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Brian Morrissey, Head of Insurance, and our insurance team have compiled a collection of KPMG's latest publications and articles which focus on developments in, and issues facing the insurance industry. Also included are recent publications from the CBI, EIOPA, and other European bodies.

KPMG Updates

Conduct Risk: Spotlight on Insurance

The insurance sector has been a key focus of the Central Bank of Ireland’s (‘CBI’) conduct and culture  work in recent years. The spotlight is set to remain on the insurance industry, with the CBI affirming in March 2022 that its work this year will have a particular focus on culture in the insurance sector, noting that “it is clear” from our work that cultural weaknesses persist, and more work is needed to address the challenges and reputational issues identified”. Now more than ever, it’s critical to the long-term success of regulated firms to focus on effectively meeting the challenge of enhancing consumer protection through embedding conduct risk frameworks in their operations. In this article, we highlight some of the key regulatory focus areas in conduct risk for the insurance industry right now and in the coming months.

Navigating uncertainty amid the conflict in Ukraine

Organizations are grappling with a number of evolving complexities that pose operational and compliance challenges. Businesses should scenario plan amid this uncertainty to comply with sanctions, stay resilient and support their people and communicate as risks develop and priorities shift. KPMG firms are here to help companies understand the potential business implications, so you can continue to support your customers, employees and communities:

General insurance emerging focus areas

As the insurance industry continues to respond to a rapidly changing operating environment, there are several areas where we are expecting to see changes which will impact the market. In this report, KPMG Australia, led by David Kells (Partner & National Insurance Sector Leader) and Richard Yee (Partner & National Insurance Actuarial Leader) highlight the impact on the market, bringing additional focus on the risk environment and risk management practices for general insurers. 

Podcast on Climate-related risks: Financial reporting impacts

Interconnectivity between the financial statements and the rest of the annual report on climate-related matters is a key concern for investors and regulators. In this podcast, KPMG Canada, led by Reinhard Dotzlaw (Partner, Global IFRS Leader), the focus of discussion is climate change financial reporting.

Technology enabled internal audit: 2022 and beyond

In this publication, KPMG Netherlands, led by Huck Chuah (Partner, Internal Audit) and Pascal Raven  (Senior Manager, Internal Audit) address different potential barriers to be overcome by internal auditors to build credibility and trust, so that they can be true strategic assurance providers and sparring partners for the organization when it comes to technology and risk management.

KPMG responses to IASB consultations

KPMG’s response to the International Accounting Standard Boards (IASB) consultations proposed amendments to IAS 1, IAS 7 and IFRS 7, discussion papers or exposure drafts are included below: 

Regulatory Cooperation - Interactions between regulators in a digital age

KPMG UK, led by Kate Dawson (Banking Conduct and Capital Markets Sector Lead for the EMA Financial Services Regulatory Insight Centre (RIC)) discuss how the financial services landscape continues to undergo widespread digitalisation, marked by an influx of borderless and data-based products and services.  

Global insurance risk and compliance transformation survey

To understand the industry’s approach to managing risk and compliance, KPMG Global, led by Laura Hay (Global Head of Insurance) conducted two separate surveys, each for the respective functions, to assess and understand where insurance firms are in their risk and compliance transformation journeys. A total of 37 insurance firms have participated in these surveys, ranging from small and medium-sized firms to some of the key players in the international insurance industry. Responses were received from a broad range of geographies.

