Ireland has a common-law legal system. The law in relation to insurance contracts is primarily governed by common-law principles – the origins of which can be found in case law.

Following the enactment of the Consumer Insurance Contracts Act 2019 (CICA), the Marine Insurance Act 1906 (MIA) only applies to non-consumer contracts. Some forms of insurance are compulsory under Irish law (eg, third-party motor insurance and professional indemnity cover for certain professionals).

There is no Irish equivalent of the UK Insurance Act 2015 for non-consumers. CICA was enacted in 2019 and reformed the consumer insurance law. It commenced in two stages (on 1 September 2020 and 1 September 2021), following industry pressure to allow sufficient time for the insurance industry to account for the far-reaching changes imposed. For consumer insurance contracts, CICA has replaced the duty of utmost good faith and the consumer’s duty of disclosure with a duty to honestly and with reasonable care respond to questions asked by the insurer.

Consumers

There are some restrictions on insurers’ freedom of contract (largely for the protection of consumers), as they are required to comply with Irish legislation enacted to implement EU law. Consumer protection law has undergone several changes as a result of the Unfair Terms in Consumer Contracts Directive 1993/13/EC and the Distance Marketing of Financial Services Directive 2002/65/EC.

When dealing with a “consumer”, the insurer must also comply with the Central Bank of Ireland (CBI)’s Consumer Protection Code 2012 (CPC), the Consumer Protection Act 2007, and the Consumer Rights Act 2022 (CRA). Under the CPC, “consumer” is broadly defined and includes individuals and small businesses with a turnover of less than EUR3 million. The exact definition is applied for CICA purposes. “Consumer” under the CRA is defined as “an individual acting for purposes that are wholly or mainly outside that individual’s trade, business, craft or profession”. It is important to note, however, that the revised CPC (see 12. Developments in Insurance Law) amends the turnover figure to less than EUR5 million. This will take effect on 24 March 2026.

Insurance contracts and the marketing and sale of insurance products to consumers must also comply with the Sale of Goods and Supply of Services Act 1980 (as amended by the CRA).

Ireland has a strong and efficient risk-based prudential regulatory framework that focuses on the application of the proportionality principle.

Central Bank of Ireland

The CBI has primary responsibility for the prudential supervision and regulation of (re)insurance undertakings in Ireland. The CBI performs this role through monitoring and ongoing supervision, and issues standards, policies, and guidance that (re)insurance undertakings must comply with.

The CBI oversees the corporate governance functions, risk management and internal control systems of (re)insurance undertakings without imposing burdensome administrative requirements on their operators. Such undertakings are required to submit annual and quarterly returns on solvency margins and technical reserves for supervisory purposes. The CBI also conducts regular themed inspections across the (re)insurance sector.

The CBI operates a rigorous authorisation process and conducts fitness and probity (F&P) assessments of individuals who are to hold certain designated management functions and positions within authorised firms. It also has responsibility for consumer protection issues.

Risks and risk ratings

An administrative sanctions regime provides the CBI with a credible enforcement tool and acts as an effective deterrent against breaches of financial services law. The CBI’s supervisory framework, Probability Risk and Impact SysteM (PRISM), is a risk-based framework that categorises regulated firms by the potential impact of their failure on the economy and the consumer. PRISM was introduced in 2011. In January 2025, the CBI implemented a new supervisory approach to reflect changes in its regulatory responsibilities and the sectors it supervises. Under this updated framework, prudential impact ratings are no longer the primary driver of supervision intensity but remain a relevant input for supervision and for certain CBI Regulations, Requirements and Guidance in specific sectors.

Consumer protection risk assessments

The CBI’s Consumer Protection Risk Assessment (CPRA) model aims to enhance the way regulated entities manage “the risks they pose to consumers and ensure they have appropriate risk management frameworks to deliver for their customers”. (Re)insurance companies must implement a consumer protection risk management framework that is tailored to the nature, scale and complexity of their business. The CBI assesses the effectiveness of these internal management frameworks through targeted CPRAs, in addition to regular thematic inspections.

II Code

The Insurance Institute’s Code of Ethics and Conduct (the “II Code”) is also relevant to the regulation of (re)insurance undertakings. The II Code is a voluntary code of conduct intended to protect policyholders resident in Ireland. It has been adopted by members of Insurance Ireland, the representative body for (re)insurance undertakings in Ireland.

The 2015 Regulations

EU Directive 2009/138/EC (“Solvency II”) introduced a common regulatory framework for European Economic Area (EEA) (re)insurance undertakings and was transposed into Irish law by the European Union (Insurance and Reinsurance) Regulations 2015 (the “2015 Regulations”). The 2015 Regulations impose harmonised capital and solvency requirements, valuation techniques, and governance and reporting standards. They also impose certain restrictions on shareholders of (re)insurance undertakings, as the CBI will not grant an authorisation to an undertaking if it is not satisfied as to the suitability and F&P of “qualifying” shareholders.

For the purposes of the 2015 Regulations, a qualifying shareholding means a direct or indirect holding in an undertaking that:

• represents 10% or more of the capital or voting rights of the undertaking; or
• makes it possible to exercise a significant influence over the management of the undertaking.

Insurance Distribution Regulations

The European Union (Insurance Distribution) Regulations 2018 (IDR) transposed the Insurance Distribution Directive (EU) 2016/97 (IDD) into Irish law. The IDD harmonises the distribution of (re)insurance products within the EU, with the aim of facilitating market integration and enhancing consumer protection. The IDR were designed to:

• enhance consumer protection and ensure a level playing field across the sector by extending the scope of application to include all participants in the distribution of insurance products;
• identify and mitigate conflicts of interest, particularly regarding remuneration; and
• introduce increased transparency and business conduct requirements.

See 2.1 Insurance and Reinsurance Regulatory Bodies and Legislative Guidance.

Insurance undertakings and intermediaries authorised by the CBI or another EU/EEA member state carrying on business in Ireland must comply with certain Irish general good requirements, such as the CPC. The CPC contains general and specific provisions concerning insurance, including requirements relating to premium handling and contact with consumers (eg, information that must be provided to consumers before entering into a contract for a product or service, as well as records, errors, rebates and claims processing).

Persons carrying out a “controlled function” on behalf of financial service providers are expected to satisfy the minimum professional knowledge and competency requirements set out in the Minimum Competency Code and Regulations 2017 (MCC).

The following taxes, levies, and duties are applied to insurance policies.

