On 22 June 2026 the Central Bank published Consultation Paper 170, which asks two questions about its own machinery: how it should carry out regulatory impact assessment, and how it should consult. It is open to industry, to consumer and civil society representatives and to the public, it closes on 30 September 2026, and a feedback statement is promised after it. Papers about process draw fewer responses than papers about rules, which is usually a mistake — the process is what decides how the next rule arrives.
The reason it matters at this end of the market is arithmetic. A large part of what any prudential rule costs a firm is fixed: the reading, the gap analysis, the policy, the board paper, the sign-off and the first year of evidencing it. That cost is very nearly the same for a large composite as it is for an undertaking that reports a single line of business — credit and suretyship — and held £16.21m of eligible own funds against a Solvency Capital Requirement of £9.96m in the report filed for 2024. Set against the premium each of them writes, it is not remotely the same number. An impact assessment that models cost per firm rather than cost per euro of premium will miss that every time.
What we intend to say is therefore narrow, and we hope useful. Assess a rule against the smallest firm it will apply to as well as the largest. Say inside the paper which firms are in scope, because a specialist reading a document written mainly for the banking sector spends its first afternoon working out whether it is being addressed at all. Allow enough time for a firm whose compliance function is one person to respond. And publish the assessment beside the rule, so that the trade-off which was accepted is visible to the people who have to live inside it.
None of that is an argument for lighter supervision, and we would rather say so plainly than be read as saying the opposite. The authorisation is the product here: a guarantee is worth what the balance sheet behind it is worth, which is why every filed Solvency and Financial Condition Report from 2019 onwards is hosted on this site rather than summarised. Rules a small undertaking can actually implement are what keeps that promise credible, and a badly targeted rule costs the same reader twice — once in compliance and once in the attention it takes away from underwriting.
If you place business with us and there is something you think our response should carry — about how regulatory change reaches an intermediary, or about how long an answer takes while a firm is digesting one — tell the broker desk before the end of September and we will put it in.
Written by the underwriting team at FDI Insurance d.a.c., Dublin. This piece is general information, not advice on any particular transaction — and it is not an offer of insurance.
