July 29, 2016
Solvency II: Still Missing Buy-in
by Hans Willert
The new prudential framework is not yet "business as usual." Many insurers are far away from using the framework.
The first QRT and the Opening information (“Day 1 Reporting”) have been filed. The insurers are “on track” with Solvency II … at least from a pure regulatory compliance point of view !
However, my day-to-day observation is more likely to be a mixed picture. The new prudential framework is not yet “Business As Usual (BAU)” as the large majority of insurance organizations are pretty far away from using the framework as a risk and capital based decision framework.
The first “real world” ORSA process has been (more or less) launched but it continues to be considered as a “reporting exercise” despite EIOPA having launched a EU-wide stress-test and a major “stress event” has occurred in June with the UK “Brexit”!
See also: The Right Way to Test for Solvency
It appears useful to have a look on a target operating model underlying Solvency II:
- Solvency II Risk and Capital Management represents the core of the new model.
- This model requires policies to meet the regulatory and organizational targets – these policies have been designed and approved in 2015 or early 2016 and need to be applied progressively.
- The two ORSA preparation projects 2014 and 2015 should now become BAU and “only” need to be run as a real process translating the ORSA policy designed in 2015 or early 2016.
- The 2017 reporting deadline for the first SFCR needs preparation and strategic decision making on how to meet the regulatory requirements and how to communicate with the stakeholders, the analysts, the competitors and any other third party eager to understand the new transparency.
- The AMSB (Administrative Management Supervisory Board) is ready to demonstrate that it takes decisions based on the risks and the capital based principles governing Solvency II!
We definitely face a sufficient number of challenges, expected and unexpected, to be eager to apply and test the new framework in BAU conditions. Let’s take the time, or, if necessary, the break to really make it happen. This experience will be crucial to contribute to the 2018 review of the Solvency II framework by EIOPA and the NCAs.