17 June 2025
The Global Federation of Insurance Associations (GFIA) welcomes the opportunity to comment on the IAIS draft Issues Paper on structural shifts in the life insurance sector. GFIA appreciates IAIS’s ongoing engagement with industry on evolving investment and reinsurance trends.
GFIA acknowledges the increasing use of alternative assets and asset-intensive reinsurance (AIR) as insurers adapt to long-term economic, demographic, and market changes. These trends support better risk management and enhance capacity to meet retirement and long-term savings needs. GFIA urges supervisory responses to remain proportionate, risk-based, and mindful of jurisdictional differences.
On alternative assets, GFIA cautions against broad classifications, noting limited aggregate exposure and established risk controls. For AIR, GFIA highlights its role in managing long-duration liabilities and access to capital, recommending IAIS avoid overly prescriptive guidance that could hinder innovation.
GFIA also calls for clearer language on the use of internal models in capital requirements, emphasising their role in accurately reflecting risk profiles rather than regulatory discretion. The Federation stresses that insurers maintain a focus on high-quality investments, with alternative assets used for prudent diversification.
Overall, GFIA supports IAIS’s view that current trends pose no material financial stability risks and encourages continued industry dialogue and evidence-based supervisory approaches.
