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On 30 September 2025, Seána Cunningham, Director of Insurance at the Central Bank of Ireland (CBI), addressed the European Insurance Forum.
She highlighted the CBI's evolving supervisory approach and its key priorities for the (re)insurance sector. Her remarks focused on resilience in uncertain times, accountability and consumer trust, and the importance of responsible innovation.
New Supervisory Approach
Ms Cunningham acknowledged the opportunities and challenges facing the (re)insurance sector industry, including geopolitical tensions, digital transformation, AI, climate-related risks, and demographic changes. In response, the CBI's supervisory strategy is anchored in four core safeguarding outcomes:
- Consumer and investor protection;
- Safety and soundness;
- Financial stability; and
- Integrity of the financial system.
Building on the PRISM model, Ms Cunningham noted that the CBI's new supervisory approach reflects the increasingly interconnected nature of financial services, whilst not changing the safeguarding outcomes pursued by the CBI. It moves beyond traditional regulatory silos such as prudential, conduct, and anti-money laundering supervision towards a more holistic framework. Under this model, the insurance sector will be supervised in an integrated manner in accordance with a multi-year supervisory strategy with significant insurance firms supervised at an individual firm level.
The CBI's key commitments under the new approach include:
- Continuing to deliver an open and transparent engagement approach;
- Remaining risk-based and outcomes-focused, with a targeted and proportionate approach to supervision; and
- Continuing engagement with key stakeholders such as EIOPA and the International Association of Insurance Supervisors to ensure a consistent application of regulatory standards and coordinated supervisory efforts.
Simplification
Ms Cunningham also addressed efforts to simplify financial regulation at the domestic and EU levels. In Ireland, the CBI has streamlined authorisation and change-of-business requirements and removed the requirement for external audits of captive (re)insurers' regulatory returns and public disclosures. At the European level, Solvency II has been amended to include a proportionality regime tailored to small and non-complex undertakings. Notably, the CBI stressed that simplification must not equate to lowering standards.
Strategic Priorities: Resilience, Trust, and Innovation
The CBI's broader strategic shift places resilience, accountability, and consumer trust at the heart of its supervisory agenda. In an increasingly volatile environment, firms are expected to maintain sufficient financial resources and prudent risk management frameworks to withstand future shocks. The CBI reinforced the importance of transparent governance, consumer trust, and product suitability to ensure consumers can rely on insurers to deliver value and honour commitments when risks crystallise.
Ms Cunningham concluded by emphasising the role of innovation in reshaping the insurance landscape. While new technologies and data-driven solutions, particularly those involving AI, offer opportunities to enhance consumer outcomes, firms must implement appropriate safeguards to ensure their ethical and responsible use.
Contributed by James O'Brien and Caitlin Lenihan
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