A Transformation in Progress – Perspectives and approaches to IFRS 17

The International Financial Reporting Standard 17 (IFRS 17) was issued in May 2017 by the International Accounting Standards Board (IASB) and has an effective date of 1st January 2021. The standard represents the most significant change in financial reporting for decades, placing greater demand on legacy accounting and actuarial systems. The regulation is intended to increase transparency and provide greater comparability of profitability across the insurance sector.

IFRS 17 will fundamentally change the face of profit and loss reporting. It will introduce a new set of Key Performance Indicators (KPIs), and change the way that base dividend or gross payments are calculated. To give an example, gross premiums will no longer be recorded under profit and loss. This is just one of the wide-ranging shifts that insurers must take on board in the way they structure their business to achieve the best possible commercial outcomes.

In early 2018 SAS asked 100 executives working in the insurance industry to share their opinions about the standard and strategies for compliance. The research shed light on the sector’s sentiment towards the regulation, challenges and opportunities that IFRS 17 presents, along with the steps organisations are taking to achieve compliance. The aims of the study were to better understand the views of the industry and how insurers are preparing to implement the standard. The objective was to share an unbiased view of the peer group’s analysis of, and approach to, tackling the challenges during the adjustment period. The information garnered is intended to help inform insurers’ decision-making during the early stages of their own projects, helping them arrive at the best-placed strategy for their business.

This report reveals the findings of the survey and provides guidance on how organisations might best achieve compliance. It provides a subjective, datadriven view of IFRS 17 along with valuable market context for insurance professionals who are developing their own strategies for tackling the new standard.

SAS’ research indicates that UK insurers do not underestimate the cost of IFRS 17 or the level of change it will likely introduce. Overall, 97 per cent of survey respondents said that they expected the standard to increase the cost and complexity of operating in insurance.

Companies will need to

  • introduce a new system of KPIs
  • and make changes in management information reports

to monitor performance under the revised profitability metrics. Forward looking strategic planning will also need to incorporate potential volatility and any ramifications within the insurance industry. To achieve this, firms will need to ensure the main parties involved co-operate and work together in a more integrated way.

The cost of these measures will, of course, differ considerably between organisations of different sizes, specialisms and complexities. However, the cost of compliance also greatly depends on

  • the approach taken by decision-makers,
  • the partners they choose
  • and the solutions they select.

Perhaps more instructive is that 90 per cent believe compliance costs will be greater than those demanded by the Solvency II Directive, aimed at insurers retaining strong financial buffers so they can meet claims from policyholders.

The European Commission estimated that it cost EU insurers between £3 and £4 billion to implement Solvency II, which was designed to standardise what had been a piecemeal approach to insurance regulations across the EU. Almost half (48 per cent) predict that IFRS 17 will cost substantially more.

Respondents are preparing for major alterations to their current accounting and actuarial systems, from minor upgrades all the way to wholesale replacements. Data management systems will be the prime target for review, with 84 per cent of respondents planning to either make additional investment (25 per cent), upgrade (34 per cent), or replace them (25 per cent). Finance, accounting and actuarial systems will also see significant innovation, as 83 per cent and 81 per cent respectively prepare for significant investment.

The use of analytics appears to be the most divisive area for insurers. While 27 per cent of participants are confident they will need to make no changes to their analytics systems or processes, 28 per cent plan to replace them entirely. A majority of 71 per cent still expect to make at least some reform.

IFRS17

IFRS17 2

Click here to access SAS’ Whitepaper

 

Risk Dashboard for fourth quarter of 2017: Risk exposure of the European Union insurance sector remains stable

Risks originating from the macroeconomic environment remained at a high level in Q4 2017, although most indicators improved slightly comparing with Q3. Positive developments in forecasted real GDP growth and increased expected inflation closer towards the ECB target contributed somewhat to a decrease in risk, as well as a slight reduction in the accommodative stance of monetary policy. Swap rates recently increased but remained low by historical standards. The credit-to-GDP gap was the only indicator to deteriorate since the previous assessment, moving further into negative territory.

Credit risks remain constant at a medium level in Q4 2017. Since the last assessment spreads have decreased across all bond segments, except for unsecured financial corporate bonds. Concerns about potential credit risk mispricing remain.

Market risks were stable at a medium level in Q4 2017. Most market indicators changed only little when compared to the previous risk assessment, except for investments in equity. Volatility of equity prices increased, with a temporary peak in February. A slight decline was reported for the price-to-book value ratio (PBV). In addition, Q4 Solvency II data seems to indicate a slight increase in median exposures to bonds and property and an increase of exposures to equity for insurers in the upper tail of the distribution.

