DLA Piper Responds to Proposed CBI Guidance for (Re)Insurance Undertakings on Climate Change Risk

The Central Bank of Ireland (CBI) has been seeking responses to its proposed Guidance for (Re)Insurance Undertakings on Climate Change Risk (the Guidance) which was published in August. We previously published an article summarising the proposed Guidance. As of 26 October 2022, the consultation is now closed.

DLA Piper has submitted a response to the proposed Guidance to the CBI. Our submission can be accessed via the link at the end of this article. We expect that the CBI will in due course publish on its website all of the responses it has received.

As a reminder, the Guidance does not aim to introduce new requirements on (re)insurers in relation to climate change risks. It is intended to clarify the CBI’s expectations for the assessment and ongoing management of climate change risk by (re)insurers that are subject to CBI supervision. The proposed Guidance sets out a baseline standard and provides general directions for (re)insurers on how they can meet this standard, notably by reference to other guidance documents from different institutions (eg EIOPA).

The Guidance focuses on five key areas: (i) materiality assessment; (ii) scenario analysis and the ORSA; (iii) strategy and business model; (iv) risk appetite statement; and (v) embedding climate change risk considerations across the business.

If you would like to discuss this topic further, please reach out to any of the contacts below or your usual DLA Piper contacts.