In response to the current situation in Ukraine, the Commissariat aux Assurances (the “CAA”) issued Information Note 22/5 (the “Note”) stating that it expects all entities under its supervision to enhance their vigilance towards the conflict and to assess its potential impacts in the short and medium term.
The Note includes a list of the measures that such enhanced vigilance and impact assessments must constitute at minimum. The scope of the measures that the CAA expects supervised entities to take varies depending on the nature of the entity, with more extensive measures expected from insurance and reinsurance undertakings.
Supervised entities must make the results of the implemented measures available to the CAA and discuss with it any material risks they may identify.
Where the implemented measures call for a revised ORSA, that ORSA must be communicated to the CAA.
