A more innovation-friendly EU single market for financial services is one of the three core pillars of Insurance Ireland’s vision for the future of the EU marketplace. Therefore, we greatly appreciate and support the European Commission’s initiative on a new digital finance strategy and a review of the fintech action plan. On 3rd April 2020 the European Commission launched a consultation to seek stakeholders’ views on core aspects of digital finance.

Insurance Ireland and its members welcome the opportunity to contribute. Digital finance is not a purpose in itself. The ambitions of our members to innovate aim at improving consumer-experience as well as more effective and efficient processes. Therefore, a strong focus of the digital finance strategy needs to be on the interaction of digital solutions and regulation. Overall, we favour a technology-neutral and innovation friendly EU Financial services regulatory framework which considers ever increasing role of data in financial services. In addition to the regulatory framework, we will have to enhance the digital operational resilience of the single market.

Our submission to the European Commission’s consultation focuses on all aspects of digitalisation including its role, usefulness and challenges. We believe that the key aspects of the new digital finance strategy are:

1. Balance the pace between increased regulation and digitalisation that poses challenges to innovation;
2. Enhance regulatory consistency as overlapping legislation at domestic and European levels hinders the realisation of the full opportunities offered by innovative technologies, especially with a view to servicing the single market,
3. Facilitate the development of tech-specific expertise in supervisory authorities to ensure effective, efficient and consistent supervision and consumer protection,
4. Create an EU regulatory sandbox to help progressing digitally innovative financial services products to consumers across the whole single market,
5. Enhance financial and tech-related literacy and education to allow consumers to fully embrace increasing consumer choice and benefit from more efficient processes, i.e. on ever-growing cyber risks,
6. Improve data sharing in a transparent manner which is compliant with all relevant regulations, such as GDPR and e-Privacy, to ensure that data can be used to its full value for the society and economy.

The recent consultation is only one step towards a more innovation-friendly and integrated EU single market for financial services. We are committed to work with our members, EU institution, supervisors and all other stakeholders. In case of any question or need for further information on these and other aspects of our work on innovation and technology,please, contact Ajay Pathak (ajay.pathak@insuranceireland.eu) and Natalie Dillon (natalie.dillon@insuranceireland.eu).