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PRACTICE NOTES
This Practice Note considers the European Union’s Sixth Money Laundering Directive (EU) 2024/1640 (MLD6) (also known as AMLD6 or 6MLD). MLD6 repeals Directive (EU) 2015/849 (MLD4), as amended by the Fifth Money Laundering Directive (EU) 2018/843 (MLD5). The Practice Note sets out the background to MLD6, key dates, and key provisions, including those related to supervision of anti-money laundering (AML) and counter terrorist financing (CTF) at national level, beneficial ownership registers and Member State Financial Intelligence Units (FIUs). The deadline for national transposition of MLD6 varies depending on the provision, between 10 July 2025 to 10 July 2029. Overview MLD6 aims to bring about a greater level of convergence in the practices of, and cooperation among, national supervisors and FIUs. Its provisions therefore relate to EU level and national supervision of the EU’s AML/CTF legislative and regulatory framework (including around financial sanctions), in contrast to the provisions of the AML Regulation (EU) 2024/1624 which focuses on private sector requirements, in particular the EU’s Single Rulebook on AML/CTF.MLD6 lays down provisions concerning:
NEWS
The European Systemic Risk Board (ESRB) has issued advice to the European Insurance and Occupational Pensions Authority (EIOPA) on draft regulatory technical standards (RTS) to specify criteria for identifying exceptional sector-wide shocks in the insurance sector, as required by Article 144c(7) of the amended EU Solvency II Directive. The advice reflects the ESRB's macroprudential perspective and considers the RTS in relation to EU Solvency II requirements.
PRACTICE NOTES
This Practice Note explains the key elements of the EU Solvency II framework (including the Solvency II Directive 2009/138/EC, the Omnibus II Directive 2014/51/EU and related materials). This Practice Note also considers changes that have been made to the Solvency II Directive by Directive (EU) 2025/2 (the Solvency II amending Directive) which entered into force on 28 January 2025 and must be applied by Member States from 30 January 2027. Solvency II—overview Background and objectives of Solvency II Solvency II is a framework for the taking-up of business and supervision of insurance and reinsurance undertakings (hereafter referred to as ‘firms’) in the EU. Directive 2009/138/EC (the Solvency II Directive) replaced 14 previous Directives (commonly referred to as Solvency I) and provides for a maximum harmonising regime achieving cross-border consistency. It is consistent with other financial service legislation, in particular with the framework for banking supervision (CRD IV/CRR—for more information, see Practice Note: EU CRD IV package—essentials). It applies to insurance groups as well as solo
PRACTICE NOTES
This Practice Note sets out the passporting rights and related notification requirements of insurance undertakings established in the EEA under Directive 2009/138/EC (the Solvency II Directive). The Treaty and Solvency II The Treaty of the Functioning of the European Union (TFEU) provides the general framework for the rights of freedom of establishment and the free movement of services in the EU and within the context of the financial services sector (including insurance businesses), such rights are further defined by the Single Market Directives. The regulatory framework for EEA life and non-life insurers and reinsurers, particularly in relation to supervision, solvency, risk management, governance, reporting and passporting, is set out in the Solvency II Directive, which is supplemented by Commission Delegated Regulation (EU) 2015/35 (the Solvency II Delegated Regulation, and together with the Solvency II Directive, Solvency II) and certain other Implementing and Regulatory Technical Standards (RTS). The Solvency II regime allows insurance undertakings which have obtained authorisation from their relevant home state regulators to pursue the right of establishment and/or the provision of cross-border
PRACTICE NOTES
