Insurance and Reinsurance 2026

IRELAND Law and Practice Contributed by: Grainne Callanan, April McClements and Aisling Kavanagh, Matheson LLP

lin – was named in the InsurTech100. Companjon is Europe’s leading specialist in 100% digital, unique add-on insurance. Companjon has been recognised by Forbes as “a tech-driven disruptor that is changing the way people think about insurance”. In September 2025, the Department of Finance announced a strategic partnership with Lloyd’s under which Ireland will host a dedicated cohort of the Lloyd’s Lab Accelerator Programme (“Programme”) in the first half of2026 with the aim of helping innova- tive ideas gain traction and achieve success in the insurance market, providing an opportunity to develop new technology solutions while being guided by expe- rienced insurance professionals. The Department of Finance has described this development as a land- mark opportunity to showcase Ireland’s position as a hub for insurance and financial services. The Programme also supports the objectives of the Ireland for Finance Strategy as regards enhancing Ire- land’s competitiveness and innovation. 10.2 Regulatory Response The CBI is responsive to the challenges posed by the regulatory treatment of financial innovations. It is a robust regulator, acknowledging the need to strike the appropriate balance between encouraging innovation- related market entry and ensuring new entrants are sufficiently prepared to fulfil all their regulatory obli- gations in relation to financial stability and consumer protection. The CBI is cognisant of the need to keep abreast of the changing technological environment and has committed significant resources to improv- ing its data architectures and establishing quantita- tive analytical teams across its banking, insurance and markets directorates. The CBI has taken a range of measures in relation to fintech, including: • establishing the Innovation Hub for engagement with fintech companies; • creating an innovation steering group and a fintech network within the CBI; and • engaging with the European Supervisory Authori- ties and the Single Supervisory Mechanism on the EC’s Fintech Action Plan.

In June 2024, the CBI announced its intention to estab- lish the Sandbox, with a call for applicants announced in October 2024. The inaugural Sandbox’s theme was “ Combatting Financial Crime,” with the aim of deploy- ing innovative technology to develop solutions that minimise fraud, enhance KYC/AML/CFT frameworks, and improve transaction security for consumers. The CBI held a showcase event in June 2025, highlighting the work carried out over the course of the Sandbox. In September 2025, the CBI announced a call for applications for its second Sandbox, with the theme “Innovation in Payments” . 11. Emerging Risks and New Products 11.1 Emerging Risks Affecting the Insurance Market “Emerging risks” are new, evolving risks that are diffi- cult for insurers to assess and that carry a high degree of uncertainty regarding their impact, probability, and expected losses. The CBI expects Irish insurance undertakings to consider assessing emerging risks and to adopt a longer-term perspective than is typical in business planning and strategy-setting processes. The CBI expects to see evidence of robust analysis and timely, effective action relating to emerging risks. With cyber-risk and digitalisation risks being the most formidable emerging risks in Ireland, it is worth noting that, in terms of climate risk, the CBI’s view is that change risk has now moved from an emerging risk to a key risk, given the impact that climate change is already having on the insurance sector. The CBI expects (re)insurers to manage climate risks in the same manner that they manage other key risks within their risk management framework. Cyber-Risk Digital innovation and growing sophistication in digi- tal technology have led to increased cybersecurity threats and data breach risks. The CBI published cross-industry guidance on IT and cybersecurity risks in 2016, highlighting a range of emerging threats. This guidance noted that IT and cybersecurity, and associ- ated risks, are a key concern for the CBI. In October 2020, the European Insurance and Occupational Pen-

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