Welcome to the FIG Top 5 at 5

On 25 March 2026, the Financial Services and Pensions Ombudsman (“FSPO”) published its Overview of Complaints for 2025 (“Overview”). The Overview  provides a summary of the complaints made to the FSPO and reports the trends and patterns in complaints made.

7,004 complaints were received in 2025, with 19% of complaints relating to customer service, which was the conduct most complained of. Customer service complaints relate to complaints which include issues such as communications, complaint handling, account access issues and the failure to provide information.  The conduct most complained of in 2024 was also customer service.

The FSPO resolved its highest number of complaints ever in 2025, with 6,282 complaints closed, representing an increase of 6%, when compared to 2024.

Some of the main statistics set out in the Overview are as follows:

Insurance

2,142 complaints in relation to insurance products were received in 2025, representing an 18% increase on 2024 and the second largest category of complaints received. The Ombudsman notes that “This growth in insurance complaints is a continuation of a trend that has been ongoing for a number of years, with the annual number of insurance complaints that my Office receives increasing from 1,129 in 2022 to 2,142 in 2025, almost doubling in just three years.” In his message at the start of the Overview, it is highlighted by the Ombudsman that this trend should be of concern to the insurance industry and he confirms that he will be engaging with the sector on this point.

Insurance related complaints accounted for 31% of all complaints received in 2025. Complaints regarding motor insurance represented 45% of insurance complaints received, followed by private health insurance (325 complaints) and travel insurance (241 complaints).

In excess of a quarter of insurance complaints concerned claim handling (553), followed by complaints about rejection of a claim (481).

Customer Service (243) and maladministration (239) and refusal to give a product / service (200) also featured in the top five conducts complained about in 2025, as was also the case in 2024.

Banking

3,802 banking complaints were received, representing 54% of all complaints received, with the number of banking complaints having increased by 12% since 2024.

Most banking complaints related to bank accounts (1,964), followed by mortgages (746) and then consumer credit (556). These three araes were also the three areas most complained of in 2024.

Disputed transactions was the conduct most complained of in the banking sector, representing 34% of complaints. Complaints concerning customer service and maladministration were the second and third most common conduct complained of in the banking sector.

Investment Complaints

The FSPO received 525 investment related complaints in 2025, a 28% increase since 2024. Investment complaints accounted for 7% of all complaints received in 2025, as they did in 2024.

The conduct most complained of in the investment sector were maladministration (182 complaints), customer service (83 complaints), followed by improper management of funds (83), and incorrect advice (41).

Pensions

The pension sector is the only sector where there was a reduction in the number of complaints received in 2025, with 276 pension scheme complaints received in 2025, compared to 348 in 2024. 86% of complaints related to occupational pension schemes.

The conduct most complained of in relation to pensions were maladministration (133) , calculation of pension benefit (56), followed by failure to provide information / correct information (21), customer service (21) and the provision of incorrect or unsuitable advice (12).

Outcomes

In 2025, 6,282 complaints were closed, and the outcomes of these complaints included the following:

• 1,521 complainants were settled through mediation, with the value of those settlements totalling €4,568,025;

 

• a further €511,140 was paid to complainants by providers to settle complaints during the FSPO’s formal investigation process, without the need for a legally binding decision; and
• the combined value of compensation directed in legally binding decisions, following the formal investigation process, was €165,950.

Disputed Transactions

The Overview highlights that the FSPO continues to receive increasing numbers of complaints regarding disputed transactions. Such complaints accounted for 34% of all banking complaints received. It is noted that this reflects a continuing increase in fraud. There were also disputed tractions complaints in the investment category. Highlighting that the FSPO cannot investigate instances of fraud, the Overview does emphasise that the FSPO can investigate a complaint which relates to service failings of the provider in dealing with a customer who suspects fraud on their account, and any complaint about unauthorised transactions.

In the interests of raising awareness as to the kinds of fraud that customers have been exposed to, the Overview contains a number of case studies.