• Non-life insurance policies attract a quarterly levy of EUR1 stamp duty on insurance policies where the risk is located in Ireland and the premium or premiums payable over a period of 12 months is EUR20 or greater.
• Non-life insurance policies also attract a levy of 3% on the gross amount received by an insurer in respect of certain non-life insurance premiums. An additional 2% contribution to the Insurance Compensation Fund applies to premiums received on non-life insurance policies (this will be reduced to 1% from 1 January 2026).
• Life assurance premiums are subject to a 1% levy on gross premiums.

Health insurance attracts levies that, depending on the cover, range from EUR94 to EUR469 in respect of relevant contracts renewed or entered into on or after 1 April 2025.

Licensing of (Re)insurance Companies

Undertakings wishing to carry on (re)insurance business in Ireland must obtain authorisation from the CBI or another EU regulator through the “single passport” regime. The CBI has published a checklist for completing and submitting applications for authorisation under the 2015 Regulations (the “Checklist”), along with a guidance paper to assist applicants. The application comprises the completed Checklist and a detailed business plan, plus supporting documents (the “Business Plan”), submitted after a preliminary meeting with the CBI.

The principal areas considered by the CBI in evaluating applications include:

• legal structure;
• ownership structure;
• overview of the group to which the applicant belongs (if relevant);
• scheme of operations;
• system of governance, including the F&P of key personnel;
• risk management system;
• own risk and solvency assessment;
• financial information and projections;
• capital requirements and solvency projections; and
• consumer issues (such as the MCC and the CPC).

A high-level overview of the application for the authorisation process is as follows:

• arrange a preliminary meeting with the CBI to outline the proposals, at which the CBI will provide feedback in relation to the proposal and identify any areas of concern that should be addressed before the application is submitted;
• prepare and submit the completed Checklist and Business Plan;
• dialogue with the CBI;
• the CBI’s authorisation committee considers the application;
• once the CBI is satisfied with the application, it will issue an “authorisation in principle” – meaning it is inclined to grant its approval as soon as certain conditions have been satisfied; and
• once all conditions are satisfied, the CBI will issue the final authorisation and the (re)insurer can commence writing business in Ireland.

The application process is iterative, involving consultation with the CBI after a formal submission. During the review process, the CBI will typically request additional information and documentation, and it may have comments on certain features of the proposal. The CBI may request additional meetings with the applicant to discuss the proposal in greater detail.

The CBI will issue a formal authorisation once it is satisfied that the capital requirements and pre-licensing requirements have been met. Throughout this process, there will be multiple meetings and the CBI may request additional information. The process can take between four and six months. The CBI does not currently charge a fee for licence applications.

Third-Country Reinsurers

Third-country reinsurers are excluded from the application of the 2015 Regulations where the reinsurer:

• has its head office in a third country;
• is lawfully carrying out reinsurance in that third country; and
• is carrying out reinsurance (but no other activity) in Ireland.

The effect is that a third-country reinsurer is not required to be authorised in accordance with the 2015 Regulations to carry out reinsurance business in Ireland.

Freedom of Establishment or Freedom of Services Basis

(Re)insurance undertakings authorised in an EU/EEA member state may carry out business in Ireland on a Freedom of Establishment basis through a local branch or operate in Ireland on a Freedom of Services basis, provided that their home state regulators notify the CBI. Passporting undertakings must comply with the Irish “general good” requirements.

Special Purpose Reinsurance Vehicles

A reinsurance provider can establish a special-purpose reinsurance vehicle, thus providing a quicker, simpler route to authorisation and reducing supervision compared with fully regulated reinsurers.

Establishing Third-Country Insurance Branches in Ireland

The 2015 Regulations facilitate a non-EEA insurer establishing a branch in Ireland (“third-country branch”), subject to the fulfilment of specific regulatory requirements. The 2015 Regulations impose standalone capital requirements on third-country branches and require the third-country branches to:

• hold assets in Ireland of at least 50% of the absolute floor prescribed in the 2015 Regulations in respect of the minimum capital requirement (EUR3.7 million); and
• deposit 25% of that amount with the Irish High Court as security.

The local substance requirements for a third-country branch will depend on the nature, scale and complexity of its operations. The CBI will expect an appropriate number of senior management in Ireland to demonstrate a sufficient level of local oversight and control. At a minimum, a branch manager and a branch management committee in Ireland will be required, with day-to-day responsibility for the branch’s corporate governance.

Significantly, a third-country branch does not have the right to passport into other EU/EEA jurisdictions and is only permitted to write business in the jurisdiction in which it is established. Therefore, a third-country branch is not suitable for third-country insurers seeking to write business across the EU/EEA. Post-Brexit, establishing a third-country branch may not represent a comprehensive solution for UK insurers seeking to maintain access to the single market; therefore, establishing an EEA-authorised subsidiary has been the preferred option.

The CBI does not currently permit 100% reinsurance arrangements.

There has been an increase in the overall number of transactions in the Irish M&A market in 2025, with 236 announced transactions in the first half of the year. This offers promise when compared with the global trend of a decrease in deal frequency; however, the value of deals has taken a significant downturn in the Irish market, with deals for the first half of 2025 valued at approximately €8.8bn (approximately a 51% decrease from the first half of 2024).

M&A activity in the Irish insurance market has shown steady growth in 2025. In recent years, consolidation has been a prominent feature of the global insurance-broking industry, and this year, it remains the transaction of choice for many insurance-specific M&A deals. This consolidation trend has been particularly prevalent in fragmented markets where regulatory requirements, technology investments and competitive pressures favour larger, more integrated operations.

Middle-market deals accounted for the majority of deal value again in 2025 (following the same trend as 2024), despite five landmark deals (of value greater than EUR500m) being announced in the first half of 2025. 88% of the deals disclosed are valued between EUR5 million and EUR250 million. Private equity (commenced or backed) made up approximately 24% of all Irish M&A transactions in the first half of 2025 – a slight increase compared to the same period for 2024, with private equity investors featuring in 11 of the 25 M&A transactions involving financial services firms in the first quarter of 2025.

Whilst Irish TMT deal value decreased in the first half of 2025, other sectors accounted for a significant share of M&A value, with financial services-based M&A accounting for the most activity (approximately 37%) of all Irish M&A value for the first half of 2025. One growth area in the Irish financial services sector was the use of roll-up strategies in the broker market, backed by private equity firms. As in previous years, 2025 has seen continued activity with regard to the consolidation of life and non-life run-off books.

2025 has been a mixed picture in general for the Irish M&A market. With an increase in deal volume and a decrease in deal value reported as of the end of the first half of 2025, as well as a number of large value deals closing in Q3 and Q4 2025, the Irish M&A outlook remains positive and highly resilient, with activity levels anticipated to remain healthy into 2026.

