CBI 2021 Updates | Central Bank of Ireland

September 29th 2021

“Insurance firms require strong customer-focused cultures and Central Bank will intervene on practices unfair or potentially unfair to consumers” – Director General Derville Rowland

Differential Pricing and Business Interruption Insurance demonstrate Central Bank’s focus on conduct, culture and customer treatment Over €130 million paid in business interruption insurance claims to date Insurance sector needs to be prepared for the challenges ahead including digitisation and climate change Speaking…

Why this matters

This regulatory update from the Central Bank of Ireland focuses on the insurance sector, with a emphasis on conduct, culture, and customer treatment, particularly around business interruption insurance and differential pricing. It also discusses the sector's future challenges including digitization and climate change.

Sectors:

Insurance & Pensions

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Operational Resilience / Outsourcing

Insurance

View Original

🇮🇪 CBI Speech

September 29th 2021

Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar

Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar Good morning everybody and thank you to Deloitte for the invitation to speak at this webinar. Some people think of insurance as a relatively modern financial concept. But of course, as the insurance experts in this…

Why this matters

I cannot provide the detailed compliance analysis you've requested because the specific regulatory publication you referenced—"Remarks by Director General, Financial Conduct Derville Rowland at the Deloitte Global Insurance Webinar" (29 September 2021)—is not included in the search results provided. The search...

Compliance Deadline: 1 July 2022

Sectors:

Insurance & Pensions

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Senior Managers / Governance

Insurance

View Original

🇮🇪 CBI Consultation Significant

July 21st 2021

Central Bank proposes to end the loyalty penalty for private car and home insurance customers

Review finds that differential pricing practices can result in unfair outcomes for some consumers Proposal to ban the practice of ‘price walking’ to end the loyalty penalty for consumers who do not switch insurance provider regularly Proposals will ensure that new business discounts are still available to allow…

AI Analysis

The Central Bank of Ireland (CBI) proposes banning "price walking" in private car and home insurance to eliminate the loyalty penalty, where long-term customers pay significantly higher premiums (14% more for car, 32% more for home after 9 years) than new customers with similar risk profiles. This stems from a 2021 review finding differential pricing unfair to loyal or less mobile consumers, with regulations finalized and effective from 1 July 2022, confirmed effective in subsequent reviews. It matters as it enforces fair treatment under CBI's consumer protection mandate, requiring insurers to overhaul pricing models while preserving new customer discounts to maintain competition.

Key dates

22 October 2021: - Consultation period closes for proposals in the final report
Early 2022: - CBI intends to finalize measures post-consultation
15 March 2022: - Publication of final Insurance Requirements Regulations 2022
1 July 2022: - Regulations apply to insurance undertakings and intermediaries; ban on price walking effective
2023/2024: - CBI review confirms regulations working, no loyalty penalty observed, no further measures needed at that time

Suggested considerations

Pricing model adjustments: Revise systems to ensure renewal premiums ≤ year-one premiums for equivalent risks; test against historical data (e.g., 11 million policy records analyzed).
Disclosure updates: Amend new customer communications to explicitly state "new business discount" inclusion.
Governance and reviews: Implement annual pricing policy reviews with documented evidence of customer impact assessment and fair treatment compliance; integrate into board/CPC oversight.
Renewal processes: Obtain explicit consumer consent for auto-renewals; provide reminders and clear switching info pre-renewal.
Monitoring and reporting: Conduct internal audits; respond to CBI engagements; retain records for supervision.

What changed

- Ban on price walking: Insurers cannot charge second or subsequent renewal customers a higher premium than an equivalent year-one renewal customer with similar risk and service cost.
Disclosure of new business discounts: Firms must clearly disclose to new customers that lower prices include a new business discount.
Annual pricing policy reviews: Providers must review pricing policies yearly to ensure focus on customer impact, adherence to rules, and fair treatment.
Automatic renewals requirements: Introduce consumer consent for automatic renewals and enhanced information/reminders to support informed decisions and switching. These were implemented via the...

