Insurance Europe recognises the possible benefits of such measures in maintaining momentum on the delayed regime, encourage readiness for actual implementation and maintaining a harmonised approach to Solvency II across Europe.
Insurance Europe remains supportive of an economic risk based regulatory regime and while delays in implementation are unfortunate, we are committed to make sure that this additional period of time is used to improve the existing framework so that it better reflects the economic reality of the insurers business model.
Insurance Europe welcomes discussion on how interim measures could be used to encourage companies to prepare for Solvency II. In particular, it supports EIOPA proposing high-level principle-based guidelines on qualitative aspects of Pillar II including governance, risk management and a forward looking risk assessment, provided proportionality is applied across all areas. Insurance Europe also supports interim guidelines on pre-application of internal models aiming at assuring consistency in approach and timing across national supervisory authorities and readiness from undertakings.
However, the industry opposes the introduction of compulsory quantitative reporting or ORSA (own risk and solvency assessment) requirements based on Solvency II pillar 1 requirements as this could pre-empt the outcome of the Omnibus II process and create potentially unnecessary costs. "Only when the outcome of Omnibus II is known can the focus turn to what — if any — interim measures should be applied to reporting", said Olav Jones, Insurance Europe's deputy director general.
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