Liquidity and funding risks remained constant at a medium level in Q4 2017, with most indicators pointing to a stable risk exposure.

Profitability and solvency risks remained stable at a medium level in Q4 2017. Annual figures for some profitability indicators show a slight deterioration when compared to annualised Q2 indicators, but are broadly at the same level as in Q4 2016. Solvency ratios remain well above 100% for most insurers in the sample. A slight increase in the quality of own funds has also been observed.

EIOPA1

Risks related to interlinkages and imbalances remain stable at a medium level in Q4 2017. Main observed developments relate to a slight decrease in median exposures to domestic sovereign debt and to a mild increase in the share of premiums ceded to reinsurers. Investment exposures to banks, insurers and other financial institutions remained broadly unchanged.

Insurance risks remained stable at a medium level when compared to Q3 2017. The impact of the catastrophic events observed in Q3 on insurers’ technical results still weights on the risk assessment.

EIOPA2

Market perceptions remained stable at a medium level since the last assessment. Positive developments related to the performance of insurers’ stock prices relative to the overall market and a decrease in the upper tail of the distribution of price-to-earnings ratios contributed to decreased risk, but this was partially compensated by a deterioration of some insurers’ external rating outlooks. Other indicators, such as insurers’ CDS spreads and external ratings remained largely unchanged.

Summary

Click here to access EIOPA’s detailed Risk Dashboard – April 2018

EIOPA3

Solvabilité II : Point de l’ACPR sur les SFCR collectés en 2017

Qualité

D’une manière générale, l’information consultable par le public via les SFCR de la collecte 2017 apparaît perfectible pour les motifs suivants :

  • Des rapports souvent désincarnés et peu accessibles pour un public non averti.
  • Des informations qui ne reflètent pas suffisamment les caractéristiques de l’entité :
    • Une absence de description du « business model » de l’organisme.
    • Des parties (gouvernance, ORSA, activité, résultat d’exploitation et capacité bénéficiaire) se limitant à l’énoncé des contraintes réglementaires.
  • Manquent également dans certains rapports publics les informations sur la politique et les pratiques de rémunération (dont les régimes de retraite anticipée et complémentaire de l’organe de gouvernance de l’organisme ou groupe).
  • Les modalités d’accès des responsables de fonctions clé aux dirigeants effectifs ne sont pas toujours suffisamment décrites.

Surtout, les effets – souvent considérables – des mesures transitoires, « provisions techniques » ou VA notamment, sur la solvabilité des organismes mériteraient d’être davantage détaillés, notamment quant à leur impact sur la solvabilité des groupes concernés.

SFCR France

Conclusion et recommandations

  • Cette première publication démontre la capacité de l’ensemble du marché à délivrer une information globalement conforme aux attendus réglementaires.
  • Cela étant, ces premiers SFCR se caractérisent par une grande hétérogénéité dans le niveau de détail et la cohérence de l’information délivrée au public et ne permettent pas encore suffisamment au lecteur de saisir les principaux enjeux et choix méthodologiques des assureurs.
  • Le SFCR n’est donc pas encore uniformément l’instrument de discipline de marché souhaité à l’origine, tant du point de vue de la conformité générale que de l’appréciation qualitative.
  • Pour les collectes à venir, notamment la collecte 2018, l’ACPR identifie les pistes d’amélioration suivantes :
    • Une publication du SFCR et de ses annexes aisément accessible sur internet pour les assurés ;
    • Une piste d’audit des données utilisées et publiées pour assurer leur traçabilité du QRT au SFCR ;
    • Une rédaction simple et fiable, selon les modes usuels de la communication financière, qui permette d’appréhender le profil de risque de l’organisme et son degré de sensibilité ;
    • Une mise en perspective des résultats avec les performances passées et les perspectives futures ;
    • La mention explicite des effets des mesures transitoires sur la solvabilité des organismes qui en bénéficient directement (obligatoire) et indirectement (si matériel) ;
    • Et d’une manière générale, des descriptions qui, au-delà de la stricte énonciation des attendus réglementaires, permettent de comprendre l’activité, l’organisation, les résultats, la solvabilité et le modèle de développement de chaque organisme.