Compliance impact

Urgency: low (as of 2026). Rules have been effective since July 2022, with CBI's 2023/2024 review confirming no loyalty penalties, no unintended consequences, and market stability—Ireland was first EU state with such a ban. Firms compliant since 2022 face ongoing low-risk monitoring; non-compliance risks enforcement under Section 48(1), but positive outcomes reduce immediate pressure. Matters for legacy audits or CPC reviews.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Compliance Deadline: 1 July 2022

Sectors:

Insurance & Pensions

Topics:

Consumer Protection / Conduct

Insurance

View Original

🇮🇪 CBI Speech

June 23rd 2021

Supervisory Priorities in Uncertain Times - Domhnall Cullinan, Director of Insurance Supervision

Introduction Good morning, and thank you for attending our Insurance Industry Event, the second of these which we’ve held virtually. Hopefully, as the vaccine rollout continues and restrictions are eased, there won’t have to be a third! The COVID 19 crisis has brought about a significant amount of change to all of our…

Compliance Deadline: 31 March 2022

Sectors:

Insurance & Pensions

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Senior Managers / Governance

InsuranceAll Firms

View Original

🇮🇪 CBI Speech

June 10th 2021

The importance of fitness, probity and ensuring responsibility - Director General, Financial Conduct, Derville Rowland

Speech delivered at Institute of Directors’ Briefing Webinar on 10 June 2021 Good morning everyone, I am delighted to speak to you on the importance of effective culture in firms, the contribution fitness and probity can make, and how we see the forthcoming Individual Accountability Framework further reinforcing…

AI Analysis

This 2021 speech by Derville Rowland, Director General of Financial Conduct at the Central Bank of Ireland (CBI), emphasizes the critical role of the Fitness & Probity (F&P) regime and the forthcoming Individual Accountability Framework (IAF) in fostering effective culture, governance, and individual responsibility in regulated firms. It matters because it signals CBI's supervisory priorities on senior role holders' competence, integrity, and accountability, which have since evolved into concrete regulatory updates, directly impacting board and compliance functions to mitigate conduct risks and ensure consumer protection. https://www.centralbank.ie/news/article/speech-importance-of-fitness-probity-and-ensuring-responsibility-derville-rowland-10-june-2021

Key dates

22 September 2021: - CBI notice of intention to amend PCFs under F&P regime (e.g., new Designated Persons roles)
20 November 2025: - Effective date for revised Guidance on Fitness and Probity Standards
24 November 2025: - CBI publishes Feedback Statement on CP160, Fitness and Probity Standards 2025, and revised Guidance
Post: amendment (TBD, after regulations effective); - 6-week window for in-situ PCF assessments and confirmations to CBI

Suggested considerations

Conduct thorough F&P due diligence on PCF/CF holders pre-appointment and ongoing (best-efforts for references, criminal/financial checks via public records; assess time commitments case-by-case).
Certify annually that PCF/CF individuals meet standards; no dual certification needed if PCF covers CF-1/2.
Review and update succession planning, handover policies, and conduct breach procedures in light of new PCFs and IAF/SEAR (Statements of Effectiveness and Accountability of Responsibilities).
Assess residency and capacity for non-resident PCF holders case-by-case, considering firm complexity.
Embed F&P into culture and governance frameworks, aligning with IAF Conduct Standards once enacted.[Speech]

What changed

The speech itself outlines no new statutory changes but highlights the F&P regime's role in ensuring "fit and proper" individuals in key roles and previews the IAF as a complementary framework to...
Consolidation of F&P Standards into the Fitness and Probity Standards 2025, applicable across all sectors, read alongside revised Guidance on the Fitness and Probity Standards (effective 20 November...
Amendments to Pre-Approval Controlled Functions (PCFs), adding roles like Designated Person for Investment Management (PCF-39D), Distribution (PCF-39E), and Regulatory Compliance (PCF-39F),...
Clarifications on due diligence (best-efforts basis for references, criminal checks, financial soundness via public records only—no bank statements required), time commitments (case-by-case), and...
Proportionality for fitness assessments but not probity; ongoing certification obligations for Controlled Functions (CFs) and PCFs. These build on the speech's vision, addressing Enria Report...

Compliance impact

Urgency: High – While the 2021 speech is foundational, 2025 Standards and Guidance are now effective, mandating immediate due diligence enhancements and certifications amid IAF rollout. Non-compliance risks CBI investigations, prohibitions, or sanctions, especially with expanded PCFs tying into broader accountability (e.g., SEAR). This elevates board exposure, demanding proactive governance reviews to align culture with consumer protection mandates.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Banking & Credit Investment Management Insurance & Pensions

Topics:

Senior Managers / Governance Consumer Protection / Conduct Authorisation & Licensing

BankAsset ManagerInsurance

View Original