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"The regulatory burden for insurers depends on the way in which the settlement requirements are worked out at the European level," explains Luuk van der Scheer, policy adviser on supervision at the Association. "That is why we ask the Ministry of Finance, in consultation with the Dutch resolution authority (DNB) and EIOPA, to keep the framework proportionate. In other words, to ensure that the framework is in line with the varying size and complexity of insurers."

Policyholders protected

The Netherlands does not have a generally applicable insurance guarantee system, but a Recovery and Resolution of Insurers Act, implemented in the Financial Supervision Act (Wft). This law ensures , among other things, that regulators can intervene early and quickly in the event of problems at an insurer. This protects policyholders and limits the impact on the economy, the financial system and the use of taxpayers' money. With the arrival of the IRRD, other member states, which do not yet have  a similar framework, will also work with it. "We are positive about that," says Van der Scheer. "A European framework strengthens confidence in the insurance sector and ensures a level playing field within Europe."

Keep funding rules the same

In the response, the Association also discusses the financing of insurance guarantee schemes. The Association supports the Ministry's proposal not to change the current financing scheme in the Financial Supervision Act for the recovery and resolution framework. At the same time, the IRRD Article 99 contains the obligation for EIOPA to report on insurance guarantee schemes to the European Commission in the future. The Association would like to continue to discuss this with the ministry.