Decision on the Results of the Thematic Control Conducted within Insurance Companies

REPUBLIC OF MOLDOVA
NATIONAL FINANCIAL MARKET COMMISSION
77 Stefan cel Mare si Sfant Blvd., Chisinau, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md

DECISION
18 May 2026 No. 24/2

On the results of the thematic control conducted within insurance companies

1. In accordance with the Control Activities Plan of the National Financial Market Commission for 2025 (annex to CNPF Decision No. 13/1/2025), during the period 16.12.2025 – 19.05.2026, a thematic control was carried out within SA “ACORD GRUP” SA, CA “ASTERRA GRUP” SA, CA “DONARIS VIENNA INSURANCE GROUP” SA, CA “GENERAL ASIGURARI” SA, IE CA “GRAWE CARAT ASIGURARI” SA, Company “INTACT ASIGURARI GENERALE” SA, “MOLDASIG” SA, SAR “MOLDCARGO” SA, and IE CIA “TRANSELIT” SA (insurers/participants), as mandated by Decision of the National Financial Market Commission (CNPF/authority) No. 60/3/2025 on conducting thematic control within insurance companies (Decision No. 60/3/2025).

2. The control focused on verifying the manner in which insurance companies processed damage files related to mandatory third-party liability auto insurance for damages caused by vehicles (internal RCA insurance) during the operational period 01.01.2025 – 30.09.2025, specifically regarding: compliance with the deadlines established in Art. 20 para. (1) lit. d) – f) and para. (2), Art. 22 para. (8), and Art. 29 para. (1) and para. (2) of Law No. 106/2022 on mandatory third-party liability auto insurance for damages caused by vehicles (Law No. 106/2022), in relation to all damage files, as well as fulfillment of legal obligations provided for in Art. 20 and Art. 26 of Law No. 106/2022, and compliance with Art. 13 of Law No. 105/2003 on consumer protection, in the case of damage files related to accidents resulting in bodily injury and/or death (thematic control).

3. According to Art. 70 para. (1) of the Administrative Code, CNPF Decision No. 60/3/2025 was sent to:
   3.1. SA “ACORD GRUP” SA via CNPF letter No. 04-5/4910 dated 18.12.2025;
   3.2. CA “ASTERRA GRUP” SA via CNPF letter No. 04-5/4911 dated 18.12.2025;
   3.3. CA “DONARIS VIENNA INSURANCE GROUP” SA via CNPF letter No. 04-5/4912 dated 18.12.2025;
   3.4. CA “GENERAL ASIGURARI” SA via CNPF letter No. 04-5/4913 dated 18.12.2025;
   3.5. IE CA “GRAWE CARAT ASIGURARI” SA via CNPF letter No. 04-5/4914 dated 18.12.2025;
   3.6. Company “INTACT ASIGURARI GENERALE” SA via CNPF letter No. 04-5/4915 dated 18.12.2025;
   3.7. “MOLDASIG” SA via CNPF letter No. 04-5/4916 dated 18.12.2025;
   3.8. SAR “MOLDCARGO” SA via CNPF letter No. 04-5/4917 dated 18.12.2025;
   3.9. IE CIA “TRANSELIT” SA via CNPF letter No. 04-5/4918 dated 18.12.2025.

Furthermore, in accordance with point 26 subpoint 4) of the Regulation on the Administrative Control Procedure (approved by CNPF Decision No. 60/10/2023), participants were informed of their rights and obligations under the Regulation.

