REPUBLIC OF MOLDOVA
NATIONAL COMMISSION OF FINANCIAL MARKET

DECISION

10 March 2026
No. 12/4

Regarding the Preliminary Request, submitted by SA „ACORD GRUP” SA, concerning the annulment of Decision of the National Commission of Financial Market No. 3/3 of 20.01.2026 regarding the petitions registered with the National Commission of Financial Market under No. 8299 and No. 8567 on 14.11.2025 and, respectively, on 27.11.2025, in relation to SA „ACORD GRUP” SA

On 18.02.2026, within the National Commission of Financial Market (NCFM), was registered (under No. 1018) the Preliminary Request No. 240/2026 of 17.02.2026 (Preliminary Request), submitted by SA „ACORD GRUP” SA (insurer), by which is requested:

„1. As principal relief, to admit this preliminary request and to annul (revoke) in full the NCFM Decision No. 3/3 of 20.01.2026 as being issued with the erroneous application of the law, with exceeding the material competence and with the misinterpretation of the norms of Law No. 106/2022. 2. As secondary relief, in order to avoid the serious and irreparable harm to the interests of ACORD GRUP, as well as to those of the other professional participants on the insurance market of the Republic of Moldova, to order the suspension of the execution of the NCFM Decision No. 3/3 of 20.01.2026 until the completion of the preliminary procedure.”.

In this case, it is to be noted that, in order to ensure a full, objective and transparent investigation, which would offer the real possibility of analyzing the claim, the insurer is notified that the examination of the factual and legal circumstances, relevant to the case, in preliminary order, is carried out by distinct enforcement officers within the NCFM.

In fact, on 14.11.2025, and, additionally, on 27.11.2025, within the NCFM, were registered (under No. 8299 and, respectively, under No. 8567) the petitions submitted by Mrs. […], attorney, in the interests of Mr. […] (insured/consumer) and of […] SRL (lessee), by which is requested the intervention of the NCFM in relation to the actions of SA „ACORD GRUP” SA.

Following the investigations carried out in the context of the respective administrative procedure, of the analysis of the materials/evidence presented by the participants to the procedure, in light of the normative framework incident to the contractual relations, the NCFM, on 20.10.2026, adopted Decision No. 3/3 regarding the petitions registered with the National Commission of Financial Market under No. 8299 and No. 8567 on 14.11.2025 and, respectively, on 27.11.2025, in relation to SA „ACORD GRUP” SA (Decision No. 3/3/2026/Contested Decision), by which it was decided:

bd. Ștefan cel Mare și Sfânt, no. 77, mun. Chișinău, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md

„1. It is found the violation by SA „ACORD GRUP” SA of art. 13 para. (1) of Law No. 105/2003 on consumer protection through the use of unfair commercial practices in offering information related to the calculation of the insurance premium and in the termination of the Compulsory Motor Third Party Liability Insurance Contract No. […], issued on 02.09.2025.

2. It is found the violation by SA „ACORD GRUP” SA of art. 89 para. (1) let. a), let. b) and let. d) of Law No. 92/2022 on insurance or reinsurance activity.

3. It is found the violation by SA „ACORD GRUP” SA of art. 12 para. (3) and para. (7) of Law No. 106/2022 on compulsory motor third party liability insurance for damage caused by vehicles.

4. SA „ACORD GRUP” SA is prohibited from applying unfair commercial practices, as misleading omissions, by omitting essential information or offering it in an unclear, unintelligible, ambiguous manner and which, in any situation, causes or is likely to cause the consumer to take a transactional decision that he would not have taken otherwise.

5. SA „ACORD GRUP” SA is prohibited from applying aggressive commercial practices, by limiting the consumer's freedom and behavior in relation to the product, by unjustified and practical influence, which causes or is likely to cause the consumer to take a transactional decision that he would not have taken otherwise.

6. Mr. […] is informed about the right to request remedial measures, proportionate and effective, including price reduction or reimbursement of the equivalent value, through termination of the contract, as well as compensation for the damage suffered, provided for in art. 15 para. (6) of Law No. 105/2003 on consumer protection.

