With the Insurance Recovery and Resolution Directive (IRRD), the EU is establishing a harmonized framework for crisis management and the orderly resolution of insurers for the first time. The directive aims to make risks visible at an early stage and to strengthen the stability of the European insurance market. For insurers, this marks a paradigm shift: away from isolated supervisory reviews towards continuous, data-driven and holistic monitoring of organizational resilience.

The New Framework: IRRD Reaches Deep into Processes and Structures

The IRRD introduces, for the first time, binding EU-wide requirements for preventive recovery plans and resolution procedures. This has tangible operational implications:
Insurers must define scenarios, develop response options, and set up their organizations so that relevant information is available and verifiable at any time.

For midsized companies in particular, the key challenge is how to interlink existing regulatory frameworks – such as Solvency II, DORA, or IFRS 17 – in a way that creates a consistent overall picture. Supervisors are not looking for purely documentation-based exercises but for robust, data-driven decision foundations that can be activated quickly in a crisis.

Time Pressure: Implementation by 2028

While the directive is already being transposed into national law, EIOPA is simultaneously working on a total of 19 technical standards (RTS/ITS). These will define how data must be provided, which reporting channels apply, and how content has to be structured.

As the standards will be published gradually until 2026, companies face a tight schedule: Those who wait for all requirements to be finalized risk falling behind significantly. The first reporting obligations starting in 2028 require insurers to begin gap analyses, prototyping and data quality initiatives already in 2025/2026.

Data Integration as the Core Challenge: IRRD Is a RegTech Project

In practice, the IRRD is above all a data project. The requirements demand:

• consistent and fully traceable datasets,
• clearly defined reporting processes,
• automated reporting workflows, and
• XBRL-based structures similar to Solvency II.

Much of the relevant information already exists in corporate data warehouses, but often not in a format suitable for recovery and resolution planning. In addition, insurers must integrate data from risk management (Solvency II), operational resilience (DORA) and crisis management (IRRD).

The logical conclusion: insurers benefit from RegTech solutions that consolidate Solvency II, DORA and IRRD processes on a single platform. Such solutions reduce complexity, prevent duplicate maintenance, and ensure that companies can react in seconds, not hours, under stress.

Implementation: Four Steps to IRRD Readiness

To implement the IRRD requirements efficiently and on time, a staged approach is recommended:

1. Technical and organisational gap analysis
   Which data already exists? Which needs to be remodelled? Where are automated workflows missing?
2. Leverage synergies with existing regulations
   Shared data models and unified governance structures significantly relieve specialist departments and IT.
3. Develop structured resolution reporting
   The annual resolution report is based on strictly defined XBRL quantitative reporting templates – a manual approach is not feasible.
4. Early development of preventive recovery plans
   These must be updated every two years from 2028 onwards and form the foundation of the later resolution framework.

Conclusion: Start Early to Stay Ahead

With the IRRD, supervisory focus is shifting: from occasional reviews to continuous, data-driven resilience assessment. Insurers that begin aligning their data architecture and operationalizing their recovery processes today not only gain time but also secure a strategic advantage. In 2028, it will not be the best plan that makes the difference, but the company able to make its risks and response options transparent at the push of a button. If you have any questions, please contact our team of experts via the web form.