4. The control was carried out by the control team at the CNPF headquarters. By letters sent on 22.12.2025, the control team requested insurers to present the following information:

• a copy of the report on internal third-party liability auto insurance for the period 01.01.2025 – 30.09.2025 (according to Annex No. 1 to CNPF Decision No. 57/14/2018 on approving specialized reports of insurers (reinsurers) related to mandatory internal and external third-party liability auto insurance) (CNPF Decision No. 57/14/2018); information contained in the Report on the main activity of the insurer, section “Third-party liability auto insurance, including internal RCA” for the period 01.01.2025 – 30.09.2025 (according to Annex No. 1 to CNPF Decision No. 26/15/2011 on approving the form and content of specialized reports of insurers (reinsurers) (CNPF Decision No. 26/15/2011));
• information about damage files related to mandatory internal RCA insurance, opened during the operational period 01.01.2025 – 30.09.2025 (according to the annex);
• copies of damage files (in full), related to accidents resulting in bodily injury and/or death, processed and paid during the operational period 01.01.2025 – 30.09.2025, with the deadline for submission being 26.01.2026.

Thus, on 23.01.2026, CA “DONARIS VIENNA INSURANCE GROUP” SA transmitted, in electronic format, a copy of the Report on internal third-party liability auto insurance for the period 01.01.2025–30.09.2025, prepared according to Annex No. 1 to CNPF Decision No. 57/14/2018, as well as information from the Report on the main activity of the insurer, section “Third-party liability auto insurance, including internal RCA”, for the same period, according to Annex No. 1 to CNPF Decision No. 26/15/2011. Additionally, information regarding damage files related to mandatory internal RCA insurance, opened during the operational period 01.01.2025 – 30.09.2025, as well as copies of damage files related to accidents resulting in bodily injury and/or death, processed and paid during the mentioned period, were presented.

Subsequently, on 26.01.2026, IE CA “GRAWE CARAT ASIGURARI” SA, SAR “MOLDCARGO” SA, and Company “INTACT ASIGURARI GENERALE” SA also transmitted the requested information in electronic format.

Concurrently, by letter No. 236 dated 26.01.2026, Company “INTACT ASIGURARI GENERALE” SA requested an extension of the deadline for completing and presenting information regarding damage files related to mandatory internal RCA insurance, until 28.02.2026.

Furthermore, within the established deadline for presenting information, by letters received during the period 20.01.2026 – 23.01.2026, some insurance companies also requested an extension of the deadline for presenting information, as follows: CA “GENERAL ASIGURARI” SA (via letter No. 112-2026 dated 20.01.2026), “MOLDASIG” SA (via letter No. 427 dated 21.01.2026), SA “ACORD GRUP” SA (via letter No. 111/2026 dated 22.01.2026), and CA “ASTERRA GRUP” SA (via letter No. 257-04/26 dated 23.01.2026), and IE CIA “TRANSELIT” SA (via letter No. 0110/2026 dated 22.01.2026).

We note that the requests for extension of the deadline were examined by the control team, and after analyzing the reasons invoked and taking into account the deadlines established in the Control Plan, it was decided to accept the extension of the deadline for presenting information until 02.02.2026, a fact communicated to the insurance companies via letters sent.

Therefore, CA “ASTERRA GRUP” SA, “MOLDASIG” SA, CA “GENERAL ASIGURARI” SA, IE CIA “TRANSELIT” SA, SA “ACORD GRUP” SA, and Company “INTACT ASIGURARI GENERALE” SA transmitted the requested information in electronic format, and additionally, CA “ASTERRA GRUP” SA and CA “GENERAL ASIGURARI” SA presented in physical format at the CNPF headquarters the damage files related to accidents resulting in bodily injury and/or death.

5. Thus, in order to substantiate the findings and evaluate in detail the manner of processing damage files, the control team proceeded to establish a sample of files. This was constituted by selecting one damage file opened/registered on the first working day of each month during the period subject to control, in order to ensure a uniform distribution over the entire analyzed period.

Subsequently, based on the preliminary analysis of the presented materials and available data, additional damage files were selected according to certain risk criteria, including: exceeding the deadline for processing and settling files, exceeding the deadline for paying insurance compensation, as well as other identified non-compliances.

The final sample included both randomly selected files and files selected based on risk indicators, for the purpose of evaluating the manner of compliance with legal provisions in the process of processing and resolving damage files.

The checks were carried out by comparing the information presented by insurers, documents related to damage files, internal registers, and data reported to CNPF, analyzing their concordance with the obligations provided for by the applicable regulatory framework.

