IRELAND Law and Practice Contributed by: Grainne Callanan, April McClements and Aisling Kavanagh, Matheson LLP
• trends in ESG terminology; and • the flood protection gap in Ireland. CBI publishes insights on asset-intensive reinsurance (AIR)
ority expectations which firms are required to assess against are as follows: • that firms will always offer a full suitability assess- ment to consumers who make contact to discuss their existing plan at renewal; • websites should include plan comparison tools; and • there should be sufficient monitoring and oversight of the overall customer support function, including as regards the individual agents. The CBI also highlighted its Guidance on Securing Customers’ Interests and urged all insurers to guaran- tee they are not taking advantage of customer inertia or market information asymmetry. CBI thematic risk assessment of intra-group outsourcing: a review of specialty insurance firms In the second half of 2025, the CBI carried out a the- matic risk assessment (Assessment) across a number of speciality insurance firms. The Assessment focused on intra-group outsourcing arrangements and the related governance and oversight. CBI set out the findings of the Assessment under three headings, as follows. • Substantive presence and decision making– with the Assessment showing that there is significant reli- ance on intra-group outsourcing across the special- ity firms through the use of a shared services struc- ture or third country branch. CBI emphasised that firms must ensure adequate substance in Ireland, with oversight and decision-making at a local level. • Outsourcing framework – the Assessment found that not all firms had an outsourcing policy and an outsourcing strategy that were sufficiently tailored to the local Irish entity and were reviewed annually by the local board. In this regard, the CBI highlights the 2021 Cross Industry Guidance on Outsourcing, specifically that firms must have a documented firm-wide outsourcing strategy and policy, to be reviewed and approved by the board on at least an annual basis. • Use of services companies and hybrid arrange- ments – the CBI notes that it has observed that firms are increasingly entering into arrangements
In March 2025, the CBI stated its intention to issue a data request to a sample of less than 20 life (re)insur- ance firms in Q2 2025 on the use of AIR. In September 2025, the CBI shared insights from the data request, some of which include: • exposure to AIR at the life (re)insurance industry level is broadly in line with what the CBI expected to see, with the total exposure at year-end 2024 at approximately €30 billion, for the firms surveyed; • exposure to AIR is expected to increase by around 5% over the course of 2025; • generally, AIR exposure is well collateralised with high-quality assets; • as regards the default of the main reinsurance coun- terparty, it was found that some firms would breach the 100% solvency capital requirement (SCR). The CBI reminded firms to engage with their supervi- sor if they plan to enter into material AIR transactions, particularly highlighting that a material change to a firm’s business, due to changes in reinsurance and/or retrocession arrangements, requires pre-notification to the CBI as a change of business notification. The CBI has advised that it will continue to monitor AIR as part of its ongoing supervision, taking into account the expected growth in this area. CBI Thematic review on consumer treatment when purchasing or renewing health insurance In July 2025, the CBI concluded a thematic review on consumer treatment when purchasing or renew- ing health insurance (Review). The CBI issued a “Dear Compliance Officer” letter (Letter) in July 2025, which set out the CBI’s findings, both good and bad, on foot of the Review together with its expectations. The Letter requires health insurance providers to com- plete a gap analysis vis-à-vis the CBI’s expectations and to ensure that a plan is put in place to address any identified gaps and weaknesses. Some of the pri-
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