2022 ECB climate risk stress test

The ECB’s supervisory climate risk stress test began on 27 January 2022 and will run through the first half of 2022, with aggregate results due to be published in July. Participating banks have worked against the clock in the last weeks, preparing starting point data and projection templates for the first submission on 7 March 2022. And yet, immediately after, banks will still have significant challenges and uncertainties to resolve before the following submission in late March. KPMG Germany, led by Alberto Delso (Senior Manager, KPMG Germany) discuss this further in this article

Shining the light on the fit and proper framework

At the turn of the year, the ECB published a podcast in which Frank Elderson, Vice-Chair of the Supervisory Board of the ECB, discussed the topic of leadership and the ECB’s role in selecting banks’ leaders. The discussion covered many topics, including what defines good leadership, and why it is critical that the right people should be selected to run banks. KPMG Germany, led by Maureen Finglass (Senior Manager, KPMG Germany) discuss the way in which banks are managed and led, as well as how suitable board members are appointed, are crucial lynchpins in navigating out of the current COVID-19 crisis. 

Central Bank of Ireland (CBI) Updates

New Insurance Regulations

The CBI has published the Central Bank (Supervision and Enforcement) Act 2013 (Section 48(1)) (Insurance Requirements) Regulations 2022 which will apply to insurance undertakings and insurance intermediaries from 1 July 2022. A ban on price walking in insurance in the motor and home insurance market will come into effect from 1 July 2022. This means that, from 1 July, insurance providers cannot charge relevant renewing customers a premium that is higher than they would have charged an equivalent year one consumer renewing their policy. The CBI has also published a feedback statement and FAQs related to this matter.

Financial Regulation Priorities

The CBI has published a press release regarding the 2022 financial regulation priorities set out by the Director General, Financial Conduct Derville Rowland. The CBI notes that its objective is to create the regulatory context in which the potential benefits of innovation for consumers, businesses and society can be realised, while the risks are effectively managed, and that it would continue to operate a forward-looking approach to the authorisation of financial services firms, being clear about its expectations to prospective and applicant firms.

Consumer Protection Outlook Report

The CBI has published its Consumer Protection Outlook Report calling out five key cross sectoral risks facing consumers of financial services, as well as what the CBI expects regulated financial firms to do about those risks. 

New Accountability in Financial Services: Changing Individual Behaviour and Culture

The CBI has published a speech by Director General, Financial Conduct Derville Rowland, at the UCD Sutherland School of Law & Eversheds Sutherland book launch regarding “New Accountability in Financial Services: Changing Individual Behaviour and Culture”. Concluding her speech, Derville encourages firms to use this time to implement the Individual Accountability Framework (IAF) by understanding their obligations, assessing current governance structures to identify who is responsible for what and implement any necessary changes to their existing business model in order to ensure the requirements can be properly embedded.

Diversity & Consumer Protection

The CBI has published comments from Derville Rowland, Director General, Financial Conduct regarding diversity at senior levels, Fitness & Probity, and consumer and investor protection. In her comments, Derville made it clear that “Regulated firms must prioritise diversity at senior levels to prevent groupthink, promote internal challenge, and protect consumers and investors”. According to the Central Bank of Ireland Demographic Analysis Report, gender diversity at senior levels in the regulated financial services sector is increasing but remains insufficient, with female representation in application for PCF roles at 31% in 2021 compared to 16% in 2012. 

Fitness & Probity

The CBI has published a feedback statement on Pre-approval Controlled Functions (PCFs). Further to the Notice of Intention issued in September 2021, the CBI is amending the PCF list as follows:

  • Expanding PCF-16 Branch Manager of branches in other EEA countries to include branch managers in non-EEA countries; and
  • Introducing stand-alone PCFs in respect of a. Independent Non-Executive Directors; b. Head of Anti-Money Laundering and Counter Terrorist Financing Compliance; and 3. Removing PCF-31 Head of Investment.

Consumer Protection

The CBI has published a Notice of Intention. It contains information about:

  • Authorisation requirements.
  • Amendments to the Consumer Protection Code 2012, the Minimum Competency Code 2017, and the Minimum Competency Regulations 2017, following enactment of the Consumer Protection (Regulation of Retail Credit and Credit Servicing Firms) Bill 2021. The Consumer Protection (Regulation of Retail Credit and Credit Servicing Firms) Bill 2021 is progressing through the Houses of the Oireachtas and is expected to be signed into law in 2022. 