1. Governor Makhlouf delivers speech at Eurofi on mobilising Europe’s savings

On 27 March 2026, Governor Gabriel Makhlouf of the Central Bank of Ireland (“Central Bank”), delivered a speech (“Speech”), focused on strengthening Europe’s single market in order to mobilise Europe’s savings in the context of an increasingly fragmented global market, at the Eurofi high level seminar.

The Governor stated that mobilising Europe’s savings needs a productive and innovative economy that operates as a genuine single market, which will create prosperity that will generate capital, in turn, supporting the longer-term wellbeing of European citizens.

He addressed the need to bring European economies closer together so that they, and their financial systems, are better connected to European citizens. He highlighted the fact that, in Europe,  households and institutions collectively hold substantial savings, having increased particularly during the pandemic, but that investment has not kept pace with this increase. In that regard, the Governor stated that “channelling a proportion of that stock and flow of savings into investment would go some way to helping the EU meet its investment needs, estimated at an additional €750-800 billion annually by 2030.”

Acknowledging that we now find ourselves in a more fragmented world, he highlighted that we are moving toward a world where European economic strength is more important than ever.

The Governor noted that a significant proportion of Europe’s savings are invested outside the EU, and in analysing why this might be the case, some of the matters he addressed are as follows:

• investors, whether households or institutions, expect higher risk-adjusted returns elsewhere. The Governor highlighted that if European growth remains relatively weak, it limits the effectiveness of any financial or regulatory reforms aimed at deepening and integrating European capital markets; and
• productivity and growth need a stable macroeconomic framework.

Barriers

The Governor stated that the single market is Europe’s most powerful, but underutilised, asset. He acknowledged that there are still significant barriers, particularly in services.  He also highlighted the following:

• European capital markets are less deep and less liquid than their counterparts elsewhere. As part of addressing this issue, he called for the development of a European safe asset which would serve to anchor institutional capital;
• there is a need for stronger retail participation in capital markets through pension reform;
• continued efforts need to be made to reduce fragmentation within markets, highlighting that the savings and investment union (“SIU”) has the potential to improve market functioning, simplify the regulatory framework, and support innovation; and
• improving convergence in supervision matters but it is not the defining feature of a successful capital market.

Role of central banks and regulators

The Governor considered the way in which central banks and regulators fit into the picture, highlighting various matters, some of which are as follows:

• central banks are responsible for anchoring the conditions that make growth and investment possible;
• central banks have a responsibility when it comes to financial stability, with such stability being a precondition for effective capital allocation. Financial stability protects consumers, supports confidence, reduces risk, and enables investment;
• the Governor highlighted the recent publication of the Central Bank’s Regulatory and Supervisory Outlook report (“RSO”), where the importance of resilience across institutions, markets and the system as a whole, was emphasised. Additionally, he pointed to the fact that the RSO highlights the need to protect consumers and investors and recognises the growing importance of innovation and technological change. For more information on the RSO, see FIG Top 5 at 5 dated 5 March 2026; and
• the Central Bank is focused on ensuring that its regulatory framework is efficient and effective and, in that regard, highlighted the publication of the Central Bank’s roadmap on supervision – for more information, see FIG Top 5 at 5 dated 11 December 2025.

Conclusion

In concluding his remarks, Governor Makhlouf highlighted that we need to:

• strengthen our growth prospects;
• complete and deepen our single market;
• build more effective and integrated capital markets; and
• maintain the macroeconomic and institutional stability that is Europe’s hallmark.

2. Governor Makhlouf at the Central Bank delivers speech at savings and investment forum

On 31 March 2026, Governor of the Central Bank of Ireland (“Central Bank”), Gabriel Makhlouf, delivered a speech (“Speech”) at the inaugural meeting of the savings and investment forum at the Central Bank.

The Governor referred to his speech that he delivered at the Eurofi seminar, discussed above, and went on to specifically consider Ireland’s position as regards unlocking retail participation in capital markets.