7. SA „ACORD GRUP” SA is prescribed to revise the internal procedures regarding the notification, recalculation of the premium and termination of MTPL insurance contracts, in order to ensure compliance with the provisions of Law No. 106/2022 on compulsory motor third party liability insurance for damage caused by vehicles and the requirements of consumer protection legislation.”.

Disagreeing with the NCFM's findings, the insurer submitted a Preliminary Request, by which it requests the annulment of the Contested Decision, as well as the suspension of its execution. In this case, it is noted that in the part of the suspension request, previously was adopted Decision No. 10/4 of 24.02.2026 regarding the request for suspension of the execution of the Decision of the National Commission of Financial Market No. 3/3 of 20.01.2026 regarding the petitions registered with the National Commission of Financial Market under No. 8299 and No. 8567 on 14.11.2025 and, respectively, on 27.11.2025, in relation to SA „ACORD GRUP” SA.

A priori, it is noted that in accordance with art. 20 of the Administrative Code, „If through an administrative activity a legitimate right or a freedom established by law is violated, this right may be claimed through an administrative contentious action, [...]”, and according to art. 17, „Injured right is any right or freedom established by law which is affected through administrative activity.”.

In law, according to art. 19 of the Administrative Code, "The preliminary request is the institution that offers a way of pre-judicial resolution of administrative disputes.", and, in accordance with the provisions of art. 162 para. (1) and para. (3) of the same law, "(1) The preliminary procedure aims to verify the legality of individual administrative acts. [...] (3) The preliminary request may be directed towards: a) the annulment in whole or in part of an illegal or void individual administrative act; b) the issuance of an individual administrative act.".

Under the conditions of art. 166 of the Administrative Code, "The preliminary request may be filed only if the person claims his/her rights infringed by the issuance or rejection of the issuance of an individual administrative act.".

Analyzing the arguments set out in the Preliminary Request, in light of the legal provisions applicable to the case, it will be assessed whether they are of such a nature as to overturn the findings of the CNPF, as follows:

1. In fact, on 02.09.2025, Mr. […], through the Insurance Broker "VR INSURANCE GROUP" SRL, filed with SA "ACORD GRUP" SA an application for the conclusion of the Compulsory Motor Third Party Liability Insurance Contract for damage caused by vehicles (compulsory MTPL insurance), in which he indicated, under "chapter 5. Characteristics K3 Legal status of the insured", the capacity of "Natural person".

On the basis of this application, the Compulsory MTPL Insurance Contract no. […] (Compulsory MTPL Insurance Contract) was concluded, valid for the period 04.09.2025 – 03.09.2026, in relation to the vehicle TOYOTA PRIUS, with reg./ch. no. […]. The Compulsory MTPL Insurance Contract was concluded in accordance with art. 8 para. (1) of Law no. 106/2022 on compulsory motor third party liability insurance for damage caused by vehicles (Law no. 106/2022), with the natural person – owner of the vehicle, who acquired the capacity of insured and holder of the personal motor third party liability risk.

According to item 8 of the Compulsory MTPL Insurance Contract, the insurance premium was calculated in the amount of 1 324,70 lei, with the presentation of its calculation, in accordance with art. 12 para. (3) of Law no. 106/2022.

Subsequently, on 03.09.2025, the vehicle TOYOTA PRIUS, with reg./ch. no. […], was transferred into the possession of […] SRL, under the Lease Contract no. 11 of 03.09.2025.

In accordance with art. 4 para. (1) and art. 8 para. (3) of Law no. 106/2022, in the situation at hand, the legal person, which operated the vehicle, had the obligation to conclude its own MTPL contract, an obligation which, according to the case materials, was not fulfilled.

Subsequently, the vehicle transferred under lease to […] SRL was involved in 2 road accidents, the lessee's driver being found at fault. Accordingly, the insurer, in both cases, paid the insurance compensation, requesting, at the same time, the restitution, by […] SRL, of the amount paid, on the basis of art. 8 para. (3) and para. (4) and art. 30 para. (1) lit. a) of Law no. 106/2022.

Additionally, on 22.10.2025, SA "ACORD GRUP" SA notified Mr. […] and […] SRL of the fact that, upon the conclusion of the Compulsory MTPL Insurance Contract, "Mr. […] provided information that does not correspond to reality in order for the insurer to be able to assess the degree of risk [...]", requesting, according to the provisions of art. 12 para. (6) and para. (7) of Law no. 106/2022, the modification of the insurance premium, by re-drafting it for the legal person – […] SRL, with the payment of the insurance premium difference in the amount of 19 326,79 lei.