Insurance Distribution Regulations

The IDR govern the distribution or sale of insurance products and applies to persons engaged in insurance distribution business in the Irish market, such as agents, brokers and bancassurance operators. However, insurers can also distribute insurance products directly to customers.

Definition of insurance distribution

Under the IDR, insurance distribution is defined as “any activity involved in advising on, proposing, or carrying out other work preparatory to the conclusion of contracts of insurance, of concluding such contracts, or of assisting in the administration and performance of such contracts ‒ in particular, in the event of a claim, the provision of information concerning one or more insurance contracts in accordance with criteria selected by customers through a website or other media and the compilation of an insurance product ranking list, including price and product comparison, or a discount on the price of an insurance contract, when the customer is able to directly or indirectly conclude an insurance contract using a website or other media”.

The following activities are specifically excluded:

• claim management on a professional basis;
• loss adjusting;
• expert claim appraisal; and
• mere provision of information if no additional steps are taken by the provider to assist in concluding an insurance or reinsurance contract.

The IDR clarifies that “introducing” is not considered a regulated activity under Irish law.

Impact of the IDR

The IDR introduces enhanced information and conduct-of-business requirements for insurance distributors. “Ancillary insurance intermediaries” are exempt from the IDR under certain conditions.

The IDR prescribes certain requirements relating to product oversight and governance (POG), which aim to:

• enhance consumer protection by ensuring insurance products meet the target market’s needs; and
• mitigate the risk of mis-selling by insurance distributors.

Insurance undertakings (and relevant intermediaries) are required to implement POG procedures prior to distributing or marketing an insurance product to customers.

The IDR requires distributors to have product distribution arrangements (PDA) in place that include appropriate procedures for obtaining all pertinent information on the products they intend to offer their customers from the manufacturer. The PDA should be a written document made available to their staff, aiming to:

• prevent customer detriment;
• manage conflicts of interest; and
• ensure the objectives, interests and characteristics of customers are considered.

Investment Intermediaries Act 1995

Previously, two pieces of legislation governed intermediaries operating in Ireland. The European Union (Insurance Mediation) Regulations 2005, which have been fully repealed, and the Investment Intermediaries Act 1995 (IIA). The IDR brought welcome clarification regarding the application of the IIA to insurance intermediaries by revoking all references to insurance.

Authorisation

(Re)insurance brokers/intermediaries require CBI authorisation to:

• carry out (re)insurance distribution or advise consumers in relation to general insurance products, life assurance, health and medical insurance products; or
• act as an insurance intermediary for an insurance company with which they have an agreement or carry out certain activities (such as loss assessing or assisting consumers in dealing with claims under insurance contracts).

(Re)insurance brokers/intermediaries are subject to ongoing CBI supervision of their compliance with the registration requirements, including completing an annual return and holding an adequate professional indemnity insurance policy. The CBI maintains a register of authorised (re)insurance intermediaries in Ireland. (Re)insurance undertakings involved in the distribution of insurance products must also comply with the national “general good” provisions that regulate how undertakings may sell and market insurance products to consumers in Ireland.

Position of UK-Based Insurance Intermediaries After 31 December 2020

See 3.1 Overseas-Based Insurers or Reinsurers.

Parties to a non-consumer insurance contract are subject to the duty of utmost good faith (Section 17 of the MIA). The proposer or insured has a duty to disclose all material facts. A material fact is one that would influence the judgment of a prudent underwriter in deciding whether to underwrite the contracts and, if so, on what terms. The duty extends beyond correctly answering questions on a proposal form; every material representation made by the insured, proposer, or their agent to the insurer must be true.

CICA replaces the duty of good faith in consumer insurance contracts and the MIA no longer applies to them. Since 1 September 2021, the consumer proposer’s duty is limited to a duty to provide responses to specific questions asked by the insurer honestly and with reasonable care.

The majority of provisions of CICA took effect from 1 September 2020. The remaining sections commenced on 1 September 2021 – except for Section 18(4), which was clarified and amended by the Insurance (Miscellaneous Provisions) Act 2022.

Prior to CICA, the remedy for breach of the duty of utmost good faith was avoidance of the policy. CICA introduced new proportionate remedies (proportional to the effects of the misrepresentation, depending on whether it was innocent, negligent or fraudulent) for a breach of the new duty of disclosure. Section 8(6) requires an insurer to establish an inducement to avail of the remedies under CICA for a breach of the duty of disclosure.

Typically, an insurance intermediary is deemed to be acting on behalf of the customer at all times during the negotiation of an insurance contract ‒ except when collecting premiums on behalf of the insurer. However, certain intermediaries act for and on behalf of an insurer as a tied insurance intermediary.

Under the IDR, insurance distributors are required to act honestly, fairly and professionally in accordance with the best interests of their customers, irrespective of whether the intermediary is negotiating an insurance contract as an individual broker or acting as a tied insurance intermediary. The information and transparency requirements set out in the IDR require an intermediary to promptly disclose whether it is representing the customer or acting for and on behalf of the insurer before the contract concludes. Any remuneration received by an intermediary in relation to a contract must be disclosed to the customer. Ongoing requirements include:

• good reputation of directors;
• knowledge and ability of senior management and key personnel;
• holding of minimum levels of professional indemnity insurance; and
• maintenance and operation of client premium accounts.

There are no specific rules for the formation of an insurance contract under Irish law, beyond the general principles of contract law, common law and the duty of good faith. There is no statutory definition of an insurance contract and legislation does not specify its essential legal elements. International Commercial Bank plc v Insurance Corporation of Ireland set out the main characteristics of an insurance contract, which are:

• an insurable interest;
• payment of a premium;
• the insurer undertakes to pay the insured on the happening of an insured risk;
• the risk must be clearly specified;
• indemnification; and
• the principle of subrogation is applied where appropriate.

CICA defines an insurance contract as “a contract of life insurance or non-life insurance made between an insurer and a consumer” and reforms the law relating to insurable interests.

It is possible to have multiple insured persons and beneficiaries under a policy. Policies can be structured as single or joint policies, as well as group policies.

Consumer contracts are now governed by CICA. The legal requirements of insurance and reinsurance are the same.

ART transactions are recognised as reinsurance transactions under the 2015 Regulations and are characterised by the CBI in a manner consistent with the Solvency II regime.

There has been a slowdown in recent years in the number of ART deals in Ireland. The CBI has concerns relating to the viability of ART transactions and the potential risks for insurance carriers, particularly regarding basis risk. Further, it is not clear if ART transactions entered by life insurers comply with the requirements to be “fully funded”. Significant growth is not expected in the coming years.

No information is available for this jurisdiction.

