NFU Position Paper on Solvency II and IRRD

Executive summary

The Nordic Financial Unions (NFU) express concerns over the ongoing negotiations regarding the IRRD and Solvency II framework. While acknowledging efforts to accommodate diverse viewpoints, NFU argues that equating insurance with the banking sector could compromise consumer protection. The NFU stresses that the draft rules disproportionately affect mutual insurance undertakings, which are prevalent in Nordic countries and collectively owned by policyholders. Phasing out profit-sharing reserves, as proposed, would undermine mutual insurers' ability to maintain adequate risk capital, threatening their existence. NFU urges the ECON team to reconsider these amendments and proposes exemptions for mutual insurers to preserve their sustainable and policyholder-focused business model.