At the same time, the insured and […] SRL were notified of the fact that, in the event of non-resolution of the request, the Compulsory MTPL Insurance Contract is to be terminated within 20 days from the notification.

In the alternative, on 17.11.2025, the notification regarding the termination of the Compulsory MTPL Insurance Contract was sent to the address of Mr. […], as a result of the unilateral termination, reference being made to Order no. 17-1-2025 of 13.11.2025, by which the termination, as of 13.11.2025, of the Compulsory MTPL Insurance Contract was established, with the revocation of the insurance policy no. […] and with the allocation of the insurance premium for the unused period to other income of the insurance activity.

2. With reference to the legal framework applicable to the case, the insurer claims that the contested Decision "(i) applies a wrong legal framework, (ii) ignores the special law no. 106/2022,".

In support of that conclusion, the insurer claims that the CNPF applied "artificially" Law no. 105/2003 "in a legal relationship strictly regulated by a special law (the MTPL Law)", which, in its opinion, "constitutes an ultra vires interpretation.".

That argument cannot be upheld given that art. 2 para. (1) of Law no. 105/2003 on consumer protection (Law no. 105/2003) provides that "(1) This law establishes the general requirements for consumer protection, for ensuring the framework necessary for unrestricted access to products and services, complete information on their main characteristics, the defense and ensuring of the legitimate rights and interests of consumers in the case of unfair commercial practices, their participation in the substantiation and taking of decisions that interest them as consumers.". At the same time, in art. 36 para. (2) lit. g) of the same normative act, it is established that "(2) The control of compliance with the provisions of the legislation on consumer protection in the part concerning the safety and quality of products and services, introduced or made available on the market and intended for consumers, including in the part concerning fair practices in the field, is carried out: […] g) over the subjects provided for in art. 4 para. (21) of Law no. 192/1998 on the National Commission of the Financial Market – by the National Commission of the Financial Market;".

In this regard, CNPF concludes that the insurer's statements are erroneous, and Law No. 105/2003 governs all legal relationships between the professional and the consumer, constituting the general regulatory framework for those relationships, while the special law establishes specific rules arising from the legal nature of insurance relationships. However, the existence of special rules does not exclude the application of the general framework, unless the legislator expressly indicates this fact.

3. Regarding aggressive commercial practices, CNPF found that, contrary to the provisions of Art. 89 para. (1) lit. a), lit. b) and lit. d) of Law No. 92/2022 on insurance or reinsurance activity (Law No. 92/2022), which impose on the insurance company the obligation to act with professionalism, honestly, to respect the rights and interests of the insured and to provide the latter with information regarding insurance premiums, as well as in breach of the requirements of professional diligence, within the meaning of Art. 1, Art. 13 para. (2) lit. a) of Law No. 105/2003, the insurer, on 22.10.2025, sent a notification to Mr. […], by which it invoked the insured's violation of legal provisions, requesting, as a consequence, the re-execution of the Compulsory Motor Third Party Liability Insurance Contract in the name of […] SRL, with the amendment of the insurance premium.

SA „ACORD GRUP” SA, in the notification dated 22.10.2025, claims that, at the conclusion of the Compulsory Motor Third Party Liability Insurance Contract, „Mr. […] provided information that does not correspond to reality so that the insurer could assess the degree of risk, although in the application he confirmed that the information presented is truthful”.

From the examination of the case materials, it results that:

1) on 02.09.2025, Mr. […] correctly declared his status as a natural person, he being the owner and user of the vehicle;

2) The lease contract with […] SRL was concluded subsequently, with No. 11 on 03.09.2025.

Therefore, within the limits of the factual circumstances invoked and in the absence of contrary evidence, a discrepancy in the information provided at the time of concluding the Compulsory Motor Third Party Liability Insurance Contract cannot be retained, this being an essential condition for the application of Art. 12 para. (6) of Law No. 106/2022.