6. Consequently, following the examination of the received materials, the control team requested additional information via letters sent on 27.02.2026 and 02.03.2026, in order to complete and clarify the data presented by insurers. In this regard, full copies of damage files according to the attached lists were requested, as well as explanations regarding discrepancies identified between data reflected in reported information and that presented, as appropriate.

Thus, the requested information was presented by the insurance companies as follows: CA “ASTERRA GRUP” SA – on 03.03.2026; “MOLDASIG” SA, IE CIA “TRANSELIT” SA, and IE CA “GRAWE CARAT ASIGURARI” SA – on 09.03.2026; Company “INTACT ASIGURARI GENERALE” SA – on 10.03.2026; SAR “MOLDCARGO” SA, CA “GENERAL ASIGURARI” SA, and SA “ACORD GRUP” SA – on 11.03.2026; and CA “DONARIS VIENNA INSURANCE GROUP” SA – on 16.03.2026.

It should be specified that the control team did not express an opinion on damage files that previously constituted the object of examination within CNPF under other administrative procedures; these are excluded from this analysis and are not included in the findings or recommendations issued within this control act, with the exception of aspects concerning the deadlines for processing files.

7. Subsequently, it should be noted that the violations found during the control carried out were recorded in the Provisional Act dated 30.03.2026 on the results of the thematic control regarding the verification of the manner of processing damage files related to mandatory internal RCA insurance by insurance companies, during the operational period 01.01.2025 – 30.09.2025, in part concerning: compliance with deadlines established in Art. 20 para. (1) lit. d) – f) and para. (2), Art. 22 para. (8), and Art. 29 para. (1) and para. (2) of Law No. 106/2022 on mandatory third-party liability auto insurance for damages caused by vehicles (Law No. 106/2022), in all damage files, and fulfillment of legal obligations provided for in Art. 20 and Art. 26 of Law No. 106/2022, and compliance with Art. 13 of Law No. 105/2003 on consumer protection, in the case of damage files related to accidents resulting in bodily injury and/or death (Provisional Control Act), which was sent via the insurers' electronic mail for information on 30.03.2026.

Furthermore, participants were granted a deadline until 10.04.2026 to submit objections and comments on the Provisional Control Act.

8. In this regard, objections and comments from insurers regarding the findings exposed in the Provisional Control Act were received, as follows:
   8.1. SA “ACORD GRUP” SA via letter dated 10.04.2026;
   8.2. CA “ASTERRA GRUP” SA via letter No. 01-04/26 dated 01.04.2026;
   8.3. CA “DONARIS VIENNA INSURANCE GROUP” SA via letter No. 852/2026 dated 07.04.2026;
   8.4. CA “GENERAL ASIGURARI” SA via letter No. 1041-2026 dated 07.04.2026;
   8.5. IE CA “GRAWE CARAT ASIGURARI” SA via letter No. 2409 dated 10.04.2026;
   8.6. Company “INTACT ASIGURARI GENERALE” SA via letter No. 919 dated 10.04.2026;
   8.7. “MOLDASIG” SA via letter No. 2184 dated 06.04.2026;
   8.8. SAR “MOLDCARGO” SA via letter No. 918 dated 10.04.2026;
   8.9. IE CIA “TRANSELIT” SA via letter No. 0674/2026 dated 10.04.2026.

9. Subsequently, explanations/submissions regarding the findings of the control team in the Provisional Control Act, along with comments from the control team, were reflected in the Divergence Table.

10. Following these, on 28.04.2026, the control team finalized the Act on the results of the thematic control regarding the verification of the manner of processing damage files related to mandatory internal RCA insurance by insurance companies, during the operational period 01.01.2025 – 30.09.2025, in part concerning: compliance with deadlines established in Art. 20 para. (1) lit. d) – f) and para. (2), Art. 22 para. (8), and Art. 29 para. (1) and para. (2) of Law No. 106/2022 on mandatory third-party liability auto insurance for damages caused by vehicles (Law No. 106/2022), in all damage files, and fulfillment of legal obligations provided for in Art. 20 and Art. 26 of Law No. 106/2022, and compliance with Art. 13 of Law No. 105/2003 on consumer protection, in the case of damage files related to accidents resulting in bodily injury and/or death (hereinafter – Control Act).

