COVID-19: EIOPA Recommendations

Flexibility for (re)insurer reporting & public disclosure

On 20 March 2020, the European Insurance and Occupational Pensions Authority (EIOPA) published recommendations on supervisory flexibility regarding the deadline for supervisory reporting and public disclosure by (re)insurers.

EIOPA is conscious that (re)insurers will face challenging market conditions in the immediate future and will need to concentrate efforts on monitoring/assessing the COVID-19 impact to ensure business continuity. EIOPA highlights that submission of Q1 2020 information to national insurance supervisors across Europe is important. However, the recommendations (applicable from 20 March 2020) aim to:

  • foster consistent approaches by supervisors when extending flexibility for reporting and disclosure
  • offer operational relief and support business continuity of (re)insurers

It remains to be seen whether supervisors will implement some or all of the recommendations. EIOPA has previously confirmed it would be directly engaging supervisors with this in mind.

EIOPA is keeping the recommendations under review.

Reporting template references (per EU level delegated and implementing regulations) are included below, to assist.

EIOPA's current recommendations

Recommendation 1 – annual reporting (y/e 31 Dec 2019 - 1 Apr 2020)

  • Supervisors should accept:
    • RSR (Regular Supervisory Report) – an eight week delay (solo and group level)
    • QRT (Quantitative Reporting Templates) – an eight week delay. There are exceptions (see more detail below)
    • For the following QRTs - a two week delay:
      • Content of the submission (S.01.01) (solo and group level)
      • Basic information (S.01.02) (solo and group level)
      • Balance-sheet (S.02.01) (solo and group level)
      • Cash-flow projections for life business (S.13.01) (solo level)
      • LTG (Long term guarantees) (S.22.01) (solo and group level)
      • Own funds (S.23.01) (solo and group level)
      • SCR (Solvency capital requirement) calculation (S.25.01 – S.25.03) (solo and group level)
      • Undertakings in the scope of the group (S.32.01) (group level)
  • What if we are exempted from quarterly reporting?

In such cases, supervisors to consider requesting additional templates as part of annual reporting.

The additional templates are as follows:

  • List of assets (S.06.02) (solo level)
  • Look-through information (S.06.03) (solo level)
  • Technical Provisions Life (S.12.01) (solo level)
  • Technical Provisions Non-Life (S.17.01) (solo level)

A two week delay to reporting recommended.

  • What about national-specific requirements?

Supervisors should take flexible approach (e.g. ORSA reporting deadlines, audit requirements).

  • Supervisors to submit information received to EIOPA no later than four weeks after receipt.

Recommendation 2 – Quarterly reporting (reference period 31 Mar 2020 – 30 Jun 2020)

  • Supervisors should accept:
    • Q1 2020 QRT/Quarterly Financial Stability – a one week delay (solo and group level) with the exception of Derivatives Transactions (S.08.02) in the QRT
    • Derivatives Transactions (S.08.02) in the QRT- four week delay
  • Early Q1 submissions encouraged
  • However, (re)insurers may take proportionate approach to less material aspects of calculations
  •  (Re)insurers expected to report the estimation of SCR for end Q1 2020 (Own Funds (S.23.01))
  • Supervisors to submit information received to EIOPA no later than four weeks after receipt.

Recommendation 3 – SFCR (y/e 31 Dec 2019 – 1 Apr 2020)

  • Supervisors should accept:
    • SFCR (Solvency & Financial Condition Report) – an eight week delay on publication. There are exceptions (more detail below).
    • For the following templates – a two week delay:
      • Balance-sheet (S.02.01) (solo and group level)
      • LTG (S.22.01) (solo and group level)
      • Own funds (S.23.01) (solo and group level)
      • SCR calculation (S.25.01) (solo and group level)
  • COVID-19 is "major development" (Art 54(1) Solvency II). (Re)insurers to publish appropriate information on effect of COVID-19 in SFCR

For more information on these issue please contact any member of A&L Goodbody's Insurance & Reinsurance team.

Date published: 26 March 2020