Key elements of Solvency II are the requirements relating to transparency and reports to be submitted to the supervisory authority as specified in Pillar 3. Pillar 3 applies at both solo and group level and consists of four elements:
- reports on solvency and financial condition, including quantitative reporting forms;
- supervisory reports, including quantitative reporting forms;
- reports on predefined events; and
- the policy on information to be publicly disclosed and the policy on reporting to the supervisory authority.
Solvency and financial condition report (SFCR)
The disclosure of Solvency II information to users of financial information constitutes an important element of Solvency II. Insurers do this by publishing an annual report on their solvency and financial condition, describing their activities and results, operations, risk profile, the principles used to value their assets, their technical provisions and other liabilities, and capital management. The relevant criteria are laid down in the Solvency II Directive and Regulation. Insurers are also required to publish several quantitative reporting forms, as specified in the European Commission's Implementing Regulation. The first Solvency and Financial Condition reports (SFCRs) were published in 2017 (on the 2016 financial year). In addition to this annual report, insurers must under specific circumstances disclose information in the interim, e.g. if they significantly fail to meet the minimum solvency capital requirement (SCR) and fail to submit a realistic recovery plan within two months. A copy of the SFCR must also be submitted to the supervisory authority.
Supervisory reports and quantitative reporting forms
As well as public disclosures, Solvency II requires insurers to compile a supervisory report for submission to the supervisory authority. This report comprises a descriptive section and various quantitative reporting forms, at both solo and group level. The descriptive section of the report is structured in the same way as the publicly disclosed report on the insurers’ solvency and financial condition, but contains information that is considered either too detailed or too confidential for public disclosure. The information to be submitted to the supervisory authority also includes an own risk and solvency assessment (ORSA). The quantitative reporting section comprises the reporting forms for the harmonised European framework (to be found on the EIOPA website) and the national reporting templates. A distinction is made between quarterly statements and annual statements, with the former being of a more limited scope. An external auditor must audit and certify a subset of the annual statements (see the Regulation on Statements of Financial Undertakings under the Financial Supervision Act for a summary of the relevant reporting forms). More information on technical reporting requirements can be found on the e-Line DNB web page.
Reports on predefined events
The occurrence of specific events may have a material impact on the insurer’s operations and may, therefore, be important to the supervisory authority. This includes events leading to a material change in the insurer’s activities, results, operations, risk profile, solvency or financial position. Insurers are required to report such events to the supervisory authority without fail.
Policy on public disclosures and supervisory reporting
The process of compiling public disclosures and supervisory reporting should be an integral part of the insurer’s operations. The insurer’s policy on public disclosures and supervisory reporting must be clearly defined.
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The relevant Articles in the Solvency II Directive are
- Article 54 - Report on solvency and financial condition: updates and additional voluntary information
- Article 55 - Report on solvency and financial condition: policy and approval
- Article 56 - Solvency and financial condition report: implementing measures
- Article 254(2) - Access to information
- Article 256 - Group solvency and financial condition report
The relevant Articles in the Delegated Regulation are:
- Articles 290-303: Report on solvency and financial condition (solo)
- Articles 304-314: Supervisory reports (solo)
- Articles 359-371: Report on solvency and financial condition (group)
- Articles 372-377: Supervisory reports (group)
The relevant technical standards are:
- ITS on regular supervisory reporting
- ITS on public disclosure
The relevant EIOPA guidelines are:
- EIOPA Guidelines on reporting and public disclosure