Insurance contracts are subject to the same general principles of interpretation as other contracts. The Supreme Court has confirmed in two judgments (Analog Devices v Zurich Insurance and Emo Oil v Sun Alliance and London Insurance Company) that the principles of construction set out by Lord Hoffman in ICS v West Bromwich Building Society should be applied to the interpretation of insurance contracts. Further, the 2021 case of Brushfield Ltd v Arachas Corporate Brokers Ltd and AXA Insurance DAC helpfully summarised the principles applicable to the interpretation of insurance policies in Ireland.

The Irish courts consider the ascertainment of the meaning the document would convey to a reasonable person, having all the background knowledge that would reasonably have been available to the parties in the situation in which they were at the time of the contract (“matrix of fact”). Certain things are excluded from the admissible background, including previous negotiations and declarations of subjective intent. The meaning of the document is not the same as the particular meaning of the words; it is what the parties using those words against the relevant background would reasonably have understood them to mean.

The courts apply the words’ ordinary and natural meaning. It is assumed that people ordinarily do not make linguistic mistakes in formal documents. However, if it is clear from the matrix of facts and the background that something is wrong with the language, judges can attribute to the parties the intention they clearly had.

The court takes an objective approach to determining the intention of reasonable persons in the position of the parties. Where a contractual term is genuinely ambiguous, the contra proferentem rule will apply and the interpretation less favourable to the drafter is adopted. The rule also applies to consumer contracts.

In non-consumer contracts, no specific wording is required to create a warranty. The word “warranty” is not required, but may be considered as evidence of the intention to create a warranty. Further, a warranty may be express or implied (Section 33 of the MIA).

A warranty is treated differently from a contractual term in that it must be strictly complied with, regardless of whether it is material to the risk. The insurer is discharged from liability from the date of breach of the warranty, although without any prejudice to any liability incurred before that date.

The Irish courts construe warranties strictly, as a breach entitles the insurer to repudiate liability even if the breach is not material to the loss. CICA replaces warranties in consumer contracts with suspensive conditions and abolishes the basis-of-contract clauses.

The effect of a breach of a condition depends on whether the condition is a condition precedent to liability. Conditions precedent to liability relate to matters arising after a loss has occurred – most commonly in relation to notification. The Irish courts will generally not construe an insurance condition as a condition precedent unless it is expressed as such or the policy contains a general condition precedent provision. Breach of a condition precedent means that an insurer can repudiate liability for the claim without any requirement to demonstrate prejudice. There is no requirement for a link between the breach and the damage.

The consequences for breach of a bare condition are damages.

In consumer contracts, conditions precedent could now be considered “continuing restrictive conditions” following the commencement of CICA.

Insurance contracts typically contain a dispute-resolution clause. An insurance contract may contain an arbitration clause or may stipulate another form of ADR. In a consumer contract, a consumer may make a complaint to the Financial Services and Pensions Ombudsman (FSPO) (see 9.7 Alternative Dispute Resolution (Financial Services and Pensions Ombudsman)).

Choice-of-forum, venue, and applicable law clauses in (re)insurance contracts are generally recognised and enforced. If the insured is domiciled in an EU member state, the following regulations may limit these provisions:

• Regulation (EC) 44/2001 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (the “Brussels I Regulation”);
• Regulation (EU) 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (the “Recast Brussels Regulation”), which replaces the Brussels I Regulation in respect of proceedings and judgments commenced after 10 January 2015;
• Regulation (EC) 593/2008 on the law applicable to contractual obligations (the “Rome I Regulation”);
• Lugano Convention (L339, 21 December 2007) on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters; and
• the Hague Choice of Court Agreements Convention 2005.

In Ireland, the District Court deals with claims up to a monetary value of EUR15,000, the Circuit Court deals with claims up to EUR75,000 (EUR60,000 for personal injury cases), and the High Court has unlimited monetary jurisdiction. Insurance disputes are heard by a single judge with no jury.

The Commercial Court is a specialist division of the High Court dealing exclusively with commercial disputes. Where the monetary value of a (counter)claim exceeds EUR1 million and the dispute is commercial in nature, either party may apply to have the dispute heard in the Commercial Court. There is no automatic right of entry; it is at the judge’s discretion and can be refused if there has been any delay.

Commercial Court proceedings progress much more quickly. Generally, the time from entry into the Commercial Court to the allocation of a trial date ranges from a matter of weeks to between four and six months, depending on the complexity and number of parties.

Appeals from the High Court are dealt with by the Court of Appeal, except when the Supreme Court believes a case is of such public importance that it should go directly to the State’s highest court.

Evidence

Evidence is given orally, except in very limited circumstances. Where a party intends to rely upon the (factual or expert) oral evidence of a witness, a witness statement or expert report must be filed – unless a judge orders otherwise.

Costs

Typically, costs follow the event, whereby the loser pays. However, where litigation is complex, the Commercial Court often analyses whether the winning party has succeeded on all grounds.

Limitation

The general position under the Statute of Limitations Act 1957 is that claims for breach of contract must be brought within six years of the date of breach. Where a complaint is made to the FSPO, there is an extended limitation period applicable to complaints relating to “long-term financial services” (ie, those for which the maturity or term extends beyond five years and one month, or life assurance policies not subject to annual renewal) – otherwise a six-year rule applies.

Following Brexit, on 1 July 2025, the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters 2019 entered into force in the United Kingdom, facilitating the mutual recognition and enforcement of judgments obtained in the UK in Ireland in proceedings commenced after that date.

For non-EU, non-Lugano Convention and non-Hague Convention judgments, an originating High Court summons is required to recognise and enforce a foreign judgment, and the High Court must grant leave to issue and serve the proceedings. To succeed, a foreign judgment must be for a definite sum, be final and conclusive, and be handed down from a court of competent jurisdiction. The High Court may refuse to recognise and enforce a judgment on several grounds (eg, fraud, lack of jurisdiction) that are contrary to Irish law or the principles of natural justice.

See 9.7 Alternative Dispute Resolution.

See 9.7 Alternative Dispute Resolution.

Insurance disputes may also be resolved through ADR mechanisms such as mediation and arbitration.

Arbitration

Where an insurance contract contains an arbitration clause, a dispute must be referred for arbitration. However, consumers are not bound by an arbitration clause where the claim is less than EUR5,000 and the relevant policy has not been individually negotiated.

The Arbitration Act 2010 (the “2010 Act”) incorporates the UNCITRAL Model Law on International Commercial Arbitration. Under the 2010 Act, the decision of an arbitrator is binding on the parties and there is no means of appeal. Where parties have entered into valid arbitration agreements, the courts are obliged to stay proceedings.