Cliquez ici pour accéder à la présentation détaillée de l’ACPR

EIOPA’s Supervisory Statement Solvency II: Solvency and Financial Condition Report

  • The majority of insurance undertakings and groups published the (Solo/Group) SFCR on a timely basis and generally complied with the relevant Solvency II requirements. In some cases Groups went the extra mile to make the Group SFCR accessible to all stakeholders: The SFCRs are generally easy to find in the websites of most of the disclosing entities. However, some undertakings still do not own a website. In the websites of the insurance groups, in general, in addition to the Group SFCR, the solo SFCRs of the major entities of the group are also available at the same address and versions in English are available which facilitates access regarding the full group. The reports follow the structure as of Annex XX of the Delegated Regulation, but for non-applicable items, it is important to have a clear indication that the information is not applicable.
  • The use of different language styles and different formats to disclose SFCR information makes difficult the definition of a common disclosure approach to all types of stakeholders: EIOPA expects that care is taken when deciding the content and language style of the SFCR and in particular of the Summary of the SFCR. The Summary is the part of the SFCR that will most interest the policyholders. They should be the main addressees of this part of the Report. In the remaining sections of the SFCR it is not expected that the full content of EU or national legislation is reproduced in the SFCR. The Report should instead include relevant undertaking-specific information under each section to make it easy to efficiently identify and read the relevant specific information.
  • The need for a more fit-for-purpose ‘Summary’: EIOPA encourages insurance groups/undertakings to improve the content and clarity of the Summary. The SFCR Summary should encompass relevant SFCR areas and briefly provide relevant information. Given the importance of the SFCR Summary for the policyholders and the range of different approaches EIOPA clarifies the expectations on its minimum content from a supervisory perspective.
  • Quantitative Reporting Templates (QRTs) in the context of the SFCR: The placement of QRTs in an Annex to the SFCR, although a good practice, should not prevent undertakings/groups from providing quantitative and qualitative information into the body of the SFCR. Relevant information covered by the QRTs and additional information not covered by the QRTs in the Annex to the SFCR, such as background information that allows the reader to understand the information in the templates should be included in SFCR. If appropriate, parts of the QRTs should be repeated, or complemented through the narrative information of the SFCR.
  • Information on the own-risk and solvency assessment (ORSA) under the SFCR is by its very nature undertaking/group specific. This means that undertaking/group specific information needs to be included, even when referring only to the process and not to the outcome: The information disclosed should go beyond repeating the laws, regulations and administrative provisions on how the ORSA needs to be integrated into the organisational structure and decision making process.
  • The information on the risk sensitivity to different scenarios or stresses, should be better structured and more comprehensive: The information regarding the SCR and risk sensitivity is not comparable across different undertakings/groups. It is expected that the reporting of sensitivities to different scenarios or stresses is disclosed in a more structured format. The sensitivity to the different risks should be shown under the section ‘Risk Profile’. In addition under each risk section information on the overall impact should be provided.
  • Information on the bases, methods and main assumptions used for the valuation for solvency purposes should include undertaking/group specific information and address the uncertainties around the valuation: the SFCR should include more relevant, undertaking/group specific information, in particular regarding valuation of investments, valuation of deferred tax assets and deferred tax liabilities and valuation of technical provisions. Regarding the later the SFCR should provide a description of the level of uncertainty, by linking it at least to the assumptions underlying the calculation, such as economic and non-economic assumptions, expected profits in future premiums, future management actions and future policyholder behaviour.
  • Information on eligible own funds: EIOPA encourages undertakings/groups to disclose information about the management of the own funds in the context of the undertaking’s/group’s strategy and business model, including information on the time horizon used for business planning and on any material changes over the reporting period. The information of the eligible own-funds items, classified by tiers should be complemented by explanations of the most material own-funds items, including the extent to which they are available, subordinated, as well as their duration and any other feature that is relevant for assessing their quality.
  • In next year’s SFCR undertakings/groups should also include comparative information in certain areas of the SFCR. EIOPA expects that when providing comparative information the format of tables is used as much as possible in the narrative part of the SFCR. These tables could include amounts for both reporting years or focus on the material differences between both reporting years. Qualitative information on material differences between two reporting years are also expected to be included in the report. Publication of QRTs for current and the previous reporting year as an Annex alone is not sufficient to be considered compliant with the comparison requirement.

 

Click here to access EIOPA’s SFCR report

EIOPA Insurance Market Risk Dashboard October 2017

Key observations:

  • Risks for the insurance sector remain overall stable and some slight improvements are observed in the solvency ratios of groups and life solo undertakings.
  • Profitability of the sector has shown some positive signs both for life and non-life.
  • Despite these positive signs, the continuing low-yield environment and the observation that market fundamentals might not properly reflect the underlying credit risk, still represent important concerns for the EU insurance industry.
  • Underwriting risks remain of limited concern; however the impact of the recent nat cat events has not yet been reflected in this risk dashboard release and might affect (re)insurers exposed to the non-life business. At this stage no final conclusion can be made.
  • Market perception improved driven by the outperformances of the insurance stocks and the reduction of the CDS spreads. Ratings and rating outlooks remain stable.

