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Regulatory Developments
European level
Ireland
Pillar 1
Head of Actuarial Function (HoAF) reporting (and AFR aligned)
Peer review
Pillar 2
Pillar 3
Financial Stability - QRTs - quarterly
Financial Stability - QRTs - annual
NSTs (1, 2) - quarterly - Non-Life, Life - high PRISM rated only
NSTs (1, 2) - annual - Non-Life, Life - high PRISM rated only
NSTs (3-7) - semi-annual - Non-Life - high PRISM rated only
NSTs (8-11) - quarterly - variable annuity writers only
NSTs (12-13) - quarterly - statistical - all undertakings
Practical example of CBI SII reporting interactions
Trilateral engagement (HoAF, peer review and external audit)
IFR
S 1
7
2018
Q3Q4
Brexit (potential timeline)
EU endorsement process
Simplified example of implementation of IFRS 17
Simplified example of production of IFRS 17 results
External audit
IASB key dates
Head of Actuarial Function (HoAF) reporting
Peer review
HoAF opinion on ORSA risks, scenarios and projections
Q1
So
lven
cy I
I
Same reporting deadlines as
EIOPA
EIOPA - QRTs - Quarterly
EIOPA - QRTs - Annual
EIOPA - SFCR
EIOPA - RSR (min. triennial, with material updates annually)
For undertakings with SII BS
assets > €12bn
Solvency II and IFRS 17 timelines - Q4 2018 to Q2 2021
Assess SF appropriateness (SF undertakings)
Example of ORSA reporting
Q2Q3 Q4 Q1Q2
2021
Q4
2020
Q2Q1
2019
Ongoing review of SII by EC and EIOPA
EC submits proposal to European Council and ParliamentEC submits proposal to ARC
EIOPA updates to SII framework in effect
Report finalisation
Padraig Osborne
Insurance Partner
01 792 6106
Ronan Mulligan
Actuarial Partner
01 792 7505
www.pwc.ie
QRT SII (annual)
RSR
SFCR
QRT SII6 wks -11 Feb QRT SII
5 wks -5 May
AOTP
ORSA supervisory report submission
to CBI within 2 weeks of Board
approval
QRT SII
FS (quarterly)8 wks -25 Nov FS (quarterly)
8 wks -25 Feb FS (quarterly)
7 wks -19 May
FS (annual)8 wks -25 Feb
NSTs 6 wks -11 Nov NSTs
6 wks -11 Feb NSTs
5 wks -5 May
NSTs (annual)
6 wks -11 Nov
NSTs semi
NSTs - VA NSTs - VA
NST NST
NSTs - VA
NST
TP peer review
16 wks -
Solvency II AbbreviationsAFR Actuarial Function Report
AOTP Actuarial Opinion on TP
ARC Accounting Regulatory Committee
ARTP Actuarial Report on TP
CBI Central Bank of Ireland
DAR Domestic Actuarial Regime
EC European Commission
ECB European Central Bank
EFRAG European Financial Reporting Advisory Group
EIOPA European Insurance and Occupational Pensions Authority
FS Financial Stability
HoAF Head of Actuarial Function
IASB International Accounting Standards Board
L Life
LTG Long Term Guarantees
NL Non-life
NST National Specific Templates
ORSA Own Risk and Solvency Assessment
PRISM CBI Probability Risk and Impact SysteM
QRT Quantitative Reporting Template
RSR Regular Supervisory Report
SCR Solvency Capital Requirement
SF Standard Formula
SFCR Solvency and Financial Condition Report
SII Solvency II
TP Technical Provisions
TRG Transition Resource Group
VA Variable Annuity
WPOP With-Profits Operating Principles
YE Year-end
Notes:
Reporting requirements presented above are not exhaustive and are for illustrative purposes only.
Deadlines are based on an individual undertaking with a 31 December financial year-end.
6 additional weeks apply to individual EIOPA/ECB/NST deadlines for groups; 2 additional weeks apply for FS reporting by groups.
EIOPA/NST quarterly reporting deadlines reduce from 6 weeks for 2018 reporting, by 1 week, to 5 weeks from 2019 onwards.
EIOPA/NST annual reporting deadlines reduce from 16 weeks for year-end 2018, by 2 weeks to 14 weeks from 2019 onwards.
FS quarterly reporting deadlines reduce from 8 weeks for 2018, by 1 week, to 7 weeks from 2019 onwards.
For FS reporting, the same deadlines apply for quarterly and annual reporting.
FS semi-annual reporting relates to reporting in respect of a quarter.
NST (3-7) semi-annual reporting for non-life relates to reporting in respect of a half-year.
Each undertaking is required by the CBI to submit its first RSR at the same time as its first set of annual QRTs and SFCR.
"Front-ending" refers to review (e.g of data, governance, assumptions and methodology) that can be completed before the valuation date.
Peer review of TPs under the DAR is required every 2, 3 or 5 years for High, Medium-High and Medium-Low undetakings respectively.
1st January 2021 is the expected live date for IFRS 17 at the time of writing, although there are discussions with regard to a potential delay.
ARTP
16 June - ARTP (within two months of AOTP)
16 July - Peer Review Report (within one
month of ARTP)
QRT SII
FS (quarterly)
NSTs
NSTs - VA
NST
5 wks -4 Aug
5 wks -4 Aug
7 wks -18 Aug
This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.
© 2018 PricewaterhouseCoopers. All rights reserved. In this document, “PwC” refers to the Irish member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity.
Please see www.pwc.com/structure for further details.
