Who Decides Who Is Insurable? Data Governance of Flood Insurance Underwriting in Ireland (Zenodo)

Summary

• About one in twenty buildings in Ireland has limited or no access to flood insurance.p.1
• Around 50,000 households are in areas with a high risk of flooding, predicted to rise to around 78,000 by 2100 under a moderate climate scenario.p.2
• Around 290,000 buildings face some level of flood risk.p.2
• Between 6,450 and 36,700 mortgaged households sit in high-risk zones, between 1.2% and 6.9% of the total, with a best central estimate of about 19,500.p.2
• The revised Consumer Protection Code, whose new protections took effect on 24 March 2026, requires firms to act honestly, fairly and professionally.p.4
• The UK Flood Re scheme supports 353,000 high-risk policies and ends 2039.p.5
• The first EU Framework for Climate Resilience was presented on 27 October 2026.p.5

Key insights

1. Governance of flood insurance data is strongest where data is public and weakest where cover decisions are made.p.1
2. A property with a 1% yearly flood chance has about a one-in-four chance of flooding at least once during a 30-year mortgage.p.2
3. The Government's Action Plan on Insurance Reform 2025-2029 focuses on cost and availability of insurance and sets no rules for flood underwriting data.p.4
4. The CJEU SCHUFA ruling (C-634/21) suggests a flood model score could itself fall within Article 22 of the GDPR.p.6
5. Under Section 5(2)(d) of the Equal Status Acts, differential treatment in insurance is allowed where based on reliable actuarial data, so area-based underwriting is generally lawful.p.7
6. The paper makes six proposals to keep accurate risk data while making the system transparent, contestable and fair.p.9
7. The US National Flood Insurance Program moved in 2021 towards risk-based pricing, with larger drop-outs in lower-income areas.p.5