He noted that  Irish retail participation in financial markets is very limited, even compared to our European peers and referenced the Central Bank’s published research on retail investor participation – for more information, see FIG Top 5 at 5 dated 4 December 2025.

In that regard, Governor Makhlouf went on to address the barriers that persist, citing:

• deep-rooted psychological and emotional barriers;
• knowledge and understanding gaps, including a perception that investment is complex, the preserve of the wealthy; and
• a sense that the investment ecosystem does not serve the full spectrum of potential retail investors.

The Governor pointed to three “important ingredients” that would enhance retail investor participation, as follows:

• the availability of suitable products;
• that retail investors have the financial education, autonomy and advice to invest; and
• that retail investors are protected when they do invest, with strong consumer protection frameworks and firms securing their interests.

Governor Makhlouf praised the efforts of policymakers and regulators, in Ireland and in the rest of Europe, to progress and reinforce the three “ingredients” and reiterated the Central Bank’s support for efforts aimed at reducing barriers to retail investment. He stated that, in his view, such efforts need to be accompanied by continued efforts to improve financial literacy and investment knowledge. In that regard, the Governor referred to the Government’s financial literacy strategy and its commitment to building the financial capability of Irish citizens – for more information on the financial literacy strategy, see FIG Top 5 at 5 dated 27 February 2025.

The Governor concluded his remarks by stating that the Central Bank will play its role in supporting the savings and investment union agenda through:

• ensuring a regulatory framework that supports retail investment;
• robust consumer protections; and
• the restoration and sustaining of trust and confidence in capital markets.

On 27 March 2026, the European Supervisory Authorities (“ESAs”) published its Spring 2026 joint committee update (“Update”) on risks and vulnerabilities in the EU financial system. The Update focuses on the challenges stemming from ongoing geopolitical tensions and developments in private finance.

The Update highlights that geopolitical events continue to shape the financial market context, with the war in the Middle East posing significant risks to the global financial landscape via higher energy prices, potential inflationary pressures and weaker economic growth.

Insurance and IORPs

Insurance and the Institutions for Occupational Retirement Provision (“IORPs”) sectors continue to demonstrate resilience, in spite of macroeconomic uncertainty, with robust capital and funding positions. The Update also highlights that investment risk is gradually increasing despite stable asset allocation. Looking ahead, the Update, states that the related adjustments  set to be introduced by the 2027 Solvency II review and the current IORP II proposal could trigger reallocation of investments, which may influence insurers’ and IORPs risk profiles.

Banking

The Update highlights that bank profitability remains high and that capitalisation is sound in the context of increased geopolitical uncertainty. Additionally, liquidity positions and asset quality are solid.

Policy recommendations

In terms of policy recommendations, the Update advises that relevant authorities and financial institutions should be ready to respond to geopolitical challenges. Some of the recommendations are as follows:

• prepare and plan thoroughly for risks using appropriate tools – including carrying out scenario analysis of the potential impacts on exposures, capital, liquidity, funding, business models and operational resilience / prepare for market volatility, liquidity risk, including risks of increasing credit spreads in both sovereign and corporate debt markets / be ready to react to risks, including plans to address challenges with specific regard to cyber threats, quantum computing and risks from rapid integration of AI models in financial markets;
• cautious management of sovereign exposures – given that sovereign spending is rising in the context of geopolitical challenges and other spending needs; and

• consider geopolitical risks in risk management – financial institutions should consider geopolitical risks in their risk management and formalise governance, enhance due diligence, and embed it in scenario planning. Risk management frameworks should include qualitative assessments. Operational and organisational planning should include worst-case scenarios as regards geopolitical developments with such scenarios including possible telecommunications and communication infrastructure failures or energy supply outages.

NBFI

The increasing role of private finance in the non-bank financial institutions (“NBFI”) sector, both at an EU and global level, is a matter highlighted by the Update, pointing to emerging risks in this area, driven by limited data, low transparency, prolonged growth and complex, opaque interconnections with the broader financial system.