This Practice Notice provides an overview of the structure and legislative framework of Directive 2009/138/EC (the Solvency II Directive). Solvency II governs the capital, governance and reporting requirements for insurance firms. This Practice Note also details the consultations and draft technical standards published in support of Directive (EU) 2025/2 (the Solvency II amending Directive) following the Solvency II review. Solvency II—overview Solvency II is a framework for the taking-up of business and supervision of insurance and reinsurance undertakings (hereafter referred to as 'firms') in the European Union (EU). The Solvency II Directive replaced 14 existing directives (commonly referred to as Solvency I) and provides for a maximum harmonising regime achieving cross-border consistency. It is consistent with other financial services legislation, in particular with the framework for banking supervision (CRD IV/CRR—for more information, see Practice Note: EU CRD IV package—essentials). Like CRD IV, the Solvency II Directive is based on three pillars: • Pillar 1: valuation and capital requirements • Pillar 2: governance, internal control and risk management requirements • Pillar 3: supervisory reporting and public disclosure For
PRACTICE NOTES
What are insurance-linked securities? Insurance-linked securities (ILS) are a form of risk management for insurance and reinsurance firms. Insurers routinely manage their exposure to risk by entering into an arrangement in which: • the insurer retains its direct liability to its policy holders, but • another firm ◦ receives amounts corresponding to part of the premia paid by policy holders to the insurer, and ◦ is liable to pay amounts to the insurer which correspond to an agreed proportion of losses incurred by the insurer This is also referred to as risk mitigation or risk transfer. The most common form of insurance risk management is reinsurance, where the insurer enters into a reinsurance agreement with another insurance company which specialises in reinsurance. A reinsurer may itself reinsure all or part of the risk that has been transferred to it. This is called ‘retrocession’ rather than reinsurance. The reinsurer of a reinsured risk is called the ‘retrocessionnaire’. ILS are a form of risk management in which: • an insurance or reinsurance firm
PRACTICE NOTES
This Practice Note explains how the EU and the wider EEA decide whether to recognise the equivalence of third country insurance regulation regimes. Introduction The regulation of insurance imposes burdens on firms and groups (insurance groups). The burden may be duplicated when an insurance business carries out business in a range of different countries. A recognition of equivalence by one state, A, of another state, B, may to a greater or lesser extent reduce that burden. The EU equivalence regime The only insurance equivalence regimes applying in the EU arise in relation to the prudential regulation of insurance. Even within the prudential sphere they are limited in scope. There are no EU insurance equivalence regimes applying in relation to rules on conduct of business (ie relationships with customers) or the activities of brokers or other insurance distributors. To understand the equivalence regime it is best to consider the prudential background and what the equivalence regime is not before explaining what it is. What is prudential regulation? Prudential regulation requires firms and insurance groups to
CHECKLISTS
This timeline shows key developments relating to the EU’s Solvency II framework (Directive 2009/138/EC). For earlier developments, see: Solvency II—timeline (2007–2023) [Archived]. 2026 Date Source Document Description 14 September 2026 European Commission Commission Implementing Regulation (EU) 2026/2041 of 11 September 2026 laying down rules for the application of Directive 2009/138/EC of the European Parliament and of the Council as regards technical information for the calculation of technical provisions and basic own funds for reporting with reference dates from 30 June 2026 until 29 September 2026 Commission Implementing Regulation (EU) 2026/2041 of 11 September 2026 laying down rules for the application of Directive 2009/138/EC of the European Parliament and of the Council as regards technical information for the calculation of technical provisions and basic own funds for reporting with reference dates from 30 June 2026 until 29 September 2026 has been published in the Official Journal of the EU. It enters into force on 15 September 2026 and applies from 30 June 2026.See: Solvency II: regulation on calculation of technical provisions and basic own funds for reporting published in the OJ. 16
PRACTICE NOTES
