Insurance Europe welcomes the opportunity to comment in writing on Discussion Paper III, forming the basis of discussions during the third meeting of the expert group on European insurance contract law (EICL) (held on 25-26 June 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 reiterates 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.

Insurance Europe has previously noted its concerns arising from the organisation of the expert group, the approval processes and the publication of on-going working materials arising from its work. Previous concerns over the scope of the work of the expert group have resurfaced in the light of the Commission’s desire to compile a comparative analysis of national contract laws – covering the areas of contract law considered in Discussion Paper III and the forthcoming Discussion Paper IV.