European Union: Insurance Laws and Products

The Insurance (Disregard of Certain Medical History and Miscellaneous Provisions) Act 2026 introduces sweeping changes to the Central Bank of Ireland's regulatory powers over insurers and reinsurers. Beyond the widely discussed "right to be forgotten" provisions for cancer survivors seeking mortgage protection, the legislation fundamentally expands the grounds on which the Central Bank can petition for winding-up orders and extends these powers to cover reinsurers for the first time.

The Central Bank of Ireland has commissioned a comprehensive review of its enforcement activities, examining effectiveness, efficiency, and transparency in light of the evolving financial system. Simultaneously, new regulations establish the 2026 levy framework for regulated entities, while the Department of Finance seeks public input on implementing EU crisis management and deposit insurance reforms.

The Central Bank of Ireland has launched Consultation Paper 171, proposing significant refinements to its domestic actuarial regime and guidance for insurance and reinsurance undertakings. These changes affect the Head of Actuarial Function role, reserving policies, peer review requirements, and various life and non-life specific elements, with the consultation open for submissions until October 2026.

Irish financial services regulations undergo significant updates as MiCA guidelines are incorporated into competency codes, investment firm regulations are amended to address concentration risks, and the Credit Review Act framework takes effect. Meanwhile, European authorities advance sustainable finance transparency rules and strengthen banking supervision methodologies.

The Central Bank of Ireland has published its first Investment Firm and Intermediary Newsletter for 2026, revealing critical regulatory updates and supervisory priorities for Irish (re)insurance intermediaries. The newsletter addresses sector mapping initiatives, commission disclosure practices, complaints handling procedures, and significant changes to intermediary authorisation requirements that firms must navigate.

The Central Bank of Ireland has completed implementation of all twelve recommendations from Andrea Enria's independent review of the Fitness and Probity approval process, following a 2024 IFSAT finding. These reforms introduce significant structural changes including a new F&P Unit, enhanced guidance materials, and improved transparency measures designed to strengthen fairness and efficiency in regulatory assessments of senior financial services appointments.

The publication of Decree No. 2026‑341 of April 30, 2026 marks a decisive shift in the regulatory treatment of French so-called “Autres FIA” (or “other alternative investment funds”...

While most provisions of CICA were commenced in phases during 2020 and 2021 (see our earlier briefings on CICA commencement here and here), section 18(4) remained uncommenced and was subsequently...

On 28 April 2026, the Government approved landmark amendments to the Central Bank (Amendment) Bill 2025 to put a statutory “Right to Be Forgotten” for cancer survivors into Irish law.