Statement of DallBogg regarding the decision of the FSC of October 1, 2025, imposing a new ban on the company’s cross-border activity

Never before has the FSC applied such restrictive and disproportionate measures against a Bulgarian insurer, let alone against the largest Bulgarian insurer. Never before has the FSC calculated capital adequacy using such a restrictive and openly discriminatory methodology. Never before has the FSC worked against and set the host country regulators so strongly against a Bulgarian insurer, nor has it acted so tendentiously within an EIOPA platform. The EIOPA platform concerning DallBogg is deeply classified, and until its contents are disclosed, the impression remains that there is a coordinated effort against the largest Bulgarian insurer.

In practice, during the last three months since cross-border sales were banned by the FSC, DallBogg’s market conduct has risen significantly above the European average. Rarely does a working day pass with pending, unanswered complaints from the same day – while regulatory requirements allow between 15 and 45 days – and payments are being executed well ahead of all deadlines. We reported, yet received no comments on, the nine assessment criteria distributed by EIOPA to all regulators. No one is perfect, of course, but the reports indicated almost flawless conduct and showed negative indicators well below the averages across all markets.

Instead of receiving recognition, encouragement, and clear guidance, today we are presented with a new decision filled with general statements, based on “complaints and concerns” that merely replace the “beliefs and doubts” of the past. The FSC clearly fails to understand that it is not a church committee (perhaps misled by our name), and that beliefs and doubts cannot serve as the basis for supervisory action. Today, when DallBogg reports a Solvency Capital Requirement (SCR) coverage of 153% – or 133% even under the FSC’s most severe methodology – we are nonetheless subjected to another decision banning our operations abroad.

We will continue to safeguard the rights and interests of consumers everywhere, to uphold the authority of Bulgaria, and to achieve even stronger capital adequacy for the largest Bulgarian insurer.

DallBogg: Life and Health Pension Assurance

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