In the third quarter of 2026, most of the efforts of the National Association of Insurers of Ukraine were aimed at ensuring that the changes now taking place in the insurance market are adopted with insurers’ real experience in mind and are based on accurate data. This concerns the European solvency rules, the state mechanism for compensating war damage and the requirements for intermediaries. To this end, the Association created open platforms, collected and analysed data and prepared knowledge available not only to NASU members but to the market as a whole.
The quarter at a glance
1
An open platform for Solvency II
2
Rules for intermediaries and clients
3
Risk-based financial monitoring
4
Data for war-risk decisions
5
Updated PDMA platform
6
A map of insurance capacity for recovery
7
Digital security of the industry
8
A basic course for intermediaries
9
Consolidated market questions to the regulator
10
International and professional platforms
1
A single platform for Solvency II: the market approaches the transition prepared and with a common position
The transition to the European solvency model will change the capital, risk management and reporting requirements for every insurer. The market must be ready for this, and the regulator needs to see the practical issues companies are already facing. That is why NASU joined the NBU project on the implementation of Solvency II and proposed creating an open expert platform on its basis.
The Association’s dedicated committee is open to all insurers regardless of membership, as well as to actuaries and experts. Its goal is to gather the market’s questions in one place, take part in assessing the impact of the new requirements and help companies prepare. This way, the transition can be gradual and predictable rather than a sudden burden.
2
Clear rules for intermediaries and clients
A significant share of insurance products reaches clients through agents and brokers. How clearly the law describes their role determines both the transparency of the market and the protection of those who work in good faith. That is why NASU continued to advocate its concept of insurance intermediaries’ activities in the draft Law “On the Distribution of Insurance Products”. In particular, the Association proposed establishing a separate category of independent insurance agent.
In parallel, the Association worked on the new version of the Law “On Insurance”, legislation on the protection of consumers of financial services and on motor third-party liability insurance (MTPL). All these acts bring Ukrainian regulation closer to European rules. Our task is to make sure their provisions are applicable in practice and do not create conflicts for companies and their clients.
3
Focusing on real risks in financial monitoring
The Association consistently insists on a risk-based approach. The resources of the state and companies should be directed where the risk actually exists, and clients buying an ordinary risk policy should not have to go through excessive procedures.
In the third quarter, this position was reflected in the draft Strategy for the Development of the Insurance Market of Ukraine proposed by the NBU. By joining the typological study of risks in the financial sector, NASU proposed describing the specifics of insurance separately. Our aim is that ordinary market practices are not perceived as signs of suspicious activity and that risk assessment relies on the industry’s real experience.
4
State decisions on war risks are based on market data
War risk insurance remains one of the key instruments that allow businesses to operate and invest in Ukraine. NASU consolidates data from all active insurers in this segment, regardless of NASU membership, so that both the market and the state can see the full picture of how much business is already protected, which products are available and where the gaps are.
Today NASU is the only centre for consolidating war risk insurance data in Ukraine. The Association not only collects this data but also makes it open. The public dashboards and the NASU War Risk Insurance Report are available to everyone on the Association’s website, while more detailed analytical materials are provided to the National Bank of Ukraine and the Ministry of Economy, Environment and Agriculture of Ukraine. This data also underpins other analytical reports and publications.
For the market
An opportunity to see the dynamics of the segment and one’s own place in it.
For the state
The ability to make decisions on business support and compensation based on actual figures rather than estimates.
For international partners
Transparent information on how insurance protection against war risks works in Ukraine.
This data and the Association’s expertise were used in developing the government’s new mechanism for compensating war damage. NASU worked on options for the mechanism together with state institutions and discussed possible models of participation with insurers. This gives the mechanism a chance to combine state support with the capacity of the insurance market.
NASU has also consistently brought the topic of war risk insurance to a wider discussion: to working meetings at the National Bank, relevant ministries and a committee of the Verkhovna Rada, as well as to conferences with the business community. The Association initiated a round table on working instruments, barriers and business needs in war risk insurance to hear what prevents companies from using this protection today.
It is equally important that such decisions meet the needs of those they are designed for. That is why the Association maintained a direct dialogue with business, in particular with ICC Ukraine, with which it signed a Memorandum of Partnership. This permanent communication channel helps to better understand which protection instruments companies need and to develop them together.
5
Transparent data is the basis of trust in the market
Trust in the insurance market begins with being able to see its condition. That is why NASU updated the PDMA analytical platform to make the data easier to use. The Association also published an overview of the market for the first half of the year.