In this case, Art. 12 para. (6) of Law No. 106/2022 expressly indicates that the mechanism for recalculating the premium can intervene only in the situation where the information provided by the insured does not correspond to reality „at the time of concluding the compulsory motor third party liability insurance contract”.

Also, the invocation of the subsequent aggravation of the risk, under Art. 12 para. (7) of Law No. 106/2022, in the sense of the use of the vehicle by a legal person in taxi regime, is unfounded, because:

1) the use of the vehicle by the legal person does not affect the personal risk of civil liability of the insured natural person;

2) Art. 8 para. (3) of Law No. 106/2022 expressly provides that the risk of the users of the legal person is considered insured, the insurer having exclusively the right of recourse, not the right to modify or terminate the contract of the natural person.

Consequently, the information obligation and any sanctioning measures could only target the subject that exploited the vehicle for commercial purposes, namely, the legal person, but not the initial insured (natural person), however, Art. 12 para. (7) of Law No. 106/2022 cannot be interpreted extensively, to the detriment of the insured and in order to eliminate the consequences of the lessee's non-compliance with the insurance obligation, by modifying the contractual subject or by terminating the contract of an insured, in relation to whom there are no signs of violation of the law.

In this case, in the Preliminary Request, the insurer invokes the fact that „the termination is not a commercial practice, but is a legal mechanism expressly regulated by Art. 12 para. (7) of Law No. 106/2022.”.

In this regard, it should be mentioned that Art. 12 para. (7) of Law No. 106/2022 establishes both a perfectly legal mechanism and the exhaustive conditions under which this mechanism is to be applied.

In context, the right to terminate the insurance contract can be exercised only if the insured „does not give consent for the modification of the contractual conditions under the conditions of para. (6) of this article.”,

In turn, Art. 12 para. (6) of the same law clearly specifies that the basis for modifying the insurance premium is the fact that „the information provided by the insured, according to Art. 8, does not correspond to reality at the time of concluding the compulsory motor third party liability insurance contract”, an aspect that is not attested in the situation at hand.

By the notification dated 22.10.2025, the insurer requested „the modification of the insurance premium for contract No. RCAI […] of 02.09.2025 by re-executing it in the name of the legal person […] SRL with the payment of the insurance premium difference in the amount of 19326,79 lei.”, under the sanction of the termination of the Compulsory Motor Third Party Liability Insurance Contract, a sanction that was, in fact, applied by Order No. 17-1-2025 of 13.11.2025.

The obligation to increase the premium, recalculate the risk or apply contractual measures could only target the contract of the legal person (non-existent in this case), but not the valid Compulsory Motor Third Party Liability Insurance Contract concluded with the natural person, who has not lost his status as insured.

Thus, the transfer of the vehicle for use, after the conclusion of the insurance contract, cannot alter the right of the owner, a natural person, to benefit from the concluded insurance. At the same time, following the conclusion of the lease contract, the obligation of the lessee to conclude the Motor Third Party Liability Insurance Contract for damage caused by vehicles arises.

In this regard, the situation at hand does not require an aggravation of the risk resulting from the Compulsory Motor Third Party Liability Insurance Contract, but rather involves a new subject, who had the obligation to conclude a motor third party liability insurance contract for damage caused by vehicles, but which was not complied with.

Under such conditions, the legal protection of the insurer consists in filing the recourse action, under art. 30 para. (1) letter a) of Law no. 106/2022, but by no means the termination of the insurance contract.

Moreover, by requesting the re-execution of the compulsory RCA insurance Contract from a natural person to a legal person, in this case, to […] SRL, the insurer exceeded the discretionary right and the principle of contractual freedom, which belongs exclusively to Mr. […], whereas he did not have the right to modify the subject of the contract, nor to condition this fact.

As a direct effect of this conduct, which is likely to materially distort the economic behaviour of the consumer, as provided in art. 13 para. (2) letter b) of Law no. 105/2003, Mr. […] was deprived of the insurance of his personal motor third party liability risk, although no violation attributable to him was established and there was no legal basis for the termination of the compulsory RCA insurance protection.

Furthermore, the insurer, in order to comply with the principles of professional diligence, was to:

1) clearly delimit the subjects of the contractual obligation;

2) apply sanctions only to the legal subject targeted by the norm;

3) use exclusively the instruments provided by law (the recourse).

