Strategic Digest of the Insurance Market

NAIU provided an exclusive planning model and a roadmap for changes

The National Association of Insurers of Ukraine has presented the “Strategic Digest of the Insurance Market” — an expert document forming the vision of the industry’s development for the next three years. Association members have already received access to applied tools, such as interactive mathematical models for their own budgeting and recommendations for adapting to regulatory requirements.

In conditions of global uncertainty, business needs solid points of support. Understanding this, the Strategic Analysis and Planning Committee (SAP) and the NAIU office conducted thorough work, analyzing macroeconomic factors, European integration directives, and the regulator’s plans. The result is a document structuring the future in two dimensions: financial (“Numbers” of the future) and regulatory (“Letters” of the future).

It should be noted that NAIU systematically engages in market development forecasting; however, this document is precedent-setting for two reasons, as for the first time the planning horizon has been extended to three years and an expert forecast of the regulatory field has been formed. This is critically important for the industry, as the activity of insurers by its nature and regulatory requirements (particularly within Solvency II) requires a strategic vision specifically for the medium-term perspective — at least for 3 years. The NAIU Digest gives companies the necessary base to fulfill this task, structuring the future in both dimensions: financial and regulatory.

NAIU ‘s Analytical Conclusion Confirms the Course for European Quality and Transparency

The presented digest confirms the irreversibility of the industry’s European integration vector. The period of 2026–2028 will be a time of final transformation of the Ukrainian market from a local environment into a full-fledged, organic component of the single European financial space. The key conclusion of NAIU analysts is that the success of companies will be determined by compliance with high international reliability standards. Implementation of Solvency II directives, digital resilience requirements (DORA), and transparent reporting (iXBRL) is the foundation for building unprecedented trust from consumers and international partners. Those market participants who, particularly using NAIU ‘s expertise and tools, start the systemic harmonization of their processes right now will become indisputable leaders of this new, European era of Ukrainian insurance.

“Numbers” of the Future from NAIU. From Macro-Forecast to Own Business Plan

NAIU moved away from the “dry statistics” format. Association members received a working calculation model that allows adapting general market trends to the specifics of a separate company by changing influence factors. The forecast is based on two scenarios: Base (continuation of the war with current intensity) and Favorable (end of combat operations in 2026 and start of reconstruction). The market structure will remain “motor-dominated”, and MTPL will occupy more than 30%, and together with CASCO and medical insurance (VHI) — about 60% of the portfolio. The market growth dynamics are forecast as follows:

• The market will grow by 14% (base scenario, driver — inflation) or by 20% (favorable, driver — investments and economic recovery).
• Growth of 14% or a leap of 26% is expected. In the favorable scenario, a key role is played by the revival of lending, an increase in the number of new cars, and the first large-scale investments in reconstruction.
• An increase of 13% or a record 32% is forecast (subject to the full restoration of air connections and large-scale reconstruction of the country).

“Letters” of the Future. 16 Areas That Will Change the Rules of the Game

NAIU experts identified 16 vectors of regulatory changes. For association members, each vector of change is accompanied by major risks and actions necessary for implementation. This list covers the entire spectrum of transformations — from financial stability to technology and consumer rights protection.