11. Thus, on 28.04.2026, the Control Act was sent to insurers, accompanied by the Divergence Table containing the synthesis of explanations/submissions presented.

12. Under Art. 94 of the Administrative Code and point 68 of Regulation No. 60/10/2023, in order to ensure compliance with the right to be heard regarding the facts and circumstances found during the thematic control, CNPF initiated the hearing procedure for 9 (nine) insurers, as follows:
    12.1. SA “ACORD GRUP” SA, via CNPF letter No. 04-5/1558 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 09:00.
    Subsequently, during the hearing, the director of SA “ACORD GRUP” SA supported the arguments invoked in the letter sent on 10.04.2026 and also mentioned that regarding the first points in the act of findings, the company will present, until 05.05.2026, at 16:00, an Excel file with additional calculations performed, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.2. CA “ASTERRA GRUP” SA, via CNPF letter No. 04-5/1559 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 09:45.
    Subsequently, during the hearing, representatives of CA “ASTERRA GRUP” SA, Head of Claims Service, and the lawyer supported the arguments invoked in letter No. 01-04/26 dated 01.04.2026 and also mentioned that they undertake to present additional information accompanied by explanations and calculations until 05.05.2026, at 16:00, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.3. CA “DONARIS VIENNA INSURANCE GROUP” SA, via CNPF letter No. 04-5/1560 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 10:30.
    Subsequently, during the hearing, the representative of CA “DONARIS VIENNA INSURANCE GROUP” SA supported the arguments invoked in letter No. 852/2026 dated 07.04.2026, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.4. CA “GENERAL ASIGURARI” SA, via CNPF letter No. 04-5/1561 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 11:15.
    Subsequently, during the hearing, the representative of CA “GENERAL ASIGURARI” SA, Head of Legal Department, supported the arguments invoked in letter No. 1041-2026 dated 07.04.2026, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.5. IE CA “GRAWE CARAT ASIGURARI” SA, via CNPF letter No. 04-5/1565 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 13:00.
    Subsequently, during the hearing, representatives of IE CA “GRAWE CARAT ASIGURARI” SA, Head of Claims Service, and the jurist supported the arguments invoked in letter No. 2409 dated 10.04.2026 and also mentioned that they will return with additional information, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.6. Company “INTACT ASIGURARI GENERALE” SA, via CNPF letter No. 04-5/1562 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 13:45.
    Subsequently, during the hearing, representatives of Company “INTACT ASIGURARI GENERALE” SA, Head of Claims Settlement Section, and the jurist supported the arguments invoked in letter No. 919 dated 10.04.2026 and also mentioned that until 05.05.2026, at 16:00, they will return with additional information, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.7. “MOLDASIG” SA, via CNPF letter No. 04-5/1557 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 14:30.
    Subsequently, during the hearing, the representative of “MOLDASIG” SA, Head of Claims Settlement Section, supported the arguments invoked in letter No. 2184 dated 06.04.2026 and also mentioned that until 06.05.2026, at 16:00, they will return with additional information, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.8. SAR “MOLDCARGO” SA, via CNPF letter No. 04-5/1564 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 15:15.
    Subsequently, during the hearing, representatives of SAR “MOLDCARGO” SA, Director, and Head of Claims Service, supported the arguments invoked in letter No. 918 dated 10.04.2026, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.
    12.9. IE CIA “TRANSELIT” SA, via CNPF letter No. 04-5/1563 dated 29.04.2026, was informed of the right to be heard on 04.05.2026, at 16:00.
    Subsequently, during the hearing, representatives of IE CIA “TRANSELIT” SA, Deputy Director, and the jurist, supported the arguments exposed in letter No. 0674/2026 dated 10.04.2026, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 04.05.2026.

