Insurance Europe welcomes the opportunity to comment in writing on Discussion Paper IV, forming the basis of discussions during the fourth meeting of the expert group on European insurance contract law (EICL) (held on 17-18 July 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 remains committed to the work of the European Commission on EICL and continues 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.

As work has progressed over the last five months, and further tasks have been added (such as the comparison table) it is increasingly difficult to determine the eventual output and scope of the work of the expert group. Added to this, is Insurance Europe’s continued concern over the time frames envisaged for completing the work of the expert group, in particular the completion of the key output - a final report summarising the findings of the expert group.