholds. This shift recognises that a one-size-fits-all regulatory model may impose unnecessary burdens on lower-risk firms and aims to better match oversight with actual business scale and complexity.