The Update advises that financial institutions, authorities and investors should monitor and manage risks associated with private markets, highlighting the following:

• given the lack of transparency in private markets, investors should exercise due diligence in monitoring performance and quality of investments, with risks associated with unclear, untimely valuations;
• with growing exposures to private finance and the unregulated part of the non-bank intermediaries, particularly to third countries, banks and supervisors need to ensure proper understanding, monitoring and risk management frameworks for such exposures. This includes proper monitoring of concentration risks of these exposures; and
• insurance supervisors should monitor the shift in risk taking in view of the upcoming Solvency II 2027 changes, with the review potentially triggering a reallocation of investments which may influence insurers’ risk profiles.

 

1. EIOPA publishes final report on revised ITS and guidelines on supervisory reporting and public disclosure under Solvency II

On 30 March 2026, the European Insurance and Occupational Pensions Authority (“EIOPA”) published a final report (“Report”) on amendments to implementing technical standards (“ITS”) and guidelines on supervisory reporting and public disclosure requirements under Solvency II, as follows:

• amendments to Implementing Regulation (EU) 2023/894 on supervisory reporting;
• amendments to Implementing Regulation (EU) 2023/895 on public disclosure;
• revised guidelines on reporting for financial stability purposes; and
• revised guidelines on the supervision of branches of third-country insurance undertakings.

EIOPA consulted on the proposed amendments to the two sets of ITS and guidelines in July 2025 – for more information, see FIG Top 5 at 5 dated 17 July 2025.

The proposed amendments include changes that were required as a result of the Solvency II review. Additionally, the amendments are in line with the European Commission’s (“Commission”) simplification agenda.

The text of both sets of ITS are contained in annex V to the Report while the guidelines on reporting for financial stability purposes are set out in annex VI and the guidelines on the supervision of branches of third-country insurance undertakings are contained in annex VI. A further annex contains the reporting and disclosure package.

Clarification of timing of entry into application

In the Report, EIOPA clarifies the timing of the entry into application of the new reporting requirements stemming from the Solvency II review, as follows:

• the new supervisory reporting requirements under Solvency II will apply from the same day as the other provisions introduced by the Solvency II review – 30 January 2027. Accordingly, EIOPA states that Q4 2026 and 2026 financial reporting should be based on the current legal framework. As of Q1 2027, reporting will be based on the amendments; and
• the 2026 Solvency and Financial Condition Report (“SFCR”), disclosed in 2027, should be based on the current legal framework, while the 2027 SFCR, disclosed in 2028, should reflect the new provisions.

EIOPA has also highlighted that it has included a transitional provision in the ITS on supervisory reporting whereby undertakings are exempted from reporting, with the annual 2026 submission, those quantitative reporting templates that are expected to be deleted as of 30 January 2027.

Next Steps

The draft amendments to the ITS on supervisory reporting and the ITS on public disclosure will be submitted to the Commission, who will decide whether to endorse them.

The draft revised guidelines on reporting for financial stability purposes and the draft revised guidelines on the supervision of branches of third country insurance undertakings will be applicable from 30 January 2027.

2. EIOPA publishes third report on application of IDD

On 30 March 2026, the  European Insurance and Occupational Pensions Authority (“EIOPA”) published its third report (“Report”) on the application of the Insurance Distribution Directive (“IDD”).

The Report builds on the experience gained by insurance distributors, and the supervisory experience of national competent authorities (“NCAs”), across the seven years since the IDD has been applicable. The Report covers the period 2024 to 2025 and draws on two surveys carried out with NCAs and feedback received from a public event held in April 2025 and EIOPA’s insurance and reinsurance stakeholder group.

The Report highlights that EIOPA has enhanced the data quality and comparability of the data in the Report to address issues that were identified in its previous two reports.

