FERMA sees need for a review of how the Principle of Proportionality (PoP) is actually interpreted across Member States.

Furthermore, FERMA also sees value in promoting a consistent approach to PoP. This consistency would help to ensure judgment from national competent authorities allows proportionality to be harmonised.

FERMA would also be in favour of clear guidance about the criteria used to assess how PoP should apply. We believe it should be applied according to the scale, nature and complexity of insurance undertakings. This application would allow for a consistent and more predictable evaluation of proportionality, regardless of the location.

FERMA also responded to some questions on cyber insurance. In this part of its response, FERMA welcomed further dialogue with EIOPA .

Read FERMA’s response to the consultation here.