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14 September 2026 · 9 min read

#46: Why every financial services provider should follow Savings and Investment Accounts closely

#46: Why every financial services provider should follow Savings and Investment Accounts closely
Edition #46 · 13 September 2026

Why every financial services provider should follow Savings and Investment Accounts closely

Savings and Investment Accounts: Ireland’s blueprint and five more member states at work · A one-click phone bill insurance, read against the IPID · Revolut and MetLife on credit protection · Stanford on who the AI agent works for · ChatGPT for Financial Services

By Andres Lehtmets · 13 September 2026
Editor’s note

A large part of my work this autumn is on Savings and Investments Union files: investment accounts, retail investment, pensions and the way all of them interact with digital finance and innovation. Ireland has just published the design of its Savings and Investment Account, and several other member states are working on theirs. National SIA design decides which products qualify, how you report and whether retail money flows through you or around you. That is a commercial question, not a policy one, and it is where this edition starts.

I worked on these questions from the regulator side and now advise firms and public authorities on them. If you want a briefing on the Irish design, the Commission’s expectations or the Estonian experience, reply to this email and we can set up a call.

Article 01

Savings and Investment Accounts: Ireland has a blueprint, five more member states are at work

On 31 August 2026 Ireland’s Department of Finance published its Roadmap for the Taxation of Retail Investment, including the design of a Savings and Investment Account (SIA). Savings and Investment Accounts are where the Savings and Investments Union (SIU) gets real for retail customers, and for the firms serving them. The European Commission’s recommendation of 30 September 2025 set out the objective and left the design to member states.

Key features of the Irish account:

  1. Taxed account. Tax applies annually at a flat low rate to the value of the account above a tax-free threshold. Rate and threshold are not yet set; both come with Budget 2027.
  2. Contributions. No minimum. A maximum annual contribution limit applies, also to be set in the Budget.
  3. One account per person.
  4. Eligible investors. Irish resident individuals aged 18 and over with a PPSN, Ireland’s national identification number.
  5. Eligible providers. MiFID-authorised investment firms, regulated fund managers, and insurers or firms regulated under the Insurance Distribution Regulations. Non-Irish EEA-authorised providers will be eligible but must operate the tax for their investors.
  6. Providers run the tax. They calculate, report and pay any tax due on behalf of the investor. The customer files nothing.
  7. Eligible investments. Listed shares, listed bonds, instruments traded on a regulated market and retail-suitable investment funds including ETFs. Insurance-based investment products (IBIPs) are also eligible.
  8. Excluded. Derivatives and crypto assets.
  9. No time limits or geographical restrictions on investments.
  10. Fees. Provider fees are expected to be minimal and competitive by international standards.

Legislation follows in the Finance (No. 2) Bill 2026 this autumn, with accounts available from 2027.

Two details matter for business. The provider list is broad, covering investment firms, fund managers and insurers, with EEA passporting firms in as long as they take on the tax work. And the product list is deliberately narrow: listed securities, retail funds and IBIPs, nothing structured or exotic. Which side of that line your product sits on decides whether the account brings you customers or takes them away.

Estonia went a different way years ago. One simple investment account, digital-first, broad asset eligibility, no caps, tax deferred until you withdraw more than you put in and the whole thing handled through the tax authority’s e-services. It works because it is easy to explain and easy to use. I wrote up the Estonian model as a blueprint for the SIU here.

Ireland is not alone. A recent stocktake among member states that I have seen lists six member states with ongoing work towards an SIA framework, Ireland included, at very different stages. Spain is finalising a legislative proposal after a public consultation, to be submitted to Parliament. Croatia expects draft legislation in Parliament during 2026. Luxembourg is working on a national framework in parallel with the Finance Europe label. The Netherlands is assessing feasibility under its 2026 coalition agreement, noting that existing securities accounts already have several of the non-fiscal features the Commission recommended. Romania is evaluating a proposal for individual investment accounts alongside recent Fiscal Code amendments to encourage retail investment. Greece pointed to a recent proposal that could form the basis for future work. Ireland is simply the furthest along in public.

Which products qualify, how you report and whether retail money flows through you or around you: all of that is settled in national design, not in Brussels. Firms in every member state that has not yet published its design should be in that conversation now, not when the bill is drafted. The Irish roadmap · the Commission recommendation.

Article 02

A one-click phone bill insurance, read against its own IPID

This week my telecom operator emailed me an offer: insure your phone bill against the unexpected. For 3.59 euros a month the insurer pays up to 90 euros a month, for up to six months, if I fall ill for a long time, need to care for a sick child or lose my job. Up to 90 euros, that is. If my bill is 20 euros, then 20 euros it is.

One button: activate. I wanted to see the customer journey, and with a single click the cover was added to my bill. The email said nothing else. So I read the terms and the insurance product information document. My notes:

  1. Waiting periods. The first 30 days of illness or job loss are never paid. Job loss cover only starts 60 days after activation. Most sick leave never reaches day 31.
  2. Exclusions. Mental health is out entirely, including stress, depression and anxiety, which are among the biggest drivers of long sick leave. Anything that started before activation is out as well, and nobody asked me a single health question.
  3. Eligibility. Self-employed, fixed-term, on probation, under 20 hours a week, already unemployed, over 65: none of them can claim on the job loss part. Nobody checks any of this when you click activate. The recommended tier appears to have been picked from my bill size, not from whether I could ever claim.
  4. Overlap. In Estonia, statutory sick pay and unemployment insurance already cover most of the income risk this product describes. Many people also hold life or health cover that does the same. What is left is a fixed credit against a phone bill, for months two to seven of a qualifying event, if none of the above applies.