By applying the termination of the RCA insurance Contract, concluded by the natural person, the insurer unjustifiably extended the effects of the alleged aggravation of the risk to a subject who was not the author of the non-compliant conduct, applied a disproportionate measure lacking legal basis, considerably limited the consumer's freedom of choice in a field characterized by the legal compulsory nature of the RCA service, constrained the consumer to accept unfounded claims under the sanction of losing the RCA protection, whereas termination constitutes the last resort, admissible exclusively in relation to the subject who breached the legal obligation to inform.

In this case, the insurer declares that "it not only had the right, but also the obligation to react to the aggravation of the risk".

On the contrary, the provisions of art. 12 para. (6) and para. (7) of Law no. 106/2022 operate with the statements "the insurance premium may be recalculated" and "the RCA insurer may terminate the contract", which indicates that these mechanisms are rights of the insurer, but by no means obligations.

Therefore, the insurer not only misinterpreted the legal provisions of art. 12 para. (6) and para. (7) of Law no. 106/2022, but also applied them in relation to the consumer, in the absence of the incidence of the legal grounds and of the exhaustive conditions that would give rise to this right of the insurer.

In conclusion, the CNPF found that the insurer terminated the compulsory RCA insurance Contract in the absence of legal grounds, invoking provisions and conditions irrelevant to the situation in the case.

In the context of those mentioned above, according to art. 13 para. (15) of Law no. 105/2003, a commercial practice is aggressive if, in the context of the factual situation:

1) it limits or is likely to significantly limit the consumer's freedom of choice;

2) it coerces or unduly influences;

3) it causes or is likely to cause the consumer to take a transactional decision that, in the absence of this practice, he would not have taken.

According to para. (16) letter d) and letter e) of the same article, for determining whether a commercial practice resorts to coercion, the following conditions are relevant:

1) the imposition of onerous or disproportionate obstacles, not provided for contractually, for the exercise of contractual rights;

2) the threat with measures that cannot be taken legally.

The termination of the compulsory RCA insurance Contract of the natural person did not represent the legitimate exercise of a contractual right, but was used as a means of pressure to determine the acceptance of conditions imposed by the insurer (the re-execution of the Contract on a legal person and the payment of an additional premium).

At the same time, it was preceded by an ultimatum notification, which conditioned the maintenance of the RCA protection on the acceptance of the insurer's request.

This conduct goes beyond the scope of mere information and represents an undue influence, since the insurer exploited its position of contractual power in a field compulsory by law.

The compulsory RCA insurance Contract is not an optional service, but a legal condition for the exercise of the right to use a vehicle.

Through the termination of the compulsory RCA insurance Contract, the consumer was placed in a situation of legal and economic coercion. In the hypothesis of using the vehicle for personal purposes (a right that the owner retains even in the case of transferring the vehicle under a lease), Mr. […] was exposed to the risk of contraventional sanctions1 .

[1] art. 229 para. (3) of the Contraventional Code

At the same time, he was deprived of the insurance protection for his own tortious civil liability, being exposed to personal civil liability for any damages caused to third parties, as well as to the legal impossibility of using the vehicle. Under these conditions, the consumer's freedom of choice was severely restricted, being placed in the situation of either accepting the conditions imposed by the insurer or bearing serious legal consequences.

Thus, the application of the termination constitutes a threat with a measure that could not be taken legally, subsumable to art. 13 para. (16) letter e) of Law no. 105/2003, whereas the termination of the compulsory RCA insurance Contract determined the following consequences:

1) it deprived the consumer of the RCA protection, without an immediate alternative mechanism;

2) it created a severe imbalance between the rights of the insurer and those of the insured;

3) it functioned as an extra-contractual sanction, not provided for by law.

Thus, through the contested Decision, the CNPF found that the respective situation represents an onerous and disproportionate obstacle, expressly prohibited by art. 13 para. (16) let. d) of Law no. 105/2003.

4. Regarding the misleading omission, the CNPF found that, on 22.10.2025, SA „ACORD GRUP” SA notified Mr. […] and […] SRL, requesting the modification of the insurance premium for the compulsory RCA insurance Contract by re-executing it in the name of the legal entity – […] SRL, with the payment of the insurance premium difference in the amount of 19 326,79 lei. In case of non-resolution of the request, the contract was to be terminated within 20 days from the notification.

