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EIOPA announces flexibility on Solvency II reporting deadlines in wake of COVID-19

Catherine Drummond
Catherine Drummond Partner

On Friday last week, EIOPA announced its recommendations on supervisory flexibility regarding Solvency II reporting and disclosure deadlines as a result of COVID-19.

This will bring some limited relief to firms which are grappling with the havoc that the Coronavirus pandemic is wreaking on their day-to-day operations, at the same time as Solvency II reporting deadlines are looming large.

Recognising the likelihood that insurers may face increasingly difficult conditions in the immediate future as they navigate through challenging market conditions, EIOPA has flagged the need for firms to concentrate their efforts on monitoring and assessing the impact of the COVID-19 situation, as well as ensuring business continuity. EIOPA also noted that the upcoming Q1 2020 reporting cycle will be extremely important for entities and regulators alike.

Given this, EIOPA has made an number of recommendations, including:

Annual reporting for firms with year-ends from 31 December 2019 – 31 March 2020 (inclusive):

1. An 8-week delay for group and solo deadlines for:

a) RSRs

b) QRT submissions, except for the following, which may be delayed by just 2 weeks:

  • Content of the Submission
  • Basic Information
  • Balance sheet
  • Cashflow projections for life business (solo only)
  • Long Term Guarantees
  • Own funds
  • SCR templates

2. For those firms which have quarterly reporting exemptions, and have not reported in Q4-2019, regulators may also request specific additional information.

3. EIOPA also recommends that regulators should take a similarly flexible approach to any national specific reporting (eg ORSAs, audits)

Quarterly reporting for quarter-ends from 31 March 2020 - 29 June 2020 (inclusive)

1. 1-week delay in the solo and group quarterly QRT (except for the Derivative Transactions QRT, which may be delayed by 4 weeks)

2. EIOPA also noted that each firm is expected to report its estimated

SCR at the quarter-end (and not the one last calculated) in the Own Funds template SFCR reporting for firms with year-ends from 31 December 2019 – 31 March 2020 (inclusive):

1. An 8-week delay for the group and solo SFCR reporting deadlines - however firms must publish the following QRTs within 2 weeks of the original deadline:

  • Balance sheet
  • Long Term Guarantees
  • Own funds
  • SCR calculation

2. EIOPA also notes that the current COVID-19 situation is a “major development” under Solvency II and that firms should also publish appropriate information alongside their regulatory reporting to explain the impact of COVID-19.

The full text of EIOPA’s recommendations is available here.

Catherine Drummond
Catherine Drummond