Risk Dashboard Oct 2017

The macroeconomic environment characterised by enduring low-yields remains fragile. Inflation rate forecast is decreasing inverting the positive trend observed till March 2017, whereas unemployment rates continued to decrease. Despite slightly increasing policy rates in some jurisdictions, the balance sheets of central banks are still expanding (even if the increasing trend is reducing) with potential effects on the pricing of risk premia.

Credit risk is still not properly reflected in market prices where the observed spreads are close to the historical low. The investment portfolio of the undertakings, largely composed of investment grade assets, remains stable in terms of credit quality.

Market risks remain at a medium level. The slight increase of the volatility in the bond markets is counterbalanced by the reduction of the volatility in equity markets. Insurance specific indicators confirm the stable risk exposure.

Risks relating to liquidity and funding remain constant in Q2 2017. However, the increase of the average coupon/maturity indicator, despite affecting a minority of the market, shows an increased challenge for insurers to raise debt funding. Q2 2017 reports a material increase in the cat bond issuance to back potential effects deriving from the hurricane season. Nevertheless the overall assessment of the risk category shows that liquidity is not a major issue for the insurance industry.

Indicators of profitability and solvency signal slight signs of improvement. SCR ratios slightly increased for groups and life solo undertakings whereas non-life solo undertakings reported stable values. Profitability of the sector has shown some positive signs both for life and non-life business.

Insurance risks remain unchanged. Concerns rise from the potential impact on the industry of the recent nat cat events observed in the US and in some European countries. Those events are not yet reflected in the specific metrics and any conclusive change on the impact is premature.

Click here to access EIOPA’s detailed dashboard

 

Solvency II : First experiences with SFCR reporting – Germany, UK, Ireland

In May 2017, all German solo insurance companies were required for the first time to publish selected reporting forms as part of Solvency and Financial Condition Reporting (SFCR) – insurance groups followed at the end of June. These reports did not only include a huge amount of data on specific Solvency II risk figures but also comprehensive information about

  • general business development,
  • qualitative explanations on the presented figures and on the financial, solvency and business situation.

Aside from the obligation to publish own Solvency II results, insurance companies now for the first time have the opportunity to compare their Solvency II results with direct competitors.

The publication of SFCR reports also gives stakeholders access to Solvency II reports who did not have insight into these results before, for instance

  • rating agencies,
  • sales partners,
  • customers,
  • media
  • and creditors.

The extension of the target group has two main consequences for insurance companies:

  1. Firstly, Solvency II results need to be explained to an audience that has little experience with Solvency II – unlike insurance supervisors who had exclusive access to Solvency II results until now.
  2. Secondly, the solvency ratio becomes increasingly important as a material piece of information from SFC reports.

Due to the flood of information available in the SFC reports and the lack of experience of many market participants, it can be expected that processing Solvency II results will be mainly restricted to the evaluation of the solvency ratio as the core result of Solvency II. In particular, it was revealed that individual insurance companies are already actively using the solvency ratio in sales.

The attention given to the solvency ratio by the public will increase even further in the future if ratios approach the critical 100% threshold due to reduced interim measures.

Due to its increasing importance, the solvency ratio is no longer regarded as a pure reporting figure but as a value that requires active management. A variety of degrees of freedom and options in the calculation of Solvency II results allow insurance companies both to adjust their business policies and to influence SII results through suitable calculation methods. Due to the short history of Solvency II, there is little understanding of the impact mechanisms “behind” the solvency ratio at the moment, which is why not all optimization potentials are currently leveraged and insurers are still actively searching for solvency ratio levers.

In light of the extended information basis, decisions about

  • the use of interest rate measures,
  • an internal model (instead of the standard model),
  • simplified calculation methods
  • and the use of company-specific parameters

can be reassessed.

SFCR Germany

Click here to access Zeb Control’s detailed report

In a survey of the Solvency and Financial Condition Reports (SFCRs) and public Quantitative Reporting Templates (QRTs) for 100 of the top non-life insurers in the UK and Ireland the aim of the review was twofold – to analyse the numbers disclosed by firms for the first time and to consider how well firms have dealt with the narrative reporting required of them under Solvency II.

The survey team has also drawn upon our Pillar 3 roundtables with insurers and reinsurers across the market to understand how the first year of submissions has worked in practice.

