EEA insurers’ private assets have finally been sized by their supervisor. EIOPA’s new factsheet, covering the 2025 Q4 reporting period, puts the total at €1.185 trillion, or around 11% of total assets, at the end of 2025 — measured against a base of €10.53 trillion in total assets. The bigger surprise is compositional: private equity, at 6.3% of total assets, outweighs private credit, at 5.0%, inverting the private-credit-centric narrative that has dominated debate on both sides of the Atlantic.
Private equity is the bigger half nobody priced
The compositional split is the real headline. Trade coverage of insurers’ alternative-asset exposure has skewed toward private credit — CLOs, direct lending, mortgage books — treating private equity as a secondary concern. EIOPA’s numbers say otherwise: private equity accounted for 6.3% of total assets while private credit made up about 5.0%, meaning the equity sleeve is larger, not smaller, than the debt sleeve. In its factsheet on private credit and private equity exposures, EIOPA frames this as the first sector-wide sizing exercise of its kind, aggregated across the €10.53 trillion asset base European supervisors oversee. For an industry still calibrating capital charges and liquidity buffers around private credit, an equity allocation that runs a fifth larger reframes where the illiquidity risk actually concentrates.
Where the mortgage book hides
Within the private credit sleeve, the collateral is conventional even if the label is exotic. EIOPA’s underlying 2025 Q4 factsheet data shows that more than two-thirds of private credit exposures sit in mortgages and loans, with direct holdings of mortgages the single largest component at 31.9% of the private credit total. That is a granular, largely mortgage-book risk, not a securitised-CLO risk — a distinction regulators on both sides of the Atlantic are still sorting through. Private equity, meanwhile, has its own concentration: insurers hold 20.6% of their overall private equity investments in unlisted equity issued by German businesses, the single largest country weighting in the book. A mortgage-heavy credit sleeve paired with a Germany-heavy equity sleeve is a very different risk map than the diversified, fund-of-funds exposure regulators have generally assumed.
Life insurers lead, reinsurers hide the concentration
The exposure is not evenly spread across business lines. Life insurers carry the highest share of private assets, at 23.1% of total investment, ahead of reinsurers at 14.0%, non-life insurers at 13.6% and composites at 11.4%. But averages flatten the story reinsurers actually tell. Reinsurers lean toward unlisted equity participations rather than the private-credit instruments life insurers favour, and EIOPA’s own Financial Stability Report flags reinsurers as the segment supervisors should watch most closely, a pattern our earlier coverage of how resilience numbers can hide liquidity fault lines also traced through the reinsurance segment. Reinsurers tend to run higher private credit shares relative to total assets than other insurer types, with one in five ranking among the top 10% of all insurers by that measure. Their private credit book is also more diversified than other segments’: 36% direct mortgages and loans, another 6% through funds, 37% in unlisted or untraded corporate bonds, and 20% in collateralised securities carrying credit risk. Diversification of instrument type does not mean diversification of counterparty, though. EIOPA’s concentration metrics show reinsurers posting a standardised HHI of 0.0765 for private credit holdings — equivalent to just 11.9 effective insurers — with the top 10 reinsurers accounting for 71.84% of the segment’s private credit and 70.85% of its total assets. That is a tail risk sitting inside a segment EIOPA already flags as thinly populated at the top.
A supervisory statement meets the balance sheet it describes
EIOPA’s interest in insurer ownership structure predates this factsheet. In a supervisory statement consultation on private-equity-owned undertakings, the authority noted that private equity firms have shown growing interest in acquiring European insurance and reinsurance undertakings over the past decade, and warned that PE ownership tends to bring significant changes in business models, including greater use of private credit, illiquid assets and balance-sheet optimisation strategies. Read against the new factsheet, that consultation looks less like a hypothetical and more like a description of the sector as it already stands: an industry where the equity sleeve, at 6.3% of assets, already outweighs the credit sleeve, at 5.0%, even before PE-owned carriers are singled out. Our recent look at a decade of Solvency II supervision under mounting pressure found the same pattern: policy catching up to a balance-sheet shift that had already happened.
A transatlantic gap in supervisory attention
The transatlantic comparison sharpens the point. US insurance regulation has spent much of its recent attention on collateralised loan obligations: the NAIC’s issue brief on private credit and CLO exposure puts US insurers’ CLO holdings at $276.8 billion at year-end 2024, up about 2% from year-end 2023 and equal to roughly 5.1% of total bonds and 3.1% of total cash and invested assets, and notes that total insurer CLO exposure has more than doubled since 2018. That is a real and fast-growing exposure, and it explains why CLOs have absorbed much of the regulatory bandwidth. But it is a narrower slice of the balance sheet than what EIOPA has just measured in Europe, where private equity alone already runs larger than the entire private credit book. Supervisory statements and capital-charge debates in the EU have largely followed the US script — focused on credit instruments — even as EIOPA’s own data shows equity is the bigger half. Our coverage of EIOPA’s push for tougher supervisory convergence across the bloc flagged private markets as an emerging strain on the framework; this factsheet is the first hard number attached to that strain, and it points supervisors toward equity risk as much as credit risk.
