EIOPA's New Diversity Guidelines For The Boards Of (Re)Insurers

EIOPA has published a new set of Guidelines on diversity considerations for the boards of directors of (re)insurers, effective from 30 January 2027.

These Guidelines aim to harmonise supervisory practices and promote cross-sectoral consistency across the EU insurance sector, following recent amendments to Article 41(1) of the Solvency II Directive.

Applicable to all (re)insurers and insurance groups, the Guidelines are designed to align with similar diversity requirements already in place for banks and financial market participants, supporting a coherent approach across the EU's financial system.

The Guidelines encourage greater diversity among board members based on factors such as educational and professional background, age, gender, and geographical origin. These considerations should be integrated both during the recruitment process and on an ongoing basis. By fostering a broader range of perspectives, the measures aim to support independent thinking, reduce the risk of groupthink, and ultimately enhance the quality of decision-making within (re)insurer boards.

Key Features

The Guidelines include a definition of diversity, which encompasses a range of characteristics such as educational and professional background, age, gender, and geographical origin. This definition sets the foundation for the expectations placed on (re)insurers in shaping the composition of their boards of directors.

Under the amended Article 41(1) of the Solvency II, all (re)insurers are required to adopt a formal diversity policy that includes specific gender balance targets for their boards. Notably, Guideline 1 (Paragraph 11) of the Guidelines addresses the principle of proportionality. EIOPA has clarified that this principle does not exempt (re)insurers from compliance, regardless of their size or complexity.

Importantly, proportionality cannot be used to avoid setting quantitative gender balance objectives. Instead, all (re)insurers must define how and when they intend to meet these targets, and are expected to use benchmarking data from national regulators or international organisations to inform their approach.

The Guidelines also require (re)insurers to establish clear implementation timelines, monitor and document progress, and take corrective action where targets are not met. This marks a shift toward greater accountability and transparency, embedding enforceable standards for board diversity within the governance framework of (re)insurers.

In addition to board-level requirements, the Guidelines reflect EIOPA's broader ambition to foster a cultural shift across the insurance sector. Guideline 7 encourages (re)insurers to extend their diversity policies beyond board appointments to encompass staff and management pipelines. While these measures are less prescriptive than those applying to boards, they signal a clear expectation that diversity and fairness should be embedded throughout the entire organisation.

Implications for Irish (Re)Insurers

It seems reasonable to expect that Irish (re)insurers will be well-positioned to meet EIOPA's new diversity requirements (assuming the Central Bank opts to comply). Ireland already has a firm foundation in place: Section 14.9 of the Central Bank's Corporate Governance Requirements for Insurance Undertakings (2015) requires boards to implement a written diversity policy and encourages diversity throughout the organisation. This was further supported by the Central Bank's 2020 'Thematic Assessment of Diversity and Inclusion in Insurance Firms', which outlined supervisory expectations for embedding diversity and inclusion across governance structures, including some quantitative benchmarks and expectations around gender representation, pay equity, and measurable D&I planning.

Although the current Irish framework provides a strong starting point, the Guidelines introduce measurable targets and defined timelines. Irish (re)insurers may therefore need to enhance their existing policies to include quantifiable commitments and structured implementation plans. Nonetheless, the governance groundwork laid by the Central Bank in recent years should support a smooth transition ahead of the 30 January 2027 implementation deadline.

EIOPA's new Guidelines mark a notable shift in the regulatory approach to board diversity in the (re)insurance sector. By introducing enforceable gender balance targets, removing proportionality as a basis for exemption, and encouraging broader organisational change, the Guidelines go beyond the current Irish framework. (Re)insurers operating in Ireland will need to reassess their governance policies, ensure measurable diversity objectives are established, and prepare for increased regulatory scrutiny. As the 2027 deadline approaches, early engagement and proactive compliance will be key to meeting these evolving expectations.