The CBI have published CP172 to seek input to their proposals on how the Industry Funding Levy is distributed across Firms. Responses to the specific questions raised in the consultation must be submitted by 8 January 2027.

In 2025 the CBI levied €226m on the financial services industry, representing some 87% of their financial regulation costs. Insurance Undertakings contributed €54.5m (24%) of the total levy with amounts payable by individual insurance firms based on their PRISM Impact categorisation.

The main change of approach proposed is in respect of those categories that currently use PRISM Impact-based scales, moving instead to an ad valorem approach. It is expected that this will result in a more proportionate allocation to firms, noting that under the current system an Impact category will comprise firms of potentially markedly different sizes which are nevertheless paying the same Levy amount. The CBI have also noted that “PRISM Impact is no longer the primary driver for the intensity of supervision”.

For (re)insurance undertakings the total amount to be collected will be allocated first among the four main categories of Life, Non-Life, Reinsurance and Others (incl Captives).

For life, non-life and reinsurance undertakings the Levy will comprise a minimum amount plus a variable amount with the latter based 50% on the firms’ GWP and 50% on technical provisions (TPs). For the purposes of the calculations, unit linked GWP and unit linked TPs will have a factor of 35% applied. This is to avoid the very large figures associated with unit linked business relative to non-linked business distorting the apportionment of levies between firms.

It will be a matter for individual firms to assess if relative size (in GWP and TPs terms) is a reasonable indicator for the level of supervision required, and for Unit Linked companies, if the 35% factor is reasonable to equate the relative risk of Unit Linked and Non-Linked insurance businesses.