Report on retail market conduct issues

The International Organization of Securities Commission’s (IOSCO) Retail Market Conduct Task Force (RMCTF), co-chaired by the CBI and the Australian Securities & Investments Commission, has published the Retail Market Conduct Task Force Report: Consultation Report. 

Overview of the Economic Outlook

The CBI published an opening statement by Governor Gabriel Makhlouf at Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach, giving a brief overview of the economic outlook. The CBI has also published an opening statement by Gerry Cross, Director, Financial Regulation, giving overview on financial regulation.

EIOPA Updates

EIOPA: Climate change adaptation measures in non-life insurance

The European Insurance and Occupational Pensions Authority (EIOPA) has announced the launch of a data collection exercise to assess the potential for a dedicated Pillar 1 treatment of climate-related adaptation measures in Solvency II's standard formula for non-life underwriting risk. The focus of the data collection is on the influence of climate-related adaptation measures on premium risk, and it is supplemented by qualitative questions on reserve risk and natural catastrophe risk. 

EIOPA: Costs and past performance of insurance and pension products

EIOPA has published its fourth report on the costs and past performance of insurance and pension products. The report points out that higher risk classes delivered higher net returns for unit-linked and hybrid products while longer holding periods continued driving higher performance of profit participation products. Certain lower-risk products posted particularly low and, at times, negative net returns. 

EIOPA: Ultimate Forward Rate

EIOPA has published the calculation of the Ultimate Forward Rate (UFR) for 2023. As of 1 January 2023, the applicable UFR for the euro will remain unchanged at 3.45%. The details of the calculation of the UFR for 2023 are available in the report on the calculation of the UFR for 2023.

EIOPA: Climate Stress Test

EIOPA has launched its first climate stress test to gain insights into the effects of environmental risks on the European occupational pension sector. Sustainability and the management of environmental risks have become key considerations for long-term investors and for European institutions for occupational retirement provision (IORPs).

EIOPA: Supervisory reporting and disclosure requirements: Solvency II

EIOPA has published a feedback statement on proposed amendments to the implementing technical standards (ITS) and guidelines on supervisory reporting and disclosure requirements under the Solvency II Directive. EIOPA consulted on the proposed amendments in July 2021. A summary of the feedback received, and EIOPA's response to it, is set out in the feedback statement. Alongside the feedback statement EIOPA has published:

  • Draft Commission Implementing Regulation laying down ITS regarding the templates for the submission of information to the supervisory authorities according to the Solvency II Directive and repealing Implementing Regulation.
  • Draft Commission Implementing Regulation laying down ITS regarding the procedures, formats and templates of the solvency and financial condition report (SFCR) in accordance with the Solvency II Directive and repealing Implementing Regulation.

EIOPA's webpage on the amended ITS includes links to related documents, including an impact assessment on the proposed ITS amendments, errata to EIOPA's guidelines on reporting for financial stability purposes and its guidelines on the supervision of branches of third-country insurance undertakings, as well as annotated templates. The final draft amended ITS have been submitted to the European Commission for endorsement.

EIOPA: Russian rouble RFR term structure

EIOPA will publish Russian rouble RFR term structures for end-March 2022 based on the most recent and reliable information according to the RFR methodology. Furthermore, EIOPA is checking the evolution of interest rates and the trading of government bonds in Russian rouble on a daily basis during March.

EIOPA: Recommendations to NCAs following stress test results

EIOPA has published a set of recommendations related to the results of its 2021 European-wide insurance sector stress test. The recommendations are addressed to National Competent Authorities (NCAs) and have been made under Article 21(2)(b) of the EIOPA Regulation. 

Other European and International Supervisory Authority Updates

IAIS: Newsletter

The International Association of Insurance Supervision (IAIS) has published a Newsletter, Issue 111, dated February/March 2022, which focuses on, among other things, cybersecurity and Climate Risk.

