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European Insurance and Occupational Pensions Authority

2458

Q&A

Question ID: 2458

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Topic: Reporting Templates