The Report presents its findings under three categories:

Changes in the structure of the EU insurance distribution market

In the category, some of the matters addressed / highlighted by the Report include:

• the total number of registered insurance intermediaries has decreased by 7.5% since 2020, due to consolidation, stricter professional requirements and the difficulty of attracting new talent to replace those reaching retirement age;
• the number of intermediaries with a passport increased by 12% between 2020 and 2024 indicating more interest in carrying out cross-border distribution activities, although the actual extent of cross-border business remains uncertain; and
• typically, a European intermediary is a natural person acting on behalf of one or more insurance undertakings engaged in selling only insurance and is remunerated by way of commissions.

Impact of the regulatory framework

In the category, some of the matters addressed / highlighted by the Report are as follows:

• some NCAs have seen an improvement in the level of professionalism and competence of distributors in some member states, evidenced by a decrease in complaints, fines and breaches. However, other NCAs have observed some shortcomings, for example, distributors completing training activities that do not count towards the required continuous professional development;
• as regards digitalisation and the use of AI, the Report notes that this is progressing slowly, with online sales still below 10% of total premiums in most markets and concentrated in products such as motor or travel insurance. Generative AI is increasingly being used in insurance distribution through chatbots and sales tools. It is also emphasised that since the IDD does not comprehensively regulate digital channels or provide detailed guidance on AI-based advice models, there is scope for the regulatory treatment of these emerging technologies to be clarified;
• the quality of advice and selling methods have improved in some markets due to supervisory actions and follow-up inspections but persistent shortcomings remain in others, such as very long claims processing times. The Report notes that reported weaknesses are consistent with EIOPA’s recent mystery shopping exercise; and
• sustainability disclosures and preference assessments are often poorly understood, inconsistently applied and affected by distributor knowledge gaps and misalignment between regulatory frameworks, raising concerns around the proportionality and effectiveness of the current requirements in delivering better consumer outcomes.

Impact on the supervisory framework

In the category, some of the matters addressed / highlighted by the Report are as follows:

• regarding conflicts of interest and remuneration, misaligned incentives and insufficient transparency remain threats to consumer protection in some markets, particularly in relation to the distribution of life insurance or credit protection insurance. In response to a survey conducted by EIOPA for the Report, some NCAs indicated that they are considering national-level measures to further restrict the payment / receipt of commissions, including by introducing a ban on commissions or implementing enhanced disclosure rules;
• NCAs and trade associations continue to face challenges as regards the consistent application of the product oversight and governance rules, particularly in defining value for money, sustainability criteria and target markets, highlighting the need for clearer and more proportionate guidance across member states; and
• most NCAs reported effective cooperation and timely information exchange between home and host authorities, but some challenges remain, particularly limited data on cross-border intermediaries, unclear division of supervisory responsibilities and growing concerns over insurers outsourcing key activities to intermediaries.

Conclusion

The Report concludes that the IDD continues to provide a framework that sets minimum standards for fair and transparent insurance distribution across the EU. However, there are some ongoing challenges that need continued attention, notably in areas such as digitalisation, sales process and sustainability integration.

EIOPA has stated that it will build on the findings of the Report to promote supervisory convergence and support the implementation of the European Commission’s retail investment strategy and eventual review of the IDD.

1. EBA publishes final report on RTS on material model changes and extensions to IRB approach under CRR

On 30 March 2026, the European Banking Authority (“EBA”) published a final report (“Report”) on draft regulatory technical standards (“RTS”) for assessing the materiality of extensions and changes of the internal ratings based (“IRB”) approach under Regulation (EU) No 575/2013 (“CRR”).

Article 143(1) of the CRR stipulates that institutions must seek prior approval from competent authorities to calculate their risk-weighted exposure amounts for credit risk using the IRB approach. Additionally, institutions must apply for permission from their competent authorities before implementing material extensions and changes to their internal approaches.

Commission delegated regulation (EU) 529/2014 contains RTS on lists of qualitative criteria for the classification of extensions and changes to the internal approaches, as well as quantitative thresholds. The EBA was mandated to revise the RTS under article 143(5) of the CRR.

The EBA consulted on the draft RTS in December 2024 – for more information, see FIG Top 5 at 5 dated 12 December 2024.

