Solvency II reporting and other timelines - Q4 2016 to Q2 2018 2016 Q4 Nov Oct 2017 Dec Q1 Feb Jan Mar Apr Solvency II reporting requirements Q2 May Jun Pillar 1 Head of Actuarial Function (HoAF) reporting (and AFR aligned) "Front-ending" Peer Review "Front-ending" 2018 Jul Q4 Nov Oct Dec Q1 Feb Jan Mar Apr AO TP "Front-ending" "Front-ending" Aug 20 - Peer Review Report (within one month of AR TP) Report finalisation HoAF opinion on ORSA risks, scenarios and projections ORSA process in 2017 Review of Risks... Jun AR TP TP peer review SF assessment to be submitted before YE SF assessment for 2017 ORSA supervisory report submission to CBI within 2 weeks of Board approval Q2 May May 6 - AO TP (same deadline as annual QRT) TP peer review SF assessment for 2016 Example of ORSA reporting Sep AR TP AO TP SF assessment to be submitted before YE Pillar 2 Q3 Aug July 20 - AR TP (within two months of AO TP) May 20 - AO TP (same deadline as annual QRT) Assess SF appropriateness (SF undertakings) November 2016 SF assessment for 2018 Scenarios... ORSA supervisory report submission to CBI within 2 weeks of Board approval Reporting Projections... Board Approval HoAF and Board engagement, HoAF reporting and opinions ORSA processes in 2018 8 wks Nov 25 QRT SII 8 wks Feb 25 QRT SII EIOPA - QRTs - Annual QRT SII (annual) EIOPA - SFCR SFCR EIOPA - RSR (min. triennial, with material updates annually) RSR (first year) Financial Stability - QRTs - Quarterly Financial Stability - QRTs - Annual For undertakings with SII BS assets > €12bn 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 FS (annual) 8 wks Nov 25 NSTs - L, NL Same reporting deadlines as EIOPA NSTs (12-13) - Quarterly - Statistical - All undertakings NSTs - L, NL 8 wks Feb 25 7 wks May 19 20 wks May 20 NSTs - L, NL 8 wks Feb 25 8 wks Feb 25 8 wks Feb 25 8 wks Nov 25 8 wks Nov 25 NSTs - VA NST NSTs - VA NST 7 wks Nov 18 QRT SII SFCR RSR NSTs - L, NL NSTs - VA NST 7 wks Aug 18 "Front-ending" and draft findings HoAF draft report Peer Review "Front-ending" and draft findings Peer Review draft report "Front-ending" and draft findings Trilateral engagement (HoAF, Peer Review and External Audit) 7 wks Nov 18 NSTs - L, NL 8 wks May 26 9 wks FS (quarterly) Mar 4 9 wks Mar 4 FS (quarterly) 7 wks Feb 18 NSTs - L, NL NSTs - VA NST 7 wks Aug 18 7 wks Aug 18 7 wks Aug 18 7 wks Feb 18 7 wks Feb 18 7 wks Feb 18 NSTs - Semi 7 wks Nov 18 7 wks Nov 18 NSTs - VA NST NSTs - VA NST Final report May 20 - CBI submissions Final report Audit Committee meeting Audit activities "Front-ending" and draft findings HoAF draft report "Front-ending" and draft findings Peer Review draft report "Front-ending" and draft findings Actuarial Function Report AO TP Actuarial Opinion on TP AR TP Actuarial Report on TP CBI Central Bank of Ireland DA SII Delegated Acts DAR Domestic Actuarial Regime ECB European Central Bank EIOPA European Insurance and Occupational Pensions Authority FS Financial Stability HoAF Head of Actuarial Function IASB International Accounting Standards Board IDD Insurance Distribution Directive ITS Implementing Technical Standards KID Key Information Document L Life MiFID Markets in Financial Instruments Directive NL Non-life NST National Specific Templates ORSA Own Risk and Solvency Assessment PRIIPS Packaged Retail and Insurancebased Investment Products PRISM CBI Probability Risk and Impact SysteM QRT Quantitative Reporting Template RSR Regular Supervisory Report RTS Regulatory Technical Standards SCR Solvency Capital Requirement SF Standard Formula SFCR Solvency and Financial Condition