Home Knowledge COVID-19: Insurance Considerations – Regulatory Pronouncements

COVID-19: Insurance Considerations – Regulatory Pronouncements


As businesses assess the impact of COVID-19, and insurers consider policy wordings in the context of meeting claims, the Central Bank of Ireland has indicated it is closely monitoring the position.  This position appears aligned with the approach of government.

Central Bank of Ireland expectations regarding COVID-19

The Central Bank issued a Dear CEO letter “Central Bank of Ireland Expectations of Insurance Undertakings in Light of COVID-19” on 27 March 2020. This letter reflects the same theme as a statement published by the UK’s Financial Conduct Authority on 19 March 2020.  

The Central Bank expects insurance companies to take a consumer centric approach (including policy payment breaks, rebates and claims) that complies with Central Bank’s Consumer Protection Code.  Where there are any areas of uncertainty about the meaning of a term in any policy, the Central Bank has expressed the view that an interpretation of the policy which is most favourable to the consumer should prevail. 
The Central Bank is of the view that where business closure claims are made as a result of the recent Government advice to close a business in the context of COVID-19, it should be treated as a direction. 

The Central Bank has said that it will be in contact with firms to discuss the matters address in the letter and how firms propose to address such matters. The Central Bank expects that CEOs of Irish authorised insurance companies shall take responsibility for oversight of how firms are managing the determination of claims. In the case of insurance firms passporting into Ireland, this will mean that the senior management must take responsibility. 

It can be expected that the way in which insurers address COVID-19 claims will be closely scrutinised by the Central Bank.

Government Statements

On 23 March 2020, the Minister for Finance, Public Expenditure and Reform, Paschal Donohoe, requested insurers not to refuse businesses’ loss of earnings claims if the claims are made as a result of a government advised closure issued to prevent the spread of COVID-19. 

Read the Central Bank letter at Dear CEO letter “Central Bank of Ireland Expectations of Insurance Undertakings in Light of COVID-19”

Read the UK Financial Authority statement at FCA sets out expectations for general insurance firms during coronavirus (Covid-19) pandemic

How William Fry can help

For more information on the expectations of the Central Bank , please contact a member of our Insurance Team or your usual William Fry contact.


Contributed by Shannon O’Neill