Regulatory Alerts2020-05-05 | NBB_2020_01Added · Updated
Insurance - Update of the overarching circular on governance
The overarching circular on governance is updated to reconcile prudential requirements with the Companies and Associations Code, prohibit the combination of director and employee statuses within the same company, and introduce standard task distribution schemes for significant insurers. New outsourcing rules require compliance and internal audit monitoring of critical functions, while remuneration expectations for identified staff receiving variable pay exceeding 50,000 euros include a 1:1 fixed-to-variable ratio and a three-year deferral of 40% of variable remuneration. IT infrastructure guidelines now explicitly emphasize cybersecurity and cloud outsourcing compliance, and recommendations on sustainable finance require the integration of sustainability risks into training, risk management, and remuneration policies. These changes are effective immediately, except for the outsourcing and remuneration provisions which apply from 1 January 2021.