6
A map of insurance capacity for recovery
A major separate project of the quarter was a study of insurers’ appetite for covering investment and infrastructure recovery projects within the Ukraine Recovery and Reconstruction Framework. NASU surveyed market participants in the second quarter, and in the third it analysed and consolidated the data and published the results as PDMA dashboards and a separate overview on the Association’s website. The results were also shared with the National Bank of Ukraine and the Ministry of Economy, Environment and Agriculture of Ukraine.
Recovery will require not only financing but also reliable insurance cover. An investor, a bank or an international partner planning a project needs to understand which risks the Ukrainian market is ready to take on today and where additional instruments will be needed. This study is intended to provide exactly such a transparent map of insurance capacity.
For the state
A basis for planning mechanisms to support recovery.
For international partners
A benchmark of the real capacity of the Ukrainian market.
For insurers
An opportunity to see where their experience and resources may be in demand in large projects.
7
Digital security of the industry
Abandoning software from the aggressor state is not only a technological issue but also a security one. Searching for solutions separately is long and costly for each company. That is why NASU took on the task of consolidation: it collected and summarised developers’ proposals so that market participants can make decisions on the transition faster.
The Association brought the problematic issues identified during this work to the regulator’s attention. The aim of the project is to determine the market’s real readiness to abandon hostile software and to ensure that cyber protection requirements are achievable for the market.
8
Quality advice starts with quality training
An intermediary is often the first and only person who explains to the client what exactly they are buying. Their knowledge determines whether a person gets the protection they really need. That is why NASU prepared a basic training course for intermediaries in line with the regulator’s updated requirements. The course was designed to be accessible to everyone entering the profession: in various formats and taking into account the needs of people who find video difficult to follow. Some of the materials have been opened up as a financial literacy project for a wider audience.
9
Predictable rules for everyday work
Even a well-written rule raises questions once it starts being applied. NASU continued to collect such questions from companies and pass them on to the regulator as a consolidated market position. They concern consumer protection, work with non-residents, information security, authorisation of intermediaries and reporting. This way the rules are applied equally for everyone, and companies receive clear guidance instead of differing interpretations.
The Association likewise presented its members’ position on strategic documents, in particular the Strategy for the Development of the Insurance Market and the requirements for business continuity plans. NASU also continued to support tax changes that are important for the industry.
10
The Ukrainian market on international and professional platforms
European integration is not only about adopting laws but also about being present in the professional community. During the quarter, NASU represented the Ukrainian insurance market at conferences and forums. Among them was the research conference of the National Bank of Ukraine and Narodowy Bank Polski, where the Association’s General Director Denys Yastreb spoke about Ukraine as a laboratory of financial innovation. For Insurance Europe, the Association collected examples of its members’ customer-focused initiatives so that European colleagues can see the strengths of the Ukrainian market.
At the invitation of the Ministry of Economy, NASU took part in the Carpathian Summit and Economic Forum, the first summit of the new regional format “Carpathian Eight” (C8). It brings together the countries of the Carpathian region around security, energy, logistics and economic cooperation. For the insurance market, presence on such a platform matters: cross-border infrastructure and investment projects will need reliable insurance protection, and the voice of Ukrainian insurers should be heard already at the planning stage.
Dialogue with the banking sector and participation in discussing the financial inclusion strategy aim to make insurance more accessible to people and businesses. Financial literacy projects for small and medium-sized businesses, as well as for defenders and their families, serve the same purpose.
The Association’s openness also applies to its own work. NASU reports on its lobbying activities in the NACP Transparency Register and develops its website to make market analytics easier to use.
Looking ahead to the fourth quarter
Much of the third quarter’s work was preparatory, and in the fourth quarter it should move into practice. The aim is for European requirements to become clear working tools for companies rather than just rules on paper.
Conference · 10 November
Insurance protection as a foundation for SME recovery and growth — together with the STEP IN 2 EU programme and GIZ
Training for market professionals
Sustainable finance (ESG), digital operational resilience (DORA) and Solvency II
PDMA
Improving war risk reporting
NASU will continue to work to ensure that new legislation is applicable in practice, that financial monitoring becomes proportionate and that war risk data remains a reliable basis for decisions by the state and the market.
The third quarter confirmed that an important task of the Association is to provide shared tools for the whole market: data on which state decisions are based, expert platforms open to all, and knowledge available to everyone entering the profession. In the fourth quarter, NASU will continue to work in exactly this way.
