Background IRRD

The IRRD introduces a new harmonisation framework for recovery and resolution planning for the European insurance sector. It focuses on pre-emptive planning and effective crisis management aimed at maintaining the stability of the insurance sector while also allowing for the orderly wind-down of failing insurance undertakings and groups. More information on the IRRD and its implications can be found in our previous blog.

Proposed timing IRRD

The IRRD entered into force on 28 January 2025. European Member States must transpose the IRRD into national law by 29 January 2027. In the Netherlands, the implementation will result in an amendment or replacement of the Recovery and Resolution (Insurers) Act (Wet herstel en afwikkeling van verzekeraars).

Consultations

EIOPA has been appointed to establish technical standards and guidelines for the practical implementation of the IRRD. Currently, two sets of consultations are launched.

First set of consultations

On 29 April 2025, the first draft regulatory technical standards have been published for consultation (see EIOPA's article), related to:

  1. Pre-emptive recovery plans: regulatory technical standards for pre-emptive recovery plans of (re)insurance undertakings.
  2. Selection criteria and market shares: criteria for selecting (re)insurance undertakings required to prepare pre-emptive recovery plans and methods for calculating their market share.
  3. Resolution plans: regulatory technical standards that further specify the minimum elements that have to be included in the resolution plans. The IRRD requires (re)insurance undertakings identified by resolution authorities as performing critical functions to draw up resolution plans.
  4. Identification of critical functions: criteria for identifying functions whose disruption could have serious implications for policyholders, beneficiaries and the broader economy, including financial stability.
  5. Assessment of resolvability: guidelines for assessing the resolvability of (re)insurance undertakings or groups, including the feasibility and credibility of their resolution strategy. 
  6. Removal of barriers: alternative measures for resolution authorities to address or remove impediments to the resolvability of (re)insurance undertakings or groups in scope.
Second set of consultations

On 22 July 2025, EIOPA launched two new consultations (see EIOPA’s article), related to:

  1. Resolution colleges: criteria for establishing resolution colleges who will coordinate and carry out tasks related to the resolution of (re)insurance groups. The consultation covers draft regulatory technical standards on the operation and collaboration of these colleges and provides guidance on the development and assessment of resolution plans, which is also useful for (re)insurance undertakings in preparation.
  2. Provision of information: implementing technical standards specifying the procedures and the minimum set of standardized forms and templates that insurance undertakings must submit to resolution authorities for the preparation of resolution plans.

Next steps?

The consultations for the first batch of technical standards run until 31 July 2025. The consultations for the second batch are open till 31 October 2025.  

Contact

If you have questions about this topic or another financial regulatory topic, please contact our Financial Regulatory Team.