I have no claims ratio and no commission share for this product. It is wrapped as a group policy between the telco and the insurer, which is a separate case study for the advanced readers.

Maybe I am too critical, or I missed some details. But anyone selling this in 2026 has misjudged the political reality, the work done on value for money and digital fairness in recent years and what supervisors now expect. Most of all, they underestimate their customers. EIOPA’s 2022 warning on credit protection insurance described the same pattern: products sold at the point of another purchase, with limited eligibility checks, high exclusions and value that is hard to see.

Article 03

Revolut and MetLife launch credit protection insurance for personal loans

On 9 September 2026 Revolut and MetLife announced Credit Protection Insurance for Revolut personal loan customers, launching first in Romania, Spain, Portugal and France, with more EU markets to follow. It is offered in-app, both at loan origination and to existing borrowers.

Two tiers. The basic package covers death, permanent or temporary disability and hospitalisation. The full package adds involuntary job loss. Payout is 100 per cent of the outstanding balance on death or permanent disability, and up to 12 monthly instalments for the rest. Distribution runs through Revolut Insurance Europe, MetLife carries the risk.

Article 04

Who is the AI agent working for? Stanford calls for a duty of loyalty

On 25 August 2026 the Stanford Institute for Human-Centered AI (Stanford HAI) published a policy brief, Designing Loyalty: AI Agents and Conflicts of Interest. Its starting point is simple: AI agents may be steered to prioritise the interests of their developers and deployers over those of their users.

Three takeaways:

  1. There are currently no requirements or standardised mechanisms for disclosing developers’ and deployers’ conflicts of interest, so the harm to consumers stays invisible.
  2. In higher-stakes or regulated areas such as financial services and healthcare, developers and deployers of AI agents should be treated as fiduciaries, with a duty of loyalty to act in the user’s best interest within the scope of the delegated task.
  3. Making that work needs coordinated action from technical standards bodies, regulators and the legislature, not one of them alone.

The EU perspective is worth setting out. Sectoral law already contains the duty: MiFID II and the IDD require firms to act honestly, fairly and professionally in the best interests of clients, with conflicts of interest identified, managed and disclosed. The AI Act adds transparency and risk management on top. The gap is not the duty, it is the perimeter. If the agent sits inside a regulated distributor, the duty applies. If it sits in a general-purpose platform that the customer uses to compare and choose, we are back to the question the House of Lords put to the FCA in edition #45, and the one EIOPA has forwarded to the European Commission in Q&A 3407, which I analysed in this piece: is the platform a distributor at all? Until that is answered, the loyalty of the agent depends on who built it. Read the brief.

Quick links
OpenAI launches ChatGPT for Financial Services

On 10 September OpenAI introduced ChatGPT for Financial Services, a version of its work product with financial data built in, developed with Morgan Stanley and Evercore as design partners. It plugs in data providers such as PitchBook, LSEG and S&P Capital IQ, cites sources at line level and produces Excel, Word and PowerPoint outputs, with separate workspaces for information barriers. The announcement.

NYDFS on cyber risk assessments: at least annually, and whenever the technology changes

On 10 September the New York State Department of Financial Services published guidance on conducting and using the risk assessments required under its Cybersecurity Regulation. No new obligations, but reassess at least annually and whenever the business or technology changes, and let the assessment drive your controls. Adopting frontier AI models is named as a trigger. In the age of agentic and frontier AI, that means a lot more often than it used to. The guidance.

AXA and Publicis Sapient scale a Global AI Hub for AI agents

On 8 September AXA announced a partnership with Publicis Sapient to develop its Global AI Hub, a shared platform for deploying AI agents across the Group, already live in five entities. Shared foundations for governance, security and human oversight, so entities build business value rather than their own agent plumbing. The press release.

Australia publishes a Financial Innovation Strategy

On 3 September the Australian Government released its Financial Innovation Strategy, built on three principles: government leadership, proportionate and fit-for-purpose regulation and public-private collaboration. It replaces the Enhanced Regulatory Sandbox with a more flexible model, creates a Financial Innovation Committee and plans thematic sandboxes for AI, tokenised assets and digital money. Strategies alone are not enough, but the process behind them forces government, regulators and industry to agree where they want to go and how much risk they are willing to take as a society. That conversation is often worth more than the document. The strategy.

Number of the week
6

The number of EU member states, Ireland included, with ongoing work towards a Savings and Investment Account framework, from exploratory policy work to bills heading to Parliament, with Greece pointing to a proposal that could follow. Each one will decide on its own which products qualify and who may offer them. Is your product line on any of those lists?

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Andres Lehtmets

Andres Lehtmets

Independent advisor on financial regulation and digital innovation. Former Senior InsurTech Expert at EIOPA. Research Analyst at Cambridge Centre for Alternative Finance. Writing weekly for 4,700+ professionals.

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