The 2021 High Court decision in Charwin Limited t/a Charlie’s Bar v Zavarovalnica Sava Insurance Company DD demonstrates that the bar is high when seeking to resist a referral to arbitration on grounds of public policy.

Although arbitration may result in additional costs, there is the benefit of confidentiality.

Ireland is party to the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (the “New York Convention”), allowing Irish arbitral awards to be enforced in any of the 157 countries party to the New York Convention.

The courts can set aside an arbitral award under Article 34 of the 2010 Act, albeit on very limited grounds. The party seeking to have the arbitral award set aside must prove that either:

• a party to the arbitration agreement was under some incapacity or the agreement itself was invalid;
• the party making the application was not given proper notice of the arbitrator’s appointment or the arbitral proceedings (or was otherwise unable to present their case);
• the award deals with a dispute outside the ambit of the arbitration agreement;
• the arbitral tribunal was not properly constituted;
• the subject-matter of the dispute is not capable of settlement by arbitration under the law of the State; or
• the award conflicts with the public policy of the State.

In the recent case of Flatley v Austin Newport Group Limited and Others, the High Court rejected the assertion that an arbitration clause in a consumer contract amounted to an “unfair term”, contrary to the provisions of the Consumer Rights Act 2022 (the “2022 Act”). The 2022 Act provides that a term in a consumer contract relating to arbitration is unfair if it requires the consumer to pay their own costs. The High Court considered that the arbitration clause would be an unfair term if it required the consumer to pay their own costs; however, the arbitration clause in that case contained no such requirement.

Mediation

Under the Mediation Act 2017 (the “Mediation Act”), solicitors in Ireland must advise their clients of the merits of mediation as an ADR mechanism before proceedings are issued. The Mediation Act provides that any court may adjourn legal proceedings to allow the parties to engage in mediation.

The court can make such an order on its own initiative or on application by either party to the proceedings. There may be cost implications if either party fails to engage in ADR following a court direction.

Financial Services and Pensions Ombudsman

The FSPO is the amalgamation of the Financial Services Ombudsman and the Pensions Ombudsman, pursuant to the FSPO Act 2017. It is an independent body established to resolve disputes between consumers and insurance providers, either through informal means or through formal investigation. The FSPO’s decision is legally binding, with a statutory right of appeal to the High Court.

It is currently not settled in Irish law whether damages are available for the late payment of claims. However, under Section 26 of CICA, where an insurer is in breach of any duty under the Act, the court has the discretion to order that a sum payable in a claim under a contract of insurance be increased in proportion to the breach involved.

Insurers have subrogation rights at common law and subrogation provisions in insurance policies are common. Generally, an indemnity must have been provided before the insurer is entitled to subrogate. CICA has introduced certain restrictions on subrogation rights in family and personal relationships and in employment contexts.

Irish government bodies, such as Enterprise Ireland and the Industrial Development Authority Ireland, work in tandem to attract and support foreign direct investment in Ireland and promote Ireland as a destination for insurtech companies.

In July 2021, 12 stakeholders in the Irish insurance sector joined together to create InsTech.ie, with the aim of promoting Ireland as an EU insurtech hub. Under the Department of Finance’s Finance Action Plan IFS 2025, InsTech.ie is tasked with building an insurtech hub in Ireland. Since 2022, the Irish insurtech cluster has more than doubled to more than 130 tech start-ups and scale-ups offering solutions to the insurance sector in Ireland and abroad. A study commissioned by InsTech.ie and conducted by Deloitte, Driving Insurtech Growth in Ireland, was published in April 2021. It found that Ireland is “one of the most developed insurance markets” in Europe and is “well positioned to take advantage of the innovation and technological enhancements being developed within the sector as part of the growth of global insurtech”. An updated report, published in October 2024, found 86% of insurtechs were optimistic about the future of insurtech in Ireland in the next 12 months.

One significant Irish insurtech firm is Blink, founded in 2016 to develop data-driven travel disruption insurance solutions. In 2020, the firm launched Blink Parametric, offering a full suite of parametric insurance solutions. Blink made it onto The Insurtech100 in 2019, 2020 and 2022, and featured in a spotlight position in InsTech.ie’s 2024 Irish Insurtech Report. In July 2023, Blink announced its intention to create 30 new jobs in Cork, effectively doubling its workforce by the end of 2025. In October 2024, Blink won the Best Parametric Insurance Product at the Global Insurtech Awards 2024.

In 2021, 2022, 2023 and 2024, Companjon – an innovative insurtech start-up headquartered in Dublin – was named in the InsurTech100. Companjon is Europe’s leading specialist in 100% digital, unique add-on insurance. Companjon has been recognised by Forbes as “a tech-driven disruptor that is changing the way people think about insurance”.

In September 2025, the Department of Finance announced a strategic partnership with Lloyd’s under which Ireland will host a dedicated cohort of the Lloyd’s Lab Accelerator Programme (“Programme”) in the first half of2026 with the aim of helping innovative ideas gain traction and achieve success in the insurance market, providing an opportunity to develop new technology solutions while being guided by experienced insurance professionals. The Department of Finance has described this development as a landmark opportunity to showcase Ireland’s position as a hub for insurance and financial services.

The Programme also supports the objectives of the Ireland for Finance Strategy as regards enhancing Ireland’s competitiveness and innovation.

The CBI is responsive to the challenges posed by the regulatory treatment of financial innovations. It is a robust regulator, acknowledging the need to strike the appropriate balance between encouraging innovation-related market entry and ensuring new entrants are sufficiently prepared to fulfil all their regulatory obligations in relation to financial stability and consumer protection. The CBI is cognisant of the need to keep abreast of the changing technological environment and has committed significant resources to improving its data architectures and establishing quantitative analytical teams across its banking, insurance and markets directorates.

The CBI has taken a range of measures in relation to fintech, including:

• establishing the Innovation Hub for engagement with fintech companies;
• creating an innovation steering group and a fintech network within the CBI; and
• engaging with the European Supervisory Authorities and the Single Supervisory Mechanism on the EC’s Fintech Action Plan.

In June 2024, the CBI announced its intention to establish the Sandbox, with a call for applicants announced in October 2024. The inaugural Sandbox’s theme was “Combatting Financial Crime,” with the aim of deploying innovative technology to develop solutions that minimise fraud, enhance KYC/AML/CFT frameworks, and improve transaction security for consumers. The CBI held a showcase event in June 2025, highlighting the work carried out over the course of the Sandbox.

In September 2025, the CBI announced a call for applications for its second Sandbox, with the theme “Innovation in Payments”.