Their key conclusions are:

  • Insurers are generally sufficiently capitalised, but the buffers firms have in place to protect against balance sheet volatility may not be enough to prevent them from having to recapitalise over the short term.
  • Motor insurers typically have the least financial headroom, compared with other insurers.
  • Brexit is on the agenda for many insurers, with some firms setting up internal steering groups to ensure they are well placed to access the European Market after the UK leaves the EU.
  • Uncertainty around the Ogden discount rate used to calculate personal injury compensation payments poses a material risk to some insurers, with two firms disclosing that the recent change required them to recapitalise significantly.
  • Firms must work harder to publish better quality QRTs, with over a quarter of the firms we reviewed disclosing QRTs containing obvious errors.
  • Some firms’ SFCRs are not fully compliant with the Solvency II regulations, with particular areas of weakness including disclosure around sensitivity testing of the SCR and uncertainty within technical provisions.

SFCR UK IRL

Click here to access LCP’s detailed survey analysis

EIOPA publishes first set of Solvency II statistics on the European insurance sector

Balance sheet structure, main items

Assets

The asset side of the Solvency II balance sheet is split into investments, assets held for unit-linked business and other assets. Investments represent those held by insurers in order to be able to fulfil the promises made to the policy-holder on an on-going basis. This excludes unit-linked business for which the investment risk is assumed by the policyholder. On an EEA wide basis, Figure 1 shows that the investment portfolio of insurers is dominated by bonds. Corporate and government bonds together account for more than 60% of the portfolio.

Figure 1: Investment mix by insurers in EEA following S.02 Balance sheet. 2016 Q3. %

Table 1 EIOPA

However, the investments shown in these figures represent only part of the balance sheet. There is also a considerable share of investments for unit-linked business. Table 1 shows the breakdown of total assets into three main categories (investments as shown above, assets held for unit-linked business and other assets). The share of unit-linked business (measured by assets) in the EEA was 21.9% in Q3-2016.

Table 1: Main categories of total assets by insurers in per country. 2016 Q3. EUR million and %

Tableau 1 EIOPA

Liabilities

Total liabilities consist of technical provisions and other liabilities. This is illustrated on an EEA level in the Figure below. Technical provisions represent the amount of resources to be set aside to pay policy-holder claims and are split into 5 main categories. Other liabilities include debt such as subordinated liabilities and financial liabilities other than debts owed to credit institutions, but also other liabilities such as, for example, deposits from reinsurers.

Figure 2: Liability profile insurers in EEA. 2016-Q3. %

Tableau 2 EIOPA

Premiums (Non-life)

One way of assessing market size is to look at the gross (i.e. before reinsurance) written premiums by country. The Figure below ranks the countries according to the gross premiums written by undertakings in their jurisdiction in the first 3 quarters of 2016. At this stage the figure shows only premiums in the non-life segment, since life premiums are not available for Q3-2016 on a consistent basis. There is an ongoing process to eliminate some national differences in reporting of life premiums.

Figure 3: Non-life GWP (gross written premiums) per country. 2016 Q3 Year to date.
Source: EIOPA [Solo/Quarterly/Published 20170628/Data extracted 20170614]. Excluding undertakings with non-standard financial year-end. Reinsurance premiums not included.

Tableau 3 EIOPA

Own funds and MCR/SCR ratios

Insurance undertakings are required by the Solvency II regulation to hold a certain amount of capital of sufficient quality in addition to the assets they hold to cover the contractual obligations towards policyholders. The amount of capital (called eligible own funds) required is defined by the Minimum Capital Requirement (MCR) and the Solvency Capital Requirement (SCR), which depend on the risks to which the undertaking is exposed.. If the amount of eligible own funds falls below the MCR, the insurance license should be withdrawn if appropriate coverage cannot be re-stablished within a short period of time. Holding enough eligible own funds to cover the SCR enables undertakings to absorb significant losses, even in difficult times. Undertakings’ compliance with the SCR therefore gives reasonable assurance to policyholders that payments will be made as they fall due.

The SCR is calculated either by using a prescribed formula (called the standard formula) or by employing an undertaking-specific partial or full internal model that has been approved by the supervisory authority. Being risk-sensitive the SCR is subject to fluctuations and undertakings are required to monitor it continuously, calculate it at least annually and re-calculate it whenever their overall risk changes significantly.

As non-compliance with the MCR jeopardizes policyholders’ interests, the MCR has to be re-calculated quarterly according to a given formula. The ratios shown in Table 2 are computed by dividing the respective eligible own funds by the SCR and MCR figures as reported by the insurance undertakings at the end of Q3 2016.

Table 2: MCR and SCR ratios by country. Weighted average and interquartile distribution. 2016 Q3

Table 2 EIOPA

Click here to access EIOPA’s Report