How is the European Commission’s 5-year agenda shaping up?

With the General Election in sight the 100 days yardstick is a familiar one. However, in Brussels the first 100 days of the full team of European Commissioners (who took up office on 1 November 2014) has passed by relatively unnoticed.

Do not take this as a sign that they have been any less busy. Many of you will have already heard about Commission President Juncker’s ambition to release €315bn into long term investment projects before the end of his 5-year term, and of course the Greek debt crisis has kept them somewhat occupied.

But what about the more day-to-day business? What can we expect over the next 5 years?

Now that the Commission has been in place for 100 days we can start to get a picture of what may be coming our way. Some things are certain, while others remain no more than 'a twinkle in a Commissioner's eye'. But as we all know these ideas can easily develop – and the real test at the moment is identifying the ones that will.

No-one likes uncertainty. But even after 100 days there are only so many judgement calls any sensible person will make. Guesswork does not support certainty so let’s work out what we know, and what we don’t know. To coin a phrase – the known knowns, the known unknowns …

The known knowns:

Nothing is 100% certain other than the proposals already on the table; Data Protection Regulation, Review of the Insurance Mediation Directive (IMD2), and the IORPs Review have all been inherited by the ‘new’ Commissioners. These will be carried through to the end and the new Commissioners will want to get these over the line as soon as they can.

The known unknowns:

We can now see the mist clearing in a few areas. The known unknowns are those issues that we know are coming but there is minimal detail about what they will look like. We know Commissioner Hill will put his mind to reviewing the powers of the European Supervisory Authorities (ESAs), including EIOPA, later on in the year but will that mean more or less power to the ESAs, will EIOPA be told to focus more resource on the implementation of legislation, such as Solvency II, or will they be given a new influence over conduct regulation?

We know a cornerstone project of this Commission is Long Term Investment and the development of the Capital Markets Union (CMU), we saw President Juncker firmly setting this in place ahead of his 100 days. Insurance companies will be affected by these efforts, not least as we are an obvious place to look to as an alternative source of funding to banks. But while we know the Commission will be considering the development of definition of infrastructure and the regulatory barriers to insurance companies investing in such projects, the details are still very much in the making. It is a clear opportunity to ensure that the insurance industry is inputting as the proposals are being developed.

With International Association of Insurance Supervisors (IAIS) and Financial Services Board (FSB) working on it, and EIOPA calling for action at EU level, we also know there will be some activity on resolution and recovery for insurance companies but what exactly? Will there be a cross-sectoral directive putting all non-banking institutions together, and will it entail changes to Solvency II recovery plans?

While it feels like a moving target there is value in knowing something will happen and that the plans of the Commission remain relatively open to input and ideas.

The unknown unknowns:

Always the most unnerving for those who hate uncertainty are the new ideas (those ‘twinkles in Commissioners’ eye’), but these are yet to show any real form. It is too early to draw conclusions but there are a number of recurring themes that are enough to warrant a spot on the radar.

For example, Commissioner Hill has referenced that the variation in the cost of motor insurance from one EU to another several times in his speeches in the last few months. It is highly likely something will emerge here – perhaps a look into the competition of the motor market across the EU?

What about efforts to increase the cross border provision of retail insurance services? This is another recurring theme that we have heard from previous Commissioners, but it is featuring increasingly so under Commissioner Hill. The reality of (or lack of) consumer demand and national consumer protection requirements, based on the different needs and expectations of consumer in each market, has made this a tough one to crack. Will this see the light of day this time around – a pan- European pension product, or perhaps a pan-European motor product?

Commissioner Hill is rightly taking his time to consider the options. Reassuringly he has confirmed that he will not regulate for regulations sake, and may even row back regulation that no longer serves a purpose.

Some of these ideas will grow and develop, others will not. But as representatives of insurers we must continue to place ourselves at the heart of debate so we can shape what comes (whatever it turns out to be in the end).

Carol Hall is Head of European Affairs at the Association of British Insurers (ABI).