“Emerging risks” are new, evolving risks that are difficult for insurers to assess and that carry a high degree of uncertainty regarding their impact, probability, and expected losses. The CBI expects Irish insurance undertakings to consider assessing emerging risks and to adopt a longer-term perspective than is typical in business planning and strategy-setting processes. The CBI expects to see evidence of robust analysis and timely, effective action relating to emerging risks.

With cyber-risk and digitalisation risks being the most formidable emerging risks in Ireland, it is worth noting that, in terms of climate risk, the CBI’s view is that change risk has now moved from an emerging risk to a key risk, given the impact that climate change is already having on the insurance sector. The CBI expects (re)insurers to manage climate risks in the same manner that they manage other key risks within their risk management framework.

Cyber-Risk

Digital innovation and growing sophistication in digital technology have led to increased cybersecurity threats and data breach risks. The CBI published cross-industry guidance on IT and cybersecurity risks in 2016, highlighting a range of emerging threats. This guidance noted that IT and cybersecurity, and associated risks, are a key concern for the CBI. In October 2020, the European Insurance and Occupational Pensions Authority (EIOPA) published its Guidelines on ICT Security and Governance. The CBI confirmed that these guidelines supersede its 2016 guidance but do not contradict anything in it.

In December 2021, the CBI published its final Cross-Industry Guidance on Operational Resilience to assist financial firms in preparing, responding, recovering, and learning from an operational disruption affecting the delivery of critical or important business services. Anticipating the Digital Operational Resilience Act (DORA), the CBI noted that these guidelines were compatible with and complementary to DORA, with no contradictions between the two. However, more recently, the CBI acknowledged that certain national guidance will need to be updated in order to align with DORA, including guidance on “operational resilience” and “outsourcing”.

In July 2025, the CBI published its updated Cross Industry Guidance on Operational Resilience (“Guidance”). The Guidance has been applicable since 14 July 2025 and replaces the previous version that applied from 1 December 2021 to 13 July 2025. Specifically, as regards DORA, the “Concept of Operational Resilience” has been updated to refer to the fact that the Guidance is supplementary to DORA, in force since 17 January 2025, highlighting that the Guidance will be useful to all firms, whether in scope of DORA or not, as regards strengthening operational resilience.

As regards guidance on outsourcing, the CBI has stated, in its December 2025 publication “Regulating & Supervising well – a more effective and efficient framework”, that it will update its outsourcing guidance in H2 2026.

Warranty and Indemnity Insurance

Warranty and indemnity insurance is being used more frequently in commercial transactions, as are other bespoke transactional products such as litigation buyout policies.

Addressing Emerging Risks

Cyber-insurance is a product on the Irish market that has grown in popularity, with several insurers offering new cyberproducts in Ireland. However, Domhnall Cullinan, the former director of insurance supervision at the CBI, previously voiced concern about the Irish market’s positioning to take advantage of this growth area, stating: “The Irish insurance industry does not find itself as a large provider of capacity in the international market… without appropriate pricing and adequate reserving and the right expertise to underwrite the risk.”

EIOPA noted that almost 70% of SMEs are not covered for cyber-attack risks. In September 2023, EIOPA launched a survey on access to cyber-insurance by SMEs to better understand the difficulties small businesses face in protecting themselves from cyber-risks and to assess the level of access to cyber-insurance. The survey found that cyber-risks remain at a medium level, with an increasing risk outlook over the next 12 months. It also showed that cyber underwriting has been limited in the EEA insurance sector, primarily due to challenges with pricing and uncertainty about the nature of the risks.

In its February 2025 Regulatory and Supervisory Outlook Report, the CBI addressed cyber insurance in the context of insurance companies’ business models and strategies. The CBI noted that concentrations of cyber insurance require careful management within a firm’s overall risk appetite, particularly where relevant experience and expertise are scarce. The CBI stated that enhancing cyber-related resilience is one of its key priorities across the financial sector, with a key element being the effective implementation of DORA obligations by regulated firms, including critical third-party information and communications technology (ICT) providers.

The latest Insurance Risk Dashboard published by EIOPA in October 2025 showed that cyber and digitalisation risks are gaining prominence, with an increased perceived likelihood of incidents and growing concerns around the vulnerabilities of IT systems.

Financial Services and Pensions Ombudsman (Amendment) Act 2025

On 15 April 2025, the Financial Services and Pensions Ombudsman (Amendment) Act 2025 (2025 Act) was signed into law by the President

The key aim of the 2025 Act is to strengthen protections for financial consumers by amending the legislation underpinning the Financial Services and Pensions Ombudsman (FSPO).

One of the main impacts of the 2025 Act is the clarification that the FSPO may investigate complaints concerning financial service providers and pension providers that are no longer regulated by the CBI, provided they were regulated at the time of the conduct in question.

Additionally, the 2025 Act provides enhanced legal clarity for the statutory operation of the FSPO.

The 2025 Act takes account of the ruling Zalewski v Adjudication Officer & Ors [2021] IESC 24, and updates elements where the FSPO could be viewed as administering justice.

The 2025 Act also sets out a limited number of further amendments to the Financial Services and Pensions Ombudsman Act 2017.

The 2025 Act is now fully in force.

Heightened Regulatory Scrutiny

Publication of revised CPC documents

Following its March 2024 Consultation Paper on the CPC (the “Consultation Paper”), in March 2025, the CBI published the Feedback Statement to the Consultation Paper together with the finalised regulations and guidance documents. The Central Bank has updated its dedicated CPC webpage.

The updated CPC will comprise two regulations: the Standards for Business Regulations and the Consumer Protection Regulations. These regulations were signed into law on 24 March 2025 and will take effect on 24 March 2026, following a 12-month implementation period.

Three guidance documents were also published, as follows:

• General Code Guidance, which provides guidance to firms to support the implementation of the broader requirements of the revised CPC. This guidance incorporates and updates the existing CPC guidance and includes new guidance on the changes under the revised CPC, which was informed by feedback received during the consultation process. It should be noted that the General Code Guidance was not published last year with CP158;
• Guidance on Protecting Consumers in Vulnerable Circumstances; and
• Guidance on Securing Customers’ Interests.

Regulation and supervision priorities for 2025

On 28 February 2025, the CBI published its Regulatory and Supervisory Outlook Report (“Report”). The Report sets out the CBI’s assessment of the key trends and risks that are shaping the financial sector. On the basis of such assessment, the Report also details the CBI’s regulatory and supervisory priorities for the next two years.

Looking specifically at the supervisory priorities, they remain as set out in the 2024 report. The Report details six cross-sectoral supervisory priorities and what it expects firms to do in response. The priorities focus on:

• managing risk;
• being consumer-centric;
• resiliency;
• managing change;
• addressing climate change risk; and
• responding to operating framework deficiencies.