In the respective notification, it is mentioned that „[...] ACORD GRUP requests the modification of the insurance premium for contract no. RCAI […] of 02.09.2025 by re-executing it in the name of the legal entity […] SRL with the payment of the insurance premium difference in the amount of 19 326,79 [...]”.

Contrary to the provisions of art. 89 para. (1) let. d) of Law no. 92/2022 and art. 12 para. (3) of Law no. 106/2022, according to which the RCA insurer is obliged to provide the insured with complete, clear and verifiable information regarding the amount of the basic insurance premium, the rectification coefficients applied and the bonus-malus coefficient used, the insurer did not provide this essential information.

Thus, contrary to professional diligence, the insurer limited itself to requesting a global amount, as an additional premium, without disclosing the calculation structure and without explaining the elements that determined the claimed increase.

As a factual circumstance, it should be noted that, although […] SRL requested, on 14.11.2025, the presentation of the calculation note, in accordance with art. 12 para. (2) and para. (3) of Law no. 106/2022, the insurer did not comply with the respective request.

Such conduct constitutes a misleading omission, within the meaning of art. 13 para. (8), para. (9) and para. (11) let. c) of Law no. 105/2003, since essential information was omitted, necessary for the consumer to be able to assess the legality and appropriateness of the proposed contractual modification, being likely to determine the insured to accept a transactional decision – namely the payment of a premium

[3] Driving a vehicle without holding the compulsory motor third party liability insurance policy on paper or in electronic format or without the data accessed from the single information system related to compulsory motor third party liability insurance.

additional or acceptance of the contract modification – , which, with full knowledge of the facts, he would not have accepted.

In the case, in the Preliminary Request, in order to combat the findings concerning the misleading omission, the insurer indicates circumstances that refer to the contract termination process.

In context, it should be explained that the misleading omission consists in the fact that the insurer did not provide the essential information about the insurance premium, even in the presence of an express request from the insured.

Additionally, the insurer, in the Preliminary Request, presents arguments „regarding the alleged „misleading action””, invoking the illegality of the contested Decision.

On the subject, it should be noted that the CNPF, through the contested Decision, did not find the use by the insurer of misleading actions.

In this regard, the CNPF, pursuant to art. 15 para. (1) let. b) of Law no. 105/2003, which provides that „(1) Taking into account all interests involved and, in particular, the public interest, the competent courts or the consumer protection control body, according to their field of competence: b) order the prohibition or initiation of appropriate legal proceedings for the prohibition of unfair commercial practices, even if they have not yet been applied, but this is imminent, in accordance with the procedures and attributions established by the Contravention Code;”, ordered: „4. SA „ACORD GRUP” SA is prohibited from applying unfair commercial practices, as misleading omissions, by omitting essential information or providing it in an unclear, unintelligible, ambiguous manner and which, in any situation, determines or is likely to determine the consumer to take a transactional decision, which he would not have taken in another situation. 5. SA „ACORD GRUP” SA is prohibited from applying aggressive commercial practices, by limiting the consumer's freedom and behavior regarding the product, through unjustified and practical influence, which determines or is likely to determine the consumer to take a transactional decision, which he would not have taken otherwise.”.

5. Regarding the preliminary procedure, it should be noted that, according to the Disposition of the Vice-President of the CNPF no. 87 of 27.02.2026 regarding the suspension of the term of the preliminary procedure, initiated by the Preliminary Request, submitted by SA „ACORD GRUP” SA, regarding the annulment of the Decision of the National Commission of the Financial Market no. 3/3 of 20.01.2026 regarding the petitions registered with the National Commission of the Financial Market with no. 8299 and with no. 8567 on 14.11.2025 and, respectively, on 27.11.2025, in relation to SA „ACORD GRUP” SA, the general term of the preliminary procedure was suspended until 06.03.2026.

Also, the aforementioned Disposition was brought to the attention of the insurer through the CNPF letter no. 06-5/629 of 27.02.2026, sent to the email address office@acordgrup.md.