13. Following the hearings on 04.05.2026, representatives of some insurers declared that they would present additional explanations related to the Divergence Table and the Control Act, regarding the findings formulated by the control team.

14. Therefore, SA “ACORD GRUP” SA via letter dated 05.05.2026, presented additional explanations regarding the findings in the Control Act, concerning points 2.1.1, 2.1.2, and 2.1.4.

15. Subsequently, via email dated 06.05.2026 to the control team, CA “ASTERRA GRUP” SA notified about the submission of additional explanations related to 526 files paid beyond the legal deadline of 90 days, by completing the Excel file previously presented by the insurer, following the first request of the control team.

16. By letter dated 05.05.2026, IE CA “GRAWE CARAT ASIGURARI” SA communicated additional information regarding damage files that were subject to control during the period 01.01.2025 – 30.09.2025, in relation to which technical errors were committed, and regarding damage files where information about the decision on the settlement of the compensation request is missing.

Furthermore, the insurer attached a list of damage files with explanations.

17. Company “INTACT ASIGURARI GENERALE” SA via letter No. 1114 dated 05.05.2026, presented additional explanations to points 2.6.2, 2.6.3, and 2.6.5 of the Control Act.

18. “MOLDASIG” SA via letter No. 2822 dated 06.05.2026, attached additional explanations to points 2.7.1, 2.7.2, and 2.7.5 of the Control Act, with attached confirming documents in this regard.

19. Thus, it is noted that relevant information and explanations were presented after the hearings and examination of the control team's findings.

20. In order to ensure the faithful, complete, and objective reflection of the situation found, it is necessary to revise and present the Final Control Act in a new edition. The necessity of presenting the Control Act in a new edition is determined by the fact that the information received subsequently modifies the factual basis on which the initial statistical findings were founded. The updated data influences the content of the tables included in the Control Act, and modifying them inevitably generates recalculation of indicators, reevaluation of synthesized data, and adjustment of conclusions formulated subsequently within the document.

Under these conditions, it is not possible to simply substitute specific text fragments or introduce separate additions, as the act represents a unified document, built on the direct correlation between tabular data, calculations performed, and conclusions resulting from them. Any modification of the values included in the tables subsequently affects the entire logical and analytical chain of the act, including interpretations and final conclusions based on such calculations.

21. Given the above, simulations and recalculations of the findings reflected in the Control Act were carried out repeatedly. It is essential to emphasize that the information and explanations presented additionally do not invalidate or completely remove the findings of the control team, but only determine a partial adjustment of them, exclusively in terms of quantity – the number of files regarding which the existence of the found violations can be retained.

22. Therefore, the nature and essence of the identified deviations are maintained, and the modifications made have a limited impact, without affecting the foundation of the findings retained in the Control Act.

23. Thus, as a result of the control, the following were found:

23.1. SA “ACORD GRUP” SA
According to the statistical data presented, during the period subject to control, SA “ACORD GRUP” SA concluded 31,165 internal RCA insurance contracts, generating gross premiums written in a total value of over 80.5 million lei, which constitutes approximately 30.8% of the insurer's portfolio. Additionally, insurance compensation paid during that period related to internal RCA amounted to 32,259,308 lei, representing approximately 44.1% of the total damages paid by the insurer.

Based on the information presented by the insurer, for the purpose of verifying compliance with the deadlines established in Art. 20 para. (1) lit. d) – f) and para. (2), Art. 22 para. (8), and Art. 29 para. (1) and para. (2) of Law No. 106/2022, information related to 1,600 damage files was subjected to analysis.

In this context, the insurer presented the requested information in the form of a table (Excel file), which included damage files and their processing deadlines for all damage files related to mandatory RCA insurance during the period 01.01.2025 – 30.09.2025.

To countercheck the presented data, the control team requested and analyzed copies of 22 damage files related to damages caused to health and 18 damage files related to damages caused to property.

Thus, based on the information reflected in the table (Excel file) and the damage files presented by the insurer, and the typology of deviations...