As regards insurance specifically, the following priorities were highlighted:

• supporting EIOPA’s 2025 EU-wide strategic supervisory priorities, with the Central Bank stating that it will be completing work in relation to risk transfers and value for money, and reviews of pricing discipline, adequacy of reserves and capital;
• sectoral supervision focusing on the monitoring of the potential impacts of changes in financial markets and the macroeconomic environment on the insurance sector and its consumers.
• assessing firms’ reliance on parent groups for services and capital support;
• assessing the embedding of DORA requirements and adherence to the Central Bank’s Cross Industry Guidance on Operational Resilience;
• reviewing the use of AI in pricing and underwriting processes; and
• as regards the Solvency II review, industry participants will be asked to engage in an assessment of the expected impacts in terms of quantitative elements as well as qualitative elements.

Individual accountability

The IAF Act was enacted on 9 March 2023 and aims to support the advancement of an improved culture in the Irish financial system through greater accountability in the regulated sector. On 16 April 2024, the CBI published its final related Guidance on the IAF as well as a statutory instrument in relation to its Senior Executive Accountability Regime (the “SEAR Regulations”).

2024 was the year of embedding the IAF. Firms that fell within the scope of the SEAR Regulations had to be compliant by 1 July 2024.

2025 saw the application of the confirmation of compliance with the certification process in respect of pre-approval controlled functions (PCFs) and controlled functions as of 1 January 2025, and independent non-executive directors and non-executive directors came into scope from 1 July 2025.

In its November 2025 Investment Firm and Intermediary Newsletter (Newsletter), the CBI provided an update on the implementation of the IAF, highlighting that industry feedback in relation to the implementation of the framework has been consistently positive, with industry representatives acknowledging the benefits of the regime. Further, the CBI stated that it has seen positive internal changes in firms on the basis of the IAF framework.

It was also highlighted that extending the senior executive accountability regime to non-executive directors, including to independent non-executive directors (“(I)NEDs”), requires firms to allocate applicable prescribed responsibilities to (I)NEDs, and to ensure that each (I)NED has a documented statement of responsibilities.

The CBI also stated that it is of the view that the expectations of (I)NEDs under the new framework are fully consistent with their existing responsibilities under the corporate governance framework and that the standards to be met relate purely to non-executive oversight functions and are limited to what should reasonably be expected of individuals in that context.

CBI publishes F&P standards and Guidance on the Standards of F&P

In April 2025, the CBI launched a consultation (CP 160) on revisions to its Fitness and Probity (F&P) Regime.CP 160 stemmed from the recommendations made in the Enria report, following Mr Andrea Enria’s independent review of the CBI’s F&P assessment process, the results of which were published in July 2024.

On 25 November 2025, the CBI published its updated F&P Standards (Standards) and accompanying Guidance on the Standards of F&P (Guidance). The Standards and Guidance were finalised following the completion of CP160.

While the Standards have now been consolidated and incorporate the provisions in respect of Credit Unions that were previously published in a separate document, the substance of the Standards themselves has not otherwise changed.

The consolidation of the Guidance is in line with the recommendations included in the Enria Report. Specifically, the CBI has now consolidated all guidance relating to the F&P Regime into a single document, including cross-references to other relevant guidance and guidelines that address the F&P Regime, thereby providing assistance to firms in complying with their obligations.

On foot of the feedback received, the CBI has amended the Guidance to provide additional detail, to reflect the application of the principle of proportionality, and to confirm the appropriateness of case-by-case assessments. The changes include:

• the nature and complexity of the firm should be taken into account when determining the appropriate level of due diligence required;
• the introduction of new guidance to facilitate the appointment of a Temporary Officer when a PCF role becomes vacant;
• the designation of a company secretary as CF-1 should be determined on a case-by-case basis, where the functions carried out by the individual enable them to exercise a significant influence on the conduct of the affairs of the firm; and
• in relation to the ten-year look-back period, notwithstanding that ten years is given as a guide to relevance, firms should seek information in relation to all criminal, civil or regulatory actions in respect of an individual, regardless of when they may have occurred.

The Guidance became applicable on 20 November 2025. The CBI has also streamlined the content on the F&P section of its website.

CBI updates General Good Requirements for Insurance and Reinsurance Undertakings

On 8 May 2025, the CBI updated its General Good Requirements for Insurance and Reinsurance Undertakings (Requirements). This version of the Requirements supersedes the previous version that applied from 2 September 2019 to 7 May 2025.

The following is a summary of the changes.

• There is a new section entitled “Central Bank of Ireland Codes”, and under this section, the requirements in relation to the following are set out:
1. the Consumer Protection Code; and
2. the Minimum Competency Code 2017.
• There is an entirely new section entitled “Reporting Requirements”, and under this section, the reporting requirements applicable to insurance and reinsurance undertakings are set out. Requirements relating to the non-life premium levy and the funding levy have been grouped under a new heading entitled “Applicable Levies”. The content is unchanged; and
• Requirements regarding motor insurance and health insurance have been grouped under a new heading entitled “Other Requirements”, and, other than the postal address for the Health Insurance Authority having changed, the content remains the same.

CBI takes enforcement action under Administrative Sanctions Procedure (ASP)

On 2 July 2025, the CBI issued a statement setting out the details of the third enforcement action taken by the CBI under the new ASP following the changes introduced by the IAF. The entity subject to this third enforcement action admitted to the prescribed contraventions set out in the Settlement Notice, specifically, failure to conduct customer due diligence/failure to carry out transaction monitoring/failure to carry out additional monitoring/failure to conduct a business risk assessment/failure to conduct a customer or transaction risk assessment/failure to adopt policies and procedures/failure to manage the identified risks with the cash lodgements service. The entity accepted the CBI’s sanction of a reprimand and monetary penalty of EUR51,819, reduced to EUR36,273 after application of a 30% settlement scheme discount.

The fourth enforcement action was published on 6 November 2025, in which the CBI issued a settlement notice in respect of a company’s breaches of anti-money laundering and counter terrorist financing between 2021 and 2025 under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (“CJA 2010”). The entity accepted the CBI’s sanction of a reprimand and a monetary penalty of EUR30,663,906, reduced to EUR21,464,734 after application of a 30% settlement scheme discount.

Both enforcement actions are subject to confirmation by the High Court and will only take effect once confirmed.