Paraic Joyce
Insurance Partner
01 792 6394
Niall Naughton
Life Actuarial Director
01 792 6314
Contacts
QRT SII5 wks -4 Nov
QRT SII (annual)
FS (quarterly)
NSTs
FS (annual)
NSTs semi
NST NST NST
NSTs NSTs
FS (quarterly)
QRT SII QRT SII5 wks -4 Feb
5 wks -5 May
7 wks -18 Feb
7 wks -18 Nov
7 wks -18 Feb
5 wks -4 Nov
5 wks -4 Feb
5 wks -5 May
14 wks -7 April
5 wks -5 May
NSTs semi
NSTs - VA NSTs - VA NSTs - VA5 wks -4 Nov
5 wks -4 Nov
SFCR
RSR
5 wks -5 May
Board update
Audit Committee meeting
"Front-ending" TP peer review
Audit Committee meeting
Ongoing trilateral communications
ORSA supervisory report submission
to CBI within 2 weeks of Board
approval
Board update
SF assessment to be submitted before YE
SF assessment to be submitted before YE
ORSA process in 2019 Review of risks...
HoAF and Board engagement, HoAF reporting and opinions
Scenarios... Projections... Reporting
SF assessment for 2018 ORSA
Bence Zaupper
Life Actuarial Senior Manager
01 792 6624
NST
QRT SII5 wks -4 Aug
NSTs - VA
NSTs 5 wks -4 Aug
QRT SII (annual)
FS (annual)
NSTs semi
NST NST
FS (quarterly) FS (quarterly)
QRT SII QRT SII5 wks -4 Feb
5 wks -5 May
7 wks -18 Feb
7 wks -18 Feb
14 wks -8 April
NSTs - VA NSTs - VA
ORSA process in 2021
SFCR
RSR
HoAF and Board engagement
ORSA supervisory report submission
to CBI within 2 weeks of Board
approval
SF assessment for
Board update
SF assessment to be submitted before YE
QRT SII5 wks -4 Nov
Final report
"Front-ending" HoAF draft report Final report
"Front-ending" Peer review draft
"Front-ending" Audit activities
"Front-ending"
22 April - AOTP (same deadline as annual QRT)
"Front-ending" AOTP ARTP
7 April - AOTP (same deadline as annual QRT)
7 June - ARTP (within two months of AOTP)
"Front-ending" AOTP ARTP
8 April - AOTP (same deadline as annual QRT)
8 June - ARTP (within two months of AOTP)
7 July - Peer Review Report (within one
month of ARTP)TP peer review"Front-ending"
ORSA process in 2020 Review of risks...
HoAF and Board engagement, HoAF reporting and opinions
Scenarios... Projections... Reporting
SF assessment for 2019 ORSA
FS (quarterly)7 wks -19 May FS (quarterly)
7 wks -18 Aug FS (quarterly)
7 wks -18 Nov
7 wks -19 May
Audit Committee meeting
NSTs 5 wks -4 Nov NSTs
5 wks -4 Feb NSTs
5 wks -5 May
NSTs (annual)NSTs (annual)
IFRS 17 AbbreviationsCoA Chart of Accounts
CSM Contractual Service Margin
GL General Ledger
IFRS Intenational Financial ReportingStandards
Actuarial model design, build and test, inc. CSM solution
Calculate historic CSM, and evaluate transition results
Technical analysis, working assumptions and policy decisions Draft IFRS 17 FS & disclosures
Audit front-ending
22 April - CBI submissions
7 April - CBI submissions
Deadline for deferred implementation of IFRS
9
Lakshmi Vishnampet
Non-Life Actuarial Senior Manager
01 792 7022
29 March 2019 -Britain's membership of the EU due to lapse
Shane McDonald
Insurance Partner
01 792 6939
1 January 2021 -IFRS 17 live
31 Dec - Opening IFRS 17 Comparative Balance
Sheet
4 Dec - TRG meeting on IFRS 17
CoA design, build and test, update GL mappings for IFRS 17 Process, controls and governance, implementation and documentation
31 December 2020 -End of potential transition period
NSTs - VA
NST
5 wks -4 Nov
5 wks -4 Nov
5 wks -5 May
5 wks -5 May
Brexit potential transition period
Final report
"Front-ending" HoAF draft report Final report
"Front-ending" Peer review draft
"Front-ending" Audit activities
Ongoing trilateral communications
Final report
"Front-ending" HoAF draft report Final report
"Front-ending" Peer review draft
"Front-ending" Audit activities
NSTs semi
Design and detailed planning
Calculate YE 2019 results
16 wks -22 April
14 wks -7 April
14 wks -8 April
6 wks -11 Feb
EC to finalise SCR StandardFormula review - 31 Dec Implementation of
WPOP - 1 Jan 2020
Completion of EIOPA review of the Solvency II framework.
5 wks -4 Aug
5 wks -4 Feb
5 wks -5 May
5 wks -5 May
5 wks -4 Feb
5 wks -4 Feb
Expected EFRAG endorsement advice of IFRS 17 - Q4 '18
ARC vote on IFRS17 endorsement - 6 months after proposal submitted
IFRS 17 is adopted by EC -3 months each after proposal submitted
EIOPA's annual report on the impact of LTG measures - Dec 2019
EIOPA's annual report on the impact of LTG measures - Dec 2018
6 wks -11 Nov
6 wks -11 Nov
External deadline
Example company set deadline
Start-date driven by period end
Start-date not prescribed
Legend
Reporting requirements not applicable to all undertakings (e.g. vary by PRISM rating)
Ongoing trilateral communications
Opening YE 2020 valuation Q1 valuation under IFRS 17Impact assessment Dry run Dry run
"Front-ending"
8 April - CBI submissions
