While it supports effective product oversight and governance (POG) arrangements, Insurance Europe has urged the European Insurance and Occupational Pensions Authority (EIOPA) not to pre-empt the outcome of EU law and to await the Insurance Distribution Directive (IDD) delegated acts on POG to assess whether there is a need for guidelines in this area.
In response to EIOPA’s consultation on preparatory POG guidelines, Insurance Europe said that guidelines should only be applied where they are required to harmonise the supervision and application of EU law, and where they ensure consistent implementation and application of the provisions stipulated by that law.
It also warned that preparatory guidelines pre-empt the political discussions on Level 2 and limit the scope of discretion of the European Commission for Level 2 measures. The EIOPA regulation does not provide for such anticipatory or preparatory guidelines.
The full response is available here.