According to the proposed project:
- SIO will be appointed as the national reinsurance operator;
- insurance companies will be required to transfer at least 10% of their risks to SIO for reinsurance, with a subsequent increase of this share to 50% annually;
- all risks that will be transferred to the Eurasian Reinsurance Company (ERC) must go through SIO;
- a new provision on the national operator is also introduced, defining its legal and organizational aspects.
In its official remarks, the IBC emphasizes that the project creates quasi-monopolistic conditions with a mandatory "right of first refusal," centralized underwriting, and administrative control.
The organization notes: "This replaces market mechanisms for risk management with bureaucratic processes, increases regulatory risks, and creates dependence of the entire insurance sector on a single state operator."
Main remarks of the IBC:
- Failure to achieve goals
- Systemic threats
- Conflict of interest
- Quasi-supervisory powers
- Threat to fronting and obligatory contracts
- Unrealistic deadlines
The IBC emphasizes that this model is borrowed from countries under sanctions (Russia, Belarus), where access to global markets is limited. Kyrgyzstan does not face such restrictions, therefore this project is considered impractical and potentially harmful.
The Council concludes: "The project does not solve the stated tasks, creates systemic risks, undermines the competitive environment, and threatens economic security. We propose to exclude the document from discussion and revise the presidential decree so that it meets the real needs of the insurance market. The development of national reinsurance capacity is impossible through administrative centralization and monopolization; it must be based on market mechanisms, a competitive environment, trust among participants, and predictable regulation, which is a key condition for the sustainable development of the insurance market and the economy of Kyrgyzstan as a whole," the IBC stated.