Financial Services Omnibus: Simpler rules, greater competitiveness

When insurers implement EU rules, they usually have to comply with more than one piece of legislation. They must navigate requirements across several regulatory frameworks, covering areas such as IT security, business operations and reporting obligations. GDV is therefore calling on the European Commission to introduce a dedicated simplification package for insurers and other financial services providers: a Financial Services Omnibus. 

The term refers to a package of targeted amendments to existing regulations, designed to improve consistency between different frameworks, minimise overlapping obligations and avoid requiring companies to submit the same or similar information multiple times. In recent years, this approach has proven effective in simplifying complex regulatory requirements, including those relating to sustainability, digital regulation and taxation. 

In October 2025, EU heads of state and government instructed the European Commission to present such a simplification package for financial services. The Commission has since announced specific simplification measures for the banking sector. GDV is advocating for the insurance industry to be included as well. 

European insurers in global competition 

The insurance industry's call for simplification is also driven by Europe's position in international competition. While US and Chinese providers now dominate banking and asset management, German and European companies remain among the global leaders in insurance and reinsurance. 

The industry is determined to maintain this position, as it helps ensure that key decisions on risk protection, investment and employment continue to be made in Europe. 

But the issue goes beyond insurance protection. Insurers are Europe's largest institutional investors. German insurers alone manage investments worth approximately €1.9 trillion and make new investments of between €200 billion and €300 billion each year, with more than 70% invested in the Euro area. These funds are invested in areas such as corporate bonds, infrastructure and venture capital. When unnecessary regulation ties up resources, those resources are no longer available to support the European economy. 

Rising administrative costs – particularly for insurers 

The scale of the administrative burden facing businesses is illustrated by a survey published by the Deutsche Bundesbank in July 2026. According to the survey, administrative costs for companies in Germany rose from an average of 5% of annual turnover in 2022 to around 7% in 2024. 

This is a concern because administrative requirements consume staff capacity, IT budgets and specialist expertise. These resources are then unavailable for other priorities, such as digitalisation and innovation – precisely the areas that are critical to competitiveness. 

The insurance and financial services sector experienced particularly sharp increases. Administrative costs rose from approximately 7% to 10% of annual turnover, the highest level of any sector surveyed. The Bundesbank identifies extensive reporting requirements, which have been repeatedly revised in recent years, as one of the main reasons for this increase. 

These findings are also supported by a study conducted by the University of St. Gallen, which examined insurance regulation in Germany, Austria and Switzerland. The study concludes that regulatory requirements have become more extensive and complex since 2014. 

Insurers surveyed cited the level of regulatory detail, rigid reporting obligations and frequent changes as major challenges. Small and medium-sized insurers, in particular, face disproportionately high burdens relating to documentation, reporting and IT requirements. 

The study identifies a systematic shortcoming in the application of proportionality – the principle that regulatory requirements should reflect a company's size and risk profile. 

A comparison with the banking sector illustrates the scale of this gap. According to GDV estimates, when the revised Solvency II Directive becomes applicable in January 2027, only around 40 insurers in Germany will qualify as small and non-complex undertakings and therefore automatically benefit from regulatory simplification. This represents approximately 15% of insurers. 

By comparison, around 80% of banks fall into the equivalent category. GDV is therefore calling for higher thresholds and greater regulatory relief for smaller insurers. 

Simplifying Solvency II reporting requirements 

One example of complex insurance regulation is the Solvency and Financial Condition Report (SFCR) required under Solvency II. 

GDV considers the public version of the report excessively detailed and proposes replacing it with a concise disclosure of the solvency ratio aimed at policyholders. Detailed data templates for professional users would remain available. 

The association points out that, on average, individual insurers' SFCRs receive fewer than ten downloads per month. This suggests that the reports are not widely used as a source of consumer information. 

Recovery and resolution: more time for a leaner regulatory framework 

The new EU Insurance Recovery and Resolution Directive (IRRD) will apply from January 2027. 

It requires many insurers to prepare recovery plans regularly and proactively, and to provide national resolution authorities with extensive data for resolution planning – regardless of whether an insurer is actually at risk of financial distress. 

Given the high implementation costs, the complexity of the new requirements and the varying stages of implementation across EU Member States, both insurers and the relevant authorities need sufficient time to establish the necessary structures, processes and data systems. 

The GDV is therefore calling for a phased introduction of the IRRD and a leaner, more risk-based approach to implementation. 

For reporting to resolution authorities, insurers propose a modular reporting framework. Under this approach, all companies would initially provide only basic information that is not already available through existing Solvency II reporting. 

Additional information would be requested only when genuinely necessary for a specific resolution strategy. 

This would help avoid unnecessary duplicate reporting and significantly reduce administrative burdens without compromising the objectives of the IRRD. 

Competitiveness as an objective for supervisory authorities 

Many of the detailed rules governing insurers do not come directly from legislators but from European supervisory authorities. For the insurance sector, this is the European Insurance and Occupational Pensions Authority (EIOPA). 

GDV is calling for EIOPA to be formally required to consider the impact of new standards and guidelines on the industry's competitiveness as an explicit secondary objective. Financial stability would remain the primary objective of supervision. 

A similar mandate is already under discussion for the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA). 

The GDV advocates a consistent approach across all three authorities. 

The United Kingdom provides a potential model, where economic growth and international competitiveness are already established as secondary objectives for financial regulators.