Report SII Solvency II TP Technical Provisions VA Variable Annuity YE Year-end wks - 6 May 12 18 wks May 6 NSTs - L, NL 6 wks May 12 6 wks May 12 NSTs - VA NST Board update Head of Actuarial Function (HoAF) reporting External Audit 9 wks Dec 2 9 wks FS (quarterly) Sept 1 NSTs - L, NL (annual) NSTs - Semi 7 wks May 19 7 wks May 19 6 wks May 12 18 wks May 6 18 wks May 6 18 wks May 6 QRT SII QRT SII (annual) Board update Practical example of CBI reporting interactions 7 wks Feb 18 QRT SII FS (annual) NSTs - L, NL (annual) NSTs - Semi 7 wks Aug 18 QRT SII 9 wks Jun 2 FS (quarterly) 10 wks FS (quarterly) Mar 11 10 wks Mar 11 10 wks FS (quarterly) Dec 9 FS (quarterly) 7 wks May 19 20 wks May 20 20 wks May 20 20 wks May 20 QRT SII AFR HoAF and Board Engagement Pillar 3 EIOPA - QRTs - Quarterly Abbreviations Final report May 6 - CBI submissions Final report Audit activities Audit Committee meeting Legend External deadline Ongoing trilateral communications Ongoing trilateral communications Example company set deadline for delivery IFRS reporting IFRS 17 (IFRS 4 Phase 2) Final standard developments Final standard expected Preparation period (for expected effective date of 1 January 2021) IFRS 9 (for insurers) Start-date driven by period end Deferral approach for insurers Start-date not prescribed Jan 1 - effective date Market and distribution Jan 1 - currently expected effective date Redrafting of RTS after EU Parliament rejection PRIIPs (Packaged Retail and Insurance-based Investment Products) IDD (Insurance Distribution Directive) Oct 24 Consultation closes EIOPA preparation of draft ITS Finalisation of RTS (TBD) Feb 23 - ITS submitted to European Commission Finalisation of requirements KID preparation and finalisation Aug 23 - EIOPA deadline for publication of final Guidelines KID updates Transposition into law Feb 23 - Deadline for transposition into Irish law Reporting requirements not applicable to all undertakings (e.g. vary by PRISM rating) Contacts Notes: Paraic Joyce Padraig Osborne Niall Naughton David Walsh Ronan Mulligan Aoife Martin Reporting requirements presented above are not exhaustive and are for illustrative purposes only. Insurance Partner Partner Life Actuarial Principal Consultant Life Actuarial Principal Consultant Non-Life Actuarial Director Non-Life Actuarial Director Deadlines are based on an individual undertaking with a 31 December financial year-end. [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] 6 additional weeks apply to individual EIOPA/ECB/NST deadlines for groups; 2 additional weeks apply for FS reporting by groups. 01 792 6394 01 792 6106 01 792 6314 01 792 8983 01 792 7505 01 792 6829 EIOPA/NST quarterly reporting deadlines reduce from 8 weeks for 2016 reporting, by 1 week each year, to 5 weeks from 2019 onwards. EIOPA/NST annual reporting deadlines reduce from 20 weeks for year-end 2016, by 2 weeks each year, to 14 weeks from 2019 onwards. FS quarterly reporting deadlines reduce from 10 weeks for 2016, by 1 week each year, 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. © 2016 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. "Front-ending" refers to review (e.g of data, governance, assumptions and methodology) that can be completed before the valuation date. Please see www.pwc.com/structure for further details. Peer review of TPs under the DAR is required every 2, 3 or 5 years for High, Medium-High and Medium-Low undetakings respectively. 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. www.pwc.ie
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