Below lists European Commission decisions involving in-depth State aid investigations and completed State aid sector inquiries since 2016 (note–recent in-depth investigations are found in the EU State aid decisions—ongoing cases tracker). For details of State aid appeals before the General Court, see General Court State aid appeals—ongoing cases tracker, for details of State aid appeals before the Court of Justice, see Court of Justice State aid appeals—ongoing cases tracker, and for details of national reference cases before the Court of Justice involving State aid, see Court of Justice State aid national references—ongoing cases tracker. In-depth investigations—2026 Case name (including case number) Sector Type of aid Decision Subsidies for recognised Flemish land managing nature organizations (SA.36303)Belgium Agriculture, forestry and fishing Direct grant scheme 27/06/2003 to 28/10/2018 • Does not constitute aid—08/09/2026• Decision to initiate formal investigation (Art 4(4))—20/06/2024 Regional aid to PCAE (Peugeot Citroën Automóviles España S.A.) (SA.49579)) Spain Manufacture of motor vehicles Direct grant • Withdrawal of notification—03/03/2026• Decision to initiate formal investigation procedure (Art 4(4))—01/07/2019 In-depth investigations—2025 Case name (including case number) Sector Type
PRACTICE NOTES
Below lists European Commission decisions involving non in-depth State aid investigations and completed State aid sector inquiries since 2016 (note–recent in-depth investigations can be found in the EU State aid decisions—ongoing cases tracker). For details of State aid appeals before the General Court, see General Court State aid appeals—ongoing cases tracker, for details of State aid appeals before the Court of Justice, see Court of Justice State aid appeals—ongoing cases tracker, and for details of national reference cases before the Court of Justice involving State aid, see Court of Justice State aid national references—ongoing cases tracker. Non in-depth investigation—2025 Case name (including case number) Sector Type of aid Decision March 2025 Criteria, modalities and procedures for the implementation of the District Contracts and the related aid measures concerning food districts, within the meaning of the provisions relating to District Contracts () Italy Agriculture, forestry, rural areas Direct grant scheme until 31/12/2029 • Did not raise objections (Art 4(3))—07/03/2025 February 2025 Investment aid ('Investeringsstøtten') (SA.115268)Denmark Fisheries and aquaculture Direct grant scheme until
PRACTICE NOTES
On 23 March 2022, the European Commission (Commission) adopted a Temporary Crisis Framework (TCF) to enable Member States to use the flexibility foreseen under State aid rules to support the economy in the context of Russia's invasion of Ukraine, based on Article 107(3)(b) TFEU. On 9 March 2023, the Commission adopted the Temporary Crisis and Transition Framework (TCTF) to support measures in sectors which are key to accelerate the green transition and reduce fuel dependencies. The TCTF replaced the TCF. On 25 June 2025, the Commission adopted the Clean Industrial Deal State Aid Framework (CISAF) to support the Clean Industrial Deal. The CISAF replaced the TCTF. The CISAF will remain in place until 31 December 2030. This document tracks all Commission decisions issued under the TCF, TCTF, and CISAF. NOTE—For all State aid decisions issued by the Commission under the Temporary Framework adopted in the context of the coronavirus (COVID-19) outbreak, see further—Coronavirus (COVID-19)—State aid case tracker NOTE—For all ongoing and completed Commission decisions involving State aid under the normal rules, see further,
PRACTICE NOTES
Below tracks recent European Commission ongoing in-depth investigations and ongoing State aid sector inquiries. Closed investigations are moved to EU State aid decisions (non in-depth investigations)—closed cases tracker . For details of State aid appeals before the General Court, see General Court State aid appeals—ongoing cases tracker, for details of State aid appeals before the Court of Justice, see Court of Justice State aid appeals—ongoing cases tracker, and for details of national reference cases before the Court of Justice involving State aid, see Court of Justice State aid national references—ongoing cases tracker. In-depth investigations Case (Case number) Member State Industry sector Type of aid Latest development Arbitration award to ten companies that invested in five solar photovoltaic power plants (SA.113263)Romania Renewable energy Other • Decision to initiate formal investigation procedure—29/07/2026 Capital injection into PostNord Strålfors A/S (SA.56621 and SA.56622)Denmark Customer communication management Capital injection • Decision to initiate formal investigation procedure—24/07/2026 Capital injection into Post Danmark (SA.47707)Denmark Postal services Capital injection • Decision to initiate formal investigation procedure—30/06/2026 Modification of restructuring plan of CE Oltenia (amendment to SA.59974) (SA.117913)Romania Production