Additionally, through the same letter, in accordance with the provisions of art. 94 of the Administrative Code, SA „ACORD GRUP” SA was informed about the exercise of the right to be heard, in connection with the circumstances relevant to the act to be adopted, as well as about the fact that the hearing is to be done in writing, by submitting, to the CNPF address, the insurer's opinion, as a hearing, until 06.03.2026 inclusive.

Consequently, the insurer, by the letter registered with the CNPF under no. 1501 on 06.03.2026, declared that “The arguments invoked in the preliminary request no. 240/2026 of 17.02.2026, including the arguments regarding the erroneous interpretation of the applicable regulatory framework and the unfounded classification of the insurer's actions as ”unfair commercial practices” remain fully valid and have not been invalidated by new legal elements.”.

At the same time, the insurer brings to the attention of the supervisory authority “several circumstances that occurred after the filing of the preliminary request, which additionally confirm the correctness of the position set out by ACORD GRUP and directly affect the premise on which the contested Decision was based.”.

In this regard, SA “ACORD GRUP” SA indicated that the insured submitted “four requests by which they sought the termination of the RCAI insurance contracts concluded with them and which constituted the subject matter of the administrative file.”.

In this case, the CNPF states that the subject matter of the administrative procedure, initiated at the request of the insured's representative and of […] SRL, is constituted by the actions of SA “ACORD GRUP” SA, related to the Compulsory Motor Third Party Liability Insurance Contract for damage caused by RCAI vehicles […], concerning the vehicle TOYOTA PRIUS, with reg. no. […],

In this context, the insurance contracts invoked by the insurer did not represent the subject matter of the administrative procedure, and their termination does not represent indicia that would support its position in the Preliminary Request.

Therefore, the invocation of the termination of certain insurance contracts, which did not constitute the subject matter of the administrative procedure, is irrelevant.

At the same time, the insurer claims that ““SRL […], the company that effectively uses the respective vehicles in economic activity, sent to ACORD GRUP a letter of intent regarding the conclusion of RCAI insurance contracts corresponding to the use of the vehicles in taxi activity.”.

In this case, the respective letter denotes the firm intention to conclude Compulsory MTPL Insurance Contracts for the following vehicles: “1. Ford Fusion with reg. no. […]; 2. Ford Fusion with reg. no. […]; 3. Ford Fusion with reg. no. […]; Toyota Prius V with reg. no. […].”.

In the same sense, the invocation of the intention regarding the conclusion of motor third party liability insurance contracts, concerning vehicles other than the one that constituted the subject matter of the administrative procedure, is irrelevant.

Moreover, the intention of […] SRL to conclude insurance contracts reveals nothing other than the performance of an imperative legal obligation.

Therefore, the respective arguments do not constitute a valid criticism of the legality of the contested administrative act.

Based on the considerations set out above, pursuant to art. 18 para. (3), art. 20 para. (1), para. (6) and para. (7) and art. 22 para. (3) of Law no. 192/1998 on the National Commission of the Financial Market, Law no. 105/2003 on consumer protection, art. 17, art. 19, art. 162 para. (1) and para. (3) letter a), art. 164 para. (1) and para. (2) letter a), art. 166, art. 167 para. (1) and para. (3) and art. 169 para. (2) and para. (3) of the Administrative Code, pt. 16 and pt. 19 of the Regulation on the organization and functioning of the National Commission of the Financial Market (CNPF Decision no. 57/11/2022),

The National Commission of the Financial Market DECIDES:

1. The preliminary request no. 240/2026 of 17.02.2026, submitted by SA “ACORD GRUP” SA, regarding the annulment of the Decision of the National Commission of the Financial Market no. 3/3 of 20.01.2026 concerning the petitions registered with the National Commission of the Financial Market under no. 8299 and no. 8567 on 14.11.2025 and, respectively, on 27.11.2025, in relation to SA “ACORD GRUP” SA (registered with the CNPF under no. 1018 on 18.02.2026), is rejected.

2. This Decision may be challenged by an administrative contentious action, filed with the Chisinau Court, Rascani office (MD-2068, mun. Chisinau, str. Kiev 3), within 30 days from the date of its communication.

3. This Decision enters into force on the date of adoption, is communicated to the addressee in accordance with the legislation and is published on the official website of the CNPF (www.cnpf.md).

Dumitru BUDIANSCHI,
PRESIDENT