CBI publishes thematic review for (re)insurance undertakings on climate change risk and a flood protection gap report

In March 2023, the CBI published its final Guidance for (Re)Insurance Undertakings on Climate Change Risk. It aims to clarify the CBI’s expectations for how (re)insurers address climate change risks in their businesses and to assist them in developing their governance and risk management frameworks to do so. In its September 2024 Insurance Newsletter, the CBI published the findings of its thematic review of the materiality assessments of 29 (re)insurers. This review illustrated that the majority of firms have made some efforts to meet the guidance, including conducting a broad analysis of potential climate risk exposure across various categories and outlining clear conclusions on the materiality of these risks.

In October 2024, the CBI published its Flood Protection Gap Report following engagement with key stakeholders, including members of the insurance industry and officials from the Department of Finance and the Office of Public Works. The key findings of the report were that Ireland is likely to see significantly more rainfall in the future due to climate change, increasing the likelihood of flood events and potentially widening the flood protection gap further. The CBI has stated that the flood protection gap remains a priority.

CBI publishes “Our Approach to Supervision”

In March 2025, the CBI published a document entitled “Our Approach to Supervision”. The Document provides an overview of the Central Bank’s supervisory framework, including details on its supervisory principles and practices, and follows on from the CBI’s initiative regarding the transformation of regulation and supervision, as announced in August 2024.

As of January 2025, the CBI has moved to an integrated supervisory model, stating that this approach sets the CBI up for the future, ensuring that the financial system operates in the best interests of consumers and the wider economy.

The CBI emphasises the importance of supervision, comprising engagement, analysis and oversight of financial services firms, together with the implementation, monitoring and enforcement of regulations, reiterating its risk-based, outcomes-focused approach to supervision. Importantly, the CBI highlights firms’ responsibilities regarding risk identification, management, and mitigation, stating that these responsibilities rest, first and foremost, with boards and management teams within regulated firms.

Sectoral level supervision

The Document goes on to address supervision at a sectoral level, stating that each sector (Banking & Payments / Insurance / Capital Markets & Funds) is supervised in an integrated, holistic way with a multi-year supervisory strategy. Supervision is delivered via a broad range of supervisory actions and interventions, used to prevent or mitigate risks. The Document also sets out examples of programmatic supervision, some of which are as follows:

• direct engagement with sectors, firms and individuals;
• thematic reviews, onsite inspections, deep dives/investigations, risk analysis and assessment;
• ensuring firms take appropriate risk mitigation actions to address issues identified; and
• firm-specific risk assessments, for example, business model and strategy risk.

Central Bank publishes its 2024 climate observatory

On 14 January 2025, the CBI published its Climate Observatory 2024 (“Observatory”).

The Observatory provides an update on climate-related financial and non–financial metrics. The aim of the Observatory is to act as an annual monitor of progress in relation to national decarbonisation and changes in financial sector climate risks.

Initially launched in 2023, the 2024 Observatory has been updated as follows:

• a new section, part A, addresses global trends in the progression of climate change, mitigation and impact;
• part B provides insights into climate risk for banks, insurers and funds using climate–aligned financial sector data.

The Observatory also provides an overview of developments regarding:

• national policy and sustainable finance;
• trends in ESG terminology; and
• the flood protection gap in Ireland.

CBI publishes insights on asset-intensive reinsurance (AIR)

In March 2025, the CBI stated its intention to issue a data request to a sample of less than 20 life (re)insurance 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 counterparty, it was found that some firms would breach the 100% solvency capital requirement (SCR).

The CBI reminded firms to engage with their supervisor 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 renewing 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 complete 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 priority expectations which firms are required to assess against are as follows:

• that firms will always offer a full suitability assessment 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 guarantee 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 thematic 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 reliance on intra-group outsourcing across the speciality firms through the use of a shared services structure 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 arrangements – the CBI notes that it has observed that firms are increasingly entering into arrangements with the use of separate legal entities for the provision of extensive staffing to the undertaking (usually part of the same group as the undertaking) and highlighted that the CBI is focused on such arrangements, due to their potential to undermine the operational resilience of regulated entities, if not effectively managed.

Under this heading, the CBI emphasised the importance of compliance with its 2022 Guidance on the Use of Service Companies for Staffing Purposes in the Insurance Sector and its 2021 Cross Industry Guidance on Outsourcing for firms with hybrid staffing arrangements.

The CBI highlighted that, although the Assessment related to speciality insurance firms, the risks, expectations and findings set out by the CBI are relevant to all (re)insurance firms with significant intra-group outsourcing arrangements in place.

The CBI issued a “Dear CEO Letter” to all speciality firms, setting out the main messages of the Assessment and stating that, where relevant, individual risk mitigation programmes and recommendations were issued to firms.

CBI reduces Insurance Compensation Fund levy

On 3 October 2025, the CBI announced that the Insurance Compensation Fund levy (Levy) would be reduced from 2% to 1% as of 1 January 2026.

This is the first change to the Levy in 14 years, and the CBI noted that the reduction will positively affect many customers with non-life insurance policies, such as home and motor insurance (where the motor insurance provider is regulated by the CBI).

The CBI has stated that it is the responsibility of insurance firms to pay the correct levy and stressed the importance of being ready to implement the Levy change from 1 January 2026.

The CBI expects firms to act in consumers’ best interests. As regards firms which explicitly pass the levy on to policyholders as a separate charge listed within their documentation, the CBI expects that the reduction is reflected in the policy from 1 January 2026 onwards.

This expectation is also applicable to current policies, which are paid in instalments into 2026, and where the Levy charge is explicitly stated within the policy, the Levy should be updated to reflect the reduction from 1 January 2026.

Central Bank publishes roadmap for more effective and efficient regulation and supervision

On 10 December 2025, the CBI published a document (“Roadmap”) entitled “Regulating & Supervising well – a more effective and efficient framework”. The Roadmap sets out the Central Bank’s simplification agenda, describing it as a multi-year, disciplined programme.

The Roadmap refers to the Draghi and Letta reports and the renewed focus on competitiveness and resilience, with the European simplification agenda forming part of this.

The Central Bank has conducted an assessment of areas for simplification and improvement, with the Roadmap outlining its current and intended direction of travel.

The Roadmap provides an overview of how the CBI will, in line with initiatives across Europe, enhance the effectiveness and efficiency of its supervision and domestic regulatory framework, improve gatekeeping processes, and deliver a more integrated and less burdensome reporting and data framework. These initiatives form part of a multi-year programme aligned with the Central Bank’s strategic commitment to transform regulation and supervision.

The Roadmap highlights that the simplification measures set out will, amongst other things, contribute to:

• maintaining and strengthening resilience;
• a regulatory framework that is clearer, simpler, and more coherent, aligned with the evolving European system;
• greater and better demonstrated proportionality;
• improved effectiveness and efficiency of supervision; and
• more predictable processes and procedures for firms, including for initial authorisations.