Insurance Europe welcomes the opportunity to comment in writing on Discussion Paper II, forming the basis of discussions during the second meeting of the expert group on European insurance contract law (EICL) (held on 15-16 May 2013), and the relevant section of the final report that will represent the work-output of the expert group by the end of 2013.

Insurance Europe maintains its continuing wish to assist the European Commission in its work of the expert group - set up to establish whether contract law obstacles exist that hinder the cross-border provision of insurance and, if so, establish in what areas of insurance such obstacles are most prevalent.

However, Insurance Europe does have some concerns arising from the organisation of the expert group and the possible publication of working materials arising from its work. There also remains concern over the scope of the work of the expert group – in particular the danger of straying into areas either beyond contract law, or into topics forming the basis of on-going discussions within the EC institutions (such as, for example, PRIPs and IMD 2). Lastly, Insurance Europe has yet to receive evidence that differences in contract law represent the main obstacle to cross-border insurance provision.