15 May 2012

Insurance Europe Position Paper on the Solvency II Reporting Package

Insurance Europe very much supports EIOPA’s initiative to work in advance of these timelines to determine the content of the quantitative reporting templates (QRTs) which forms the bulk of Pillar III requirements. Insurance Europe would like to note that while significant progress has been made in terms of developing draft templates, there are many outstanding issues with regards to LOG definitions which are vital in ensuring that (re)insurers correctly understand the information to be reported and how to obtain data within their organisations.

In November 2011, EIOPA launched a public consultation on the draft QRTs and draft guidelines on narrative reporting (RSR)/public disclosure (SFCR). In December 2011, EIOPA launched a subsequent consultation to consider additional reporting requirements for financial stability purposes.

With particular reference to quantitative and financial stability templates, Insurance Europe understands the benefits of incorporating all reporting requirements into one package. However the industry is becoming increasingly concerned as to how this would work in practice within the framework of Solvency II.

Insurance Europe comments:

• Quarterly templates:
  • The use of approximations and simplified calculations are essential in order to deliver quarterly reports.
  • Financial stability reporting should be integrated into a single reporting process for undertakings.
• Information held by 3rd party providers:
  • Availability of information is reliant on cooperation with third part service providers, any delays in the data chain will impact supervisory reporting.
  • (Re)Insurers may incur additional fees for passing data on to third parties (supervisors).
• Public disclosure:
  • Templates for public disclosure should be simplified and should not contain undertaking sensitive data.
  • The statutory accounting column should not be publically disclosed alongside the Solvency II valuation column.
• Historical data based on Solvency II definitions and methodologies will not be available upon entry into force.
• Narrative reporting and QRTs should not contain duplicate information
• It should not be required to submit the quarterly template for Q4 of the financial year
• Proportionality/Materiality:
  • Insurance Europe is uncertain as to how proportionality and materiality might apply in practice.
  • Where the (re)insurer does not directly hold risk, detailed reporting should be reduced.

Full position paper

© InsuranceEurope