The EBA has stated that the amendments to the RTS:

• address the high volume of material model change applications, which have put pressure on supervisory resources and has led to delays as regards approval timelines – hampering effective model use. Accordingly, the EBA points out that it has opted  for a pragmatic recalibration of the materiality criteria, with a view to reducing the overall number of changes subject to prior approval; and
• align the RTS with changes introduced under the CRR 3 – references that are no longer part of the prudential framework have been removed, for example, the IRB approach for equity exposures and the advanced measurement approach.

Next Steps

The draft RTS have bene submitted to the European Commission for endorsement.

ECB work simplifying approval processes for material model changes

The EBA explains that the revised RTS run in parallel with the work carried out by the European Central Bank (“ECB”) to simplify its approval processes for material model changes. In a press release dated 30 March 2026, the ECB set out that it is streamlining how it assesses changes to banks’ internal models for credit risk.

The ECB explains that it is moving from an ex ante to an ex post assessment which will make the approval process faster and more predictable for banks. This change will allow banks to  implement model changes quickly, without having to maintain old and new models in parallel while awaiting supervisory review.

The EBA explains that its work, together with that of the ECB, will “support more efficient supervisory procedures at the ECB and national competent authorities within the EU, leading to quicker and smoother IRB model approvals for EU banks.”

 2. ECB publishes Eurosystem’s comprehensive payments strategy

On 31 March 2026, the European Central Bank (“ECB”) published the Eurosystem payments strategy (“Strategy”).

The Strategy sets out how developments in recent years, in particular the ever-faster adoption of new technologies, such as DLT and tokenisation, have prompted the Eurosystem to review and expand the scope of its payment policies and strategies and to set out a new, holistic vision for the European payments market. The Strategy highlights that it focuses on digital payments and does not cover cash aspects.

The approach set out in the Strategy is a two-pronged one, as follows:

• improving the existing payment infrastructures; and
• catalysing and supporting new ones.

Strategic aims

This approach is based on four strategic aims:

• ensuring the effectiveness of monetary policy, financial stability and the smooth functioning of payment systems by maintaining the role of central bank money as the anchor of a two-tier monetary system;
• achieving strategic autonomy and increased resilience for European payments;
• fostering an integrated, competitive and innovative payments ecosystem; and
• supporting the international role of the euro.

Some of the areas of work, contained in the Strategy, under these strategic aims are as follows:

• developing a European market for tokenised settlement assets – the Strategy emphasises that the innovative potential of tokenisation should be leveraged, with central bank money maintained as the anchor for settlement, complemented by private settlement assets, including, tokenised deposits and stablecoins that are EU-governed, euro-denominated and properly designed and regulated;
• improving the existing infrastructure and investing in DLT-based solutions for wholesale payments – the Eurosystem will continue to support and invest in its real-time gross settlement system T2, including by exploring the extension of its operating hours. It will also develop central bank money for the settlement of DLT-based wholesale payments and securities transactions;

• enhancing standardisation, automation and process integration in corporate payments – the Eurosystem will facilitate more proactive engagement between the supply side and the corporate sector to create more efficient and innovative solutions for European businesses;

• achieving resilient, integrated, innovative and competitive euro retail payments through the digital euro and market-led solutions – the Strategy highlights that preserving the role of central bank money is equally important in retail markets, explaining that it is adapting central bank money to the digital age via the digital euro project. The development of pan-European private retail payment solutions remains complementary to the digital euro project; and

• advancing the G20 roadmap to enhance cross-border payments – the Strategy explains that the Eurosystem will continue to work on advancing the G20 roadmap for faster, cheaper, more transparent and more inclusive cross-border payments.

Next Steps

The Eurosystem will monitor relevant developments and adapt the Strategy as necessary. Finally, the Strategy highlights that it will be “key in shaping the European payments landscape of tomorrow, supporting competitiveness, innovation and resilience, and delivering tangible benefits for European citizens, businesses and markets.”