1. Transition to Solvency II. With the completion of the transition period, “significant” insurers will be obliged to calculate solvency capital and minimum capital under the new standard approach, which requires finalizing the methodology and reconfiguring IT systems. This will also require integrating ORSA processes and ESG risks into the companies’ management systems.
2. Operational Resilience (DORA). Implementation of European digital operational resilience standards envisages new strict requirements for cybersecurity, IT risk management, penetration testing, and incident reporting.
3. Cyber Hygiene and Cloud Services. A complete rejection of software from the aggressor state and tightening of requirements for the use of cloud services is envisaged. Mandatory due diligence of cloud solution providers and an exit strategy are being introduced.
4. SAF-T UA Tax Report. To implement the mandatory submission of the Standard Audit File (SAF-T UA), insurers must be technically ready to provide tax authorities with a full digital cross-section of accounting information within tight deadlines.
5. Liability for Information Disclosure (NSSMC). From January 1, 2026, fines for violating the deadlines and order of information disclosure on the stock market will increase significantly. The maximum sanction size may reach 5% of the company’s annual turnover.
6. Data Protection in the Intermediary Registry (CIPS). Implementation of a Comprehensive Information Protection System (CIPS) in the Register of Insurance Intermediaries will require the collection and verification of an expanded list of data on all agents and their employees.
7. Monitoring and Training of Intermediaries. To implement a system of constant monitoring of intermediaries’ compliance with legislative requirements, insurers must ensure (and automate) the process of annual professional development and testing of agents.
8. Corporate Governance. Tightening of requirements for supervisory boards for significant insurers is expected. Quotas for independent directors and the creation of committees (audit, risk, remuneration), as well as separate compliance and risk management units, will become mandatory.
9. New MTPL Market Conditions. From 2026 (or after the end of martial law), new liability limits come into force: UAH 1 million per person and UAH 20 million per incident. This requires a radical review of actuarial models and tariffs.
10. Remuneration Regulation. Improvement of requirements for remuneration policies of managers and key persons will include a condition where remuneration must be tied to the long-term results and risks of the company, with mandatory information disclosure.
11. Artificial Intelligence (AI) Regulation. Regulation of AI use in the financial sector (analogous to the EU AI Act) is forecast. The use of AI in underwriting and claims settlement will be classified as high-risk, requiring algorithm transparency and human control.
12. ESG Requirements. Implementation of mandatory reporting on environmental, social, and governance aspects (ESG) is expected, for which insurers need to integrate ESG factors into the risk management system and prepare non-financial reports.
13. iXBRL Reporting. With the tightening of requirements for reporting in the iXBRL format, an expansion of the taxonomy, deeper tagging of notes to financial statements, and integration of Solvency II indicators into this format are expected.
14. Lobbying Monitoring. To fulfill the already existing requirements of the law on fair lobbying, insurers must report on contacts with government bodies and register in the Transparency Register or regulate this activity through the association.
15. Post-War Transition. The cancellation of temporary martial law norms (after its end) envisages a phased return to standard requirements of prudential supervision, financial monitoring, and currency liberalization.
16. Consumer Rights Protection. Implementation of updated requirements of the law “On Consumer Rights Protection” (3 months after the war) introduces strict requirements for advertising, a ban on unfair practices, and joint liability of insurers with marketplaces.

Guidelines for the Future

NAIU analysis highlights that the time of “firefighting” is passing, giving way to the era of systemic strategic planning. To successfully navigate the 2026–2028 period, heads of insurance companies should consider the following guidelines:

• Invest in IT hygiene right now. Issues of software legalization, cyber protection (DORA), and readiness for SAF-T UA are not a distant perspective, but a basic hygienic level for company survival in the coming years.
• Prepare capital and people. Solvency II and ESG requirements require not only financial injections but also new expertise. It is necessary to start staff training and the search for independent directors in advance.
• Be flexible.The existence of two development scenarios requires companies to have a “Plan B”. NAIU models can be used for stress-testing company budgets.
• Change the approach to the product. The increase in MTPL limits and new consumer rights protection requirements demand a review of not only tariffs but also the philosophy of service and transparency.
• Implement a data culture. Implementation of AI and Solvency II requirements is impossible without high-quality historical data. Companies should already review the architecture of collecting, cleaning, and storing information. Data is becoming as valuable an asset as capital.
• Keep attention on operational efficiency. Increasing regulatory burden will inevitably increase administrative costs. Management should focus on optimizing business processes and automating routine tasks to preserve business margins without shifting all costs to the client.

Our Strategic Digest 2026–2028 is not just an analytical report, but a manifesto of the Ukrainian insurance market’s maturity. We are moving from situational response to long-term planning according to European standards. The document clearly demonstrates that the market will be more complex, more technological, and more demanding of capital, but at the same time more transparent and reliable for the consumer.

This public release offers the general public an overview of the situation and key analytical conclusions. For in-depth, internal analysis and precise calculations, the full array of data, formulas, legislation impact scenarios, and interactive mathematical models are provided to NAIU member insurers. These extended resources are intended for their joint work and use.

We are confident that armed with this knowledge and tools, insurers will be able not only to dignifiably pass the period of turbulence but also to become a driver of Ukraine’s economic recovery.