Based on EIOPA’s final guidelines to regulators for the implementation of the System of Governance requirements, insurers will need to establish a Risk Management Function with Solvency II responsibilities, perhaps as early as 1 January 2014. In addition, the current Central Bank of Ireland consultation on the Corporate Governance Code for Credit Institutions and Insurance Undertakings requires insurers to appoint a Chief Risk Officer. This note analyses the implications for insurers, setting out the key issues to address.