FSB: Work programme

The Financial Stability Board (FSB) has published its 2022 work programme. The FSB's work priorities reflect the fact that financial challenges are global in nature and affect the financial system. These challenges include digitalisation, climate change and potentially also shifts in the macroeconomic and interest rate environment. 

Recovering from the Pandemic, Preparing for Future Challenges

In partnership with the Economic and Social Research Institute (ESRI) and the European Investment Bank (EIB), the CBI hosted an event, “Business Finance & Investment: Recovering from the Pandemic, Preparing for Future Challenges.” The event provided an opportunity to share insights and discussion on the financing and investment challenges facing firms in Ireland. Opening the event, Governor Gabriel Makhlouf highlighted the CBI’s mandate to provide independent economic analysis and insight, saying “Good policy cannot be set without data, research, and analysis.” He continued, “Events like this are an attempt by our institutions to provide this holistic view, which is essential to good policymaking.” Deputy Governor Sharon Donnery closed the event.

EC/CBI: Russian Sanctions

The European Commission has issued a press statement (dedicated webpage) by President von der Leyen on the fifth round of sanctions against Russia. The CBI has also a dedicated webpage regarding this topic which is updated regularly. 

UK Updates

The PRA’s supervisory priorities for the insurance sector in 2022

Charlotte Gerken gave a speech in which she set out the Prudential Regulation Authority’s (“PRA”) supervisory priorities for insurance firms in the coming year. These include:

  • Climate Change and Environmental, Social, and Governance (ESG);
  • Diversity and Inclusion;
  • Operational Resilience; and
  • Approach to Third Country Branches.

UK: further sanctions targeting provision of insurance

HM Treasury announced that Russian companies in the aviation or space industry will be prevented from making use of UK-based insurance or reinsurance services directly or indirectly. The UK Government will bring in legislation to prohibit UK based insurance and reinsurance providers from undertaking financial transactions connected with a Russian entity or for use in Russia. Further details of the legislation will be available in due course.

PRA: Technical information for Solvency II firms

The PRA published the technical information for UK insurance firms subject to Solvency II to calculate technical provisions for the month of February on 8th March 2022. From 31 December 2020 (RFR data) and 31 March 2021 (SAECC and Volatility Adjustment data) UK firms must use the data which is published by the PRA rather than EIOPA.

Modification by consent for third-country branches

The PRA has published a new modification. Following the UK’s departure from the EU, a significant number of EEA firms have entered the Temporary Permissions Regime. In some cases, the operations effected by the branches of insurance firms in the Temporary Permissions Regime include, in whole or in part, risks that are not located in the UK. PRA is now offering a modification by consent to all third-country insurance branches to exclude risks that are not located in the UK when calculating branch technical provisions and branch capital requirements. If a firm wishes to take advantage of this modification, it should contact the PRA with a suitable request, copying in their usual supervision contact. The email should include the firm name and reference number.

Operational Resilience and Operational Continuity in Resolution

The PRA published Policy Statement PS2/22 which contains feedback to responses to Consultation Paper (CP) 21/21. The PRA states that it has amended certain aspects of its proposed policy, the main ones applicable to insurers being as follows:

  • To provide greater clarity for firms, the PRA has decided to amend the definition of important group business services in Rule 1.2 of the Operational Resilience rules applicable to Solvency II firms. Rule 1.2 now states that an important group business service means a service provided by a member of ‘the’, rather than ‘a’, firm’s group.
  • Paragraph 9.3 has been amended to clarify that a threat to the viability of the group is one example of how risks could arise to UK financial stability or a firm’s safety and soundness in the context of PRA-regulated insurers and policyholder protection.
  • Paragraph 9.5 has been amended to clarify that firms are expected to work with other members of their group to act, should it be likely that a relevant important group business service could not be delivered within its impact tolerance.

The implementation dates for the changes set out PS2/22 are 31 March 2022 for the Operational Resilience Parts and the Group Supervision Part and 1 January 2023 for the Operational Continuity Part.

PRA: Occasional Consultation Paper March 2022

The PRA published an Occasional Consultation Paper (dated March 2022) which contains minor updates regarding its approach to fulfilling its obligation to publish technical information (TI) necessary for the valuation of insurance liabilities for each relevant currency and some clarifications in its approach. This consultation closes on Tuesday 10 May 2022. Pending consideration of the responses to this consultation, the proposed implementation date for the changes resulting from this CP is Thursday 28 July 2022.

FCA: Operational resilience insights for insurance firms

The Financial Conduct Authority (“FCA”) published a webpage “Operational resilience insights for insurance firms”, asking a sample of firms about rules for strengthening operational resilience. It contains examples of good practices and areas of improvement relating to operational resilience. The FCA directs firms to use its observations to review their approaches to operational resilience against the FCA's observations and consider what actions they still need to take.

Financial Services Compensation Scheme – Management Expenses Levy Limit 2022/23

The PRA published PS3/22 Financial Services Compensation Scheme (FSCS) – Management Expenses Levy Limit (MELL) 2022/23, in which it provided feedback on consultation paper CP1/22 and set out the final rules for the FSCS MELL for 2022/23.

When CP1/22 was published the FSCS was forecasting an underspend of £5.2 million compared to the 2021/22 management expenses budget of £90.5 million. CP1/22 stated that if this forecast were to materialise these funds would be rebated to firms in the form of reduced levies for 2022/23. The FSCS is now forecasting an underspend of c. £9 million. If this forecast materialises and the contingency reserve is not utilised in 2022/23 the total levy paid by firms in 2022/23 will be £86.5 million instead of £95.5 million.

EIOPA Q&As

Please see below for EIOPA’s response to recent questions, as summarised by our colleagues in KPMG UK. EIOPA has responded to queries where uncertainties exist in the Solvency II requirements. The Solvency II requirements may change or become more prescriptive over time.

04 March: Insurance Distribution Directive –Single registration in Home member state

EC clarified in Q&A (#1847) that in accordance with the principle of single registration, the decision to register an intermediary, valid for the whole of the EEA, is the sole responsibility of the competent authority of the home Member State. There is no requirement for a separate or additional registration with the competent authority of the host Member State, neither for the intermediary nor for any staff members.

04 March: No netting off in market risk modules of SCR

EC clarified in Q&A (#1250) that as changes in the level or volatility of market prices of financial instruments may affect assets and liabilities in a different manner, assets and liabilities should not be netted against each other for the calculation of the market risk module. This principle is also embedded in the definition of the sub-modules of the market risk module in the Directive. More specifically, the sub-modules are defined as the capital requirements for the “sensitivity of the values of assets [and] liabilities” to the related risks.

04 March: Risk mitigation techniques

EC clarified in Q&A (#2064) that where a risk-mitigation technique will be in force for a period of 3 months and the insurer intends to replace that technique at the time of its expiry with a “similar” arrangement (following a three months strategy of hedging based on financial options), the risk-mitigating effect expected over 12 months can be taken into account in the calculation of the Solvency Capital Requirement, provided that the criteria set out in Article 209(3) of the Delegated Regulation (EU) 2015/35 are met. In addition, pursuant to Article 210(2) of Delegated Regulation (EU) 2015/35, the contractual arrangements governing a risk mitigation technique must not result in material basis risk or in the creation of new risks, unless these are reflected in the calculation of the Solvency Capital Requirement.

04 March: Health revision risk sub-module

EC clarified in Q&A (#1901) that Article 158 of the Delegated Regulation (EU) 2015/35 requires insurance and reinsurance undertakings to apply the permanent increase factor of 4% to the amount of annuity benefits payable under the underlying insurance policies where those benefits could increase as a result of changes in inflation, the legal environment or the state of health of the person insured. Also, where types of multi-state or frequency-severity modelling are used for the valuation of health insurance products, the permanent increase of 4% must be applied to the whole amount of payments and not exclusively to specific variables within the formula for calculating those payments, such as, for instance, percentages of payments that are associated to specific events or risks (e.g., disability).

04 March: Reinsurance recoverables–adjustment for counterparty default cannot be positive

EC clarified in Q&A (#1979) that in accordance with Article 81 of Directive 2009/138/EC, the amounts recoverable from reinsurance contracts and special purpose vehicles shall be adjusted “to take account of expected losses due to default of the counterparty”. Since the purpose of the adjustment is to account for losses and not for possible gains, the adjustment cannot be positive or, in other words, cannot increase the value of the reinsurance recoverables.

07 March: Insurance Distribution Directive-Ancillary insurance intermediary

EC clarified in Q&A (#1971) that with regard to the examples given in the question, car dealers can offer mandatory third party liability (MTPL) insurance as an add-on product to cars sold by them, as the sale of cars is their principal professional activity. Travel agencies could propose liability insurance, possibly as part of a travel insurance package provided that (1) there is a sufficient connection between the insurance product and the travel services provided by the agency and (2) the provision of travel services is the principal professional activity of the agency.

The same principles apply to financial agents offering payment protection insurance with life insurance elements as a complement to loans and mortgages offered by them, or to real estate agents who propose multi-risk home insurance including liability coverage to the buyers of homes sold by the agents as part of their principal professional activity. In all such cases, there must be a sufficient temporal and factual connection between the insurance coverage and the provision of the good or service by the intermediary as part of his or her principal professional activity.

08 March: Scope of Insurance Distribution Directive

EC clarified in Q&A (#2006) that the definition of ‘insurance distribution’ in Article 2(1)(1) of the Directive (EU) 2016/97 includes not only ‘the activities of advising on, proposing, or carrying out other work preparatory to the conclusion of contracts of insurance, of concluding such contracts’ but also ‘assisting in the administration and performance of such contracts, in particular in the event of a claim’. It follows that the activities consisting solely of claims management on a professional basis, loss adjusting, and expert appraisal of claims undertaken by operators performed by third party providers are excluded from the scope of the IDD (Article 2(2)(b) IDD).

08 March: Scope of Insurance Distribution Directive

EC clarified in Q&A (#1795) that whether car rentals are within scope of this exemption will depend on the circumstances of the individual case. It further explained this with an example. In order to be exempted from the scope of the Directive, an ancillary insurance intermediary – in the present case a car rental company – would have to meet all the cumulative conditions set out in Article 1(3) IDD for the entire range of insurance products offered. If the exemption of Article 1(3) IDD applies, Article 1(4) IDD must also be complied with.

08 March: Insurance Distribution Directive – Portfolio management

EC clarified in Q&A (#1596) that although the concept of ‘portfolio management’ has not been included in the IDD, it is possible that, in individual cases, a customer entrusts an insurance intermediary with a mandate to make on-going investment decisions related to an insurance-based investment product on a discretionary basis. In such a case, the intermediary would, for example, be entitled to make decisions on the switching between underlying investment assets on behalf of the client.

08 March: Insurance Distribution Directive –Definition of ‘third parties’

EC clarified in Q&A (#2100) the meaning of the term “third parties” in Article 29(3) IDD. The second sentence of the article referred to must be understood as meaning any party outside the relationship between the customer and the insurance intermediary or insurance undertaking distributing the insurance-based investment product and providing insurance advice. Having that in mind, insurance undertakings providing the insurance-based investment product are to be considered as third parties within the meaning of the second sentence of Article 29(3) IDD when they are not involved in the distribution and provision of insurance advice to the customer.

08 March: Insurance Distribution Directive –Timing of sale of insurance product

EC clarified in Q&A (#2208) that the Directive sets no conditions about the precise timing of the sale of insurance product in relation to supplying the good or service. The exact timing of the purchase of the insurance product in relation to the provision of the good or service is not a decisive factor. Indeed, Article 1(3) of the IDD does not explicitly prevent the distribution of insurance products after the purchase of the principal good/service if the insurance product can be considered complementary to the specific good or service previously purchased from the same provider.

In the case of services, this can typically be the case if the provision of the service has not yet begun. In the case of insurance of goods against the risk of breakdown, loss, or damage there must be a sufficient temporal and factual connection with the supply of the good by the provider.

08 March: Insurance Distribution Directive - CPD requirements

EC clarified in Q&A (#2111) that only those persons within the management of the concerned undertakings who are responsible for distribution in respect of insurance and reinsurance products and all other staff members personally performing insurance and reinsurance distribution activities as defined in Article 2(1)(1) IDD, are to be covered by the requirement for continuing professional training and development, based on at least 15 hours of professional training or development per year.

18 March: Technical Provisions –Future discretionary benefits

EIOPA clarified in Q&A (#2056) that all future discretionary benefits should be included within the Technical Provisions, unless they form part of the surplus funds (Article 91 (2) of the Solvency II Directive). Solvency II does not differentiate the determination of surplus funds according to whether business is in run-off or not. In addition, national specificities of the different markets, where surplus funds occur, such as the UK, will have consequences on the concrete determination of surplus funds in the respective markets and should be considered for business in this country only. Therefore, the PRA's supervisory statement does not apply in Ireland.

18 March: Technical Provisions – Not yet due premiums

EIOPA clarified in Q&A (#2366) that they agree with the approach described by the stakeholder that premium cash-flows that have a contractual payment date after the valuation date should be considered as not due and hence include these cash-flows within the Solvency II technical provisions. Therefore, regardless of whether any premium cash-flows have been accrued under the statutory financial statements, the premium cash-flows are included within the technical provisions if the contractual payment date is after the valuation date.

18 March: Technical Provisions – Allocation of expenses

EIOPA clarified in Q&A (#2355) that the expenses should be allocated to current and future policies according to Solvency II regulation. However, in some cases there might be no current business to bear this expense. To ensure a prudent, reliable, and objective calculation as required by Article 76 (4) of the Solvency II Directive, undertakings may need to adapt their assumptions to allocate future expenses during exceptional situations.

In any case, future expenses alone should never lead to the recognition of a best estimate liability, as insurance and reinsurance obligations shall be recognised only at the date the undertaking becomes a party to the contract or the date the insurance or reinsurance cover begins, whichever date occurs earlier (Article 17 of the Delegated Regulation 2015/35). However, undertakings should pay attention to any requirement to recognise a non-insurance liability according to IFRS framework, as Solvency II follows IFRS recognition for non-insurance liabilities.

18 March: Exposures to the International Development Association (IDA)

EIOPA clarified in Q&A (#1698) exposures in the form of bonds and loans to the International Development Association (a member of the World Bank Group) should be assigned a risk factor stress i of 0 % in the calculation of the capital requirement for spread risk on bonds and loans.

15 –31 March: EIOPA published a number of responses relating to QRTs as follows:

  • QRT S.23.02 Detailed information by tiers on own funds in Q&A responses (#776), (#712) and (#2397);
  • QRT S.06.02.07 3rd country branch reporting for Investments in Q&A (#2395);
  • QRT S.06.03 Collective Investment Undertakings in Q&A (#2374); and
  • QRT S.23.01.04.01 Group Own Funds and QRT S.25.01.04.02 Group SCR in in Q&A (#2381).

Transition to IFRS 17

Every month KPMG Ireland’s IFRS team produces an update on the progress of the industry to date on the implementation of the new insurance accounting standard.

Further information

For more on any of the items above, or any Insurance-related queries, contact Brian Morrissey, Head of Insurance.