The establishment of the pool could mark a significant turning point in the framework of mandatory nat cat coverage introduced by the aforementioned legislation. It is expected to provide the national insurance market with a collective vehicle for complying with new legal obligations, leveraging mutual tools for risk mitigation and transfer.

As is known, Article 1, paragraph 102, of Law No. 213/2023 introduced, with effect from 1 January 2024, an obligation for all enterprises with a registered office or permanent establishment in Italy to obtain insurance coverage against catastrophic events.

This obligation specifically concerns physical damage to assets instrumental to business activity and serves general public interest objectives: reducing the systemic economic impact of extreme natural events, promoting a culture of prevention, and containing public financial exposure ex post.

In parallel, the legislator has encouraged public reinsurance mechanisms, through the intervention of SACE S.p.A., which would act as a reinsurer of last resort, on a subsidiary basis with respect to the private market (see paragraph 106).

However, the regulatory framework presupposes the existence of a market capable of sustainably absorbing this new mandatory demand. In this context, the initiative to establish a national insurance pool—promoted by the main companies operating in Italy—has emerged as a response, with both technical and systemic aims.

According to available information, the pool is structured as a consortium with legal personality, yet without autonomous underwriting capacity: it does not retain risk or capital, and operates exclusively in the name and on behalf of its member companies.

Its core operational functions are expected to include:

• Centralising the negotiation and placement of reinsurance treaties with third-party operators (including international reinsurers)
• Facilitating technical dialogue with SACE regarding the public retrocession layer
• Harmonising and standardising practices for risk transfer and catastrophe risk management
• Ensuring coordinated and mutualised management of insurance capacity

Membership in the consortium is voluntary, and it is currently understood that insurers representing approximately 75% of the Italian market would be participating.

The pool would therefore act as a vehicle for collective efficiency and technical stabilisation, without amounting to any joint exercise of reserved activities under Article 11 of the Italian Private Insurance Code (Legislative Decree No. 209/2005).

The pool's operational framework will be governed by two internal instruments:

• A statute, which regulates the organisation of the consortium, including the calculation mechanism for reinsurance needs
• A technical regulation, which outlines the detailed procedures for risk transfer

The pool will be also structured around the following bodies:

• A steering committee, composed of the chair and eight representatives of member companies (who do not hold executive roles within their respective groups)
• A technical secretariat, composed of independent members, entrusted with the aggregation and technical analysis of portfolios

With regard to operational aspects, ANIA has clarified that risk cessions would be conducted based on the "pure premium" principle, while allowing each company to independently determine its commercial premium. The technical secretariat will obtain reinsurance quotes based on proposals submitted by member companies.

The risk transfer mechanisms are expected to follow two main reinsurance models: proportional and non-proportional.

Each participating company is required to cede a minimum portion of its portfolio, referred to as the Pool access threshold. Specifically:

• For proportional reinsurance, each company must retain at least 10% of the insured risk
• For non-proportional reinsurance, it is possible to cede up to 25% of the pool's total capacity, but only for portfolios involving significant risks

The technical secretariat may proportionally reduce the maximum share of cessions submitted by each company ("referenced risk"), depending on the overall technical balance of the pool.

The establishment of the nat cat insurance pool could introduce a novel operational model to the Italian market, with several distinctive features:

• Risk mutualisation and access to international reinsurance

By concentrating portfolios and centralising cessions, the pool may enable participating insurers to secure improved conditions on global reinsurance markets, thereby reducing volatility and enhancing technical efficiency.

• Overcoming fragmentation and streamlining the offering

In a context where mandatory coverage could lead to pricing imbalances and opportunistic behaviours, the consortium approach might help harmonise practices, contract structures, and underwriting strategies.

• Coordination with public reinsurance

The pool is expected to serve as a bridge between the primary market and the subsidiary role of SACE, facilitating the information flow and operational coordination envisaged under Law No. 213/2023.

• Systemic value and replicability

Should the model prove effective, it could serve as a virtuous precedent for other emerging risk areas (e.g. cyber risk, pandemic risk, climate-related losses), where individual insurance management often proves unsustainable.

According to ANIA, the nat cat pool should not be seen as a mere operational response, but rather as the beginning of a new, structured, and cooperative approach to managing systemic risk.

In a country like Italy, highly exposed to extreme natural events, the development of collective mechanisms capable of channelling insurance capacity and interfacing with public entities could become a key strategic milestone.

It is reasonable to expect further developments over the coming months in the implementation rules and operational protocols of the Pool, including minimum contractual standards required for regulatory compliance.

It will also be of interest to assess whether the model will be supported by fiscal or regulatory incentives (e.g. solvency relief), in recognition of its function as a public interest initiative.