Insurance Europe welcomes the opportunity to comment in writing on Discussion Paper V, forming the basis of discussions during the fifth meeting of the expert group on European insurance contract law (EICL) (held on 9-10 September 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 continues to be supportive of the objective of the work of the expert group. It has previously noted its concerns over the organisation of the expert group and the procedural rules applying to the expert group. Following discussions between Insurance Europe and the Commission at the last meeting of the expert group, potentially detrimental procedural rules may now be applied to the expert group and its work.

Insurance Europe raises these genuine concerns in the spirit of collaboration and a desire for active participation in the work of the expert group. Insurance Europe would very much appreciate if the Commission would consider the impact some procedural rules may have on the quality and credibility of the final report of the expert group, the purpose of which is to advise the Commission on the mandated question.