EIOPA has published the expected follow up guidance on timelines for reporting and disclosure during the Covid-19 situation. It stressed the need for National Competent Authorities to give delays on required reporting to alleviate pressure on insurance and reinsurance firms. The guidance sets out three recommendations for delays to annual year-end reporting, quarterly reporting and the Solvency and Financial Condition Report (SFCR) Reporting.
EIOPA has recommended an eight-week delay for firms in submitting the annual year end reporting (which for Ireland, was due with CBI by 7th April) at both Group and Solo levels. There are however some exceptions to this, for which EIOPA suggests only a two-week delay:
Group
1.Content of the Submission (S.01.01)
2.Basic Information (S.01.02)
3.Balancesheet (S.02.01), LTG (S.22.01)
4.Own funds (S.23.01)
5.SCR calculation (S.25.01 to S.25.03)
6.Undertakings in the scope of the group (S.32.01)
Solo
1.Content of the Submission (S.01.01)
2.Basic Information (S.01.02)
3.Balancesheet (S.02.01)
4.Cash-Flow projections for life business (S.13.01)
5.LTG (S.22.01)
6.Own funds (S.23.01)
7.SCR calculation (S.25.01 to S.25.03)
For those firms who have quarterly reporting responsibilities and reporting for Q12020 end occurring on 31 March 2020 or after that date but before 30 June 2020, EIOPA recommends a one-week delay in the submission of the Quantitative Reporting Templates and the Quarterly Financial Stability reporting both at solo and group level. The exception to this is the Derivatives Transactions (S.08.02) in the Quantitative Reporting Templates, which should EIOPA suggests should have a four-week delay.
For the Solvency and Financial Condition Report referring to year-end occurring on 31 December 2019 or year-end after that date but before 1 April 2020, EIOPA recommends an eight-week delay for publication with the exception of the following sections, for which it recommends a two-week delay:
1.Balance-sheet (S.02.01)
2.LTG (S.22.01)
3.Own funds (S.23.01)
4.SCR calculation (S.25.01) using the templates as identified in Commission Implementing Regulation (EU) 2015/24523 both at solo and group level.
EIOPA also flagged that insurance and reinsurance firms should consider the current situation as a “major development” as referred to in article 54(1) in the Solvency II Directive and publish at the same time of publication of the information referring to the year-end occurring on 31 December 2019 or after, any appropriate information on the effect of the Coronavirus/COVID-19 in the published information.
Should you have any questions relating to this, please contact Jacqueline Thornton (Jacqueline.thornton@insuranceireland.eu)