Cumulative Regulatory Burden: EU Requirements Affecting Insurers Since March 2023 (Insurance Europe)

Summary

• In March 2023, the European Commission committed to reducing reporting requirements by 25% to reduce red tape and strengthen European competitiveness.p.1
• The initial CSRD Level 2 package consists of 1 delegated regulation containing 12 ESRS across approximately 284 pages.p.3
• The Solvency II review Directive spans 91 pages of Level 1 legislation and includes 13 technical standards in scope, comprising 7 new and 6 revised mandates.p.3
• The AI Act contains 144 Level 1 pages and includes 14 delegated-act empowerments under Article 97.p.4
• The Retail Investment Strategy (RIS) proposal would introduce 24 new Level 2 & 3 measures across the Insurance Distribution Directive and PRIIPs KID Regulation.p.5

Key insights

1. Insurance Europe calls for addressing the cumulative interaction between regulatory requirements rather than reviewing each legislative file in isolation.p.2
2. Level 2 delegated acts, technical standards, and supervisory guidelines significantly increase the operational compliance burden beyond Level 1 EU legislation.p.1
3. The Taxonomy extension involves 2 major Level 2 delegated regulations combined into approximately 233 pages of screening criteria and disclosures.p.3
4. ESMA's work programme for EMIR 3 identified at least 18 new RTS/ITS mandates covering active account requirements, supervisory procedures, and margin rules.p.4
5. Under the End-of-life vehicles Regulation applicable from 1 September 2028, insurers face new obligations to assess whether a vehicle is an ELV.p.5