On October 9, the IIF submitted its response to the International Association of Insurance Supervisors' (IAIS) Draft Application Paper on Operational Resilience Objectives. In its response, the IIF emphasized the need for a principles-based, outcomes-focused approach to operational resilience that can work across jurisdictions. As such, the IIF recommends that the IAIS use this as an opportunity to advance a common language around operational resilience in the insurance sector. The response highlights that aligned definitions for key terms, particularly "critical services," are important in promoting supervisory coordination and cooperation, especially for cross-border insurance groups for instance. The IIF further emphasizes the unique nature of insurers, which generally do not provide critical payment, clearing, and settlement services that could severely impact the global financial system. The IIF encourages the IAIS to reflect these considerations in operational resilience frameworks for insurers, especially as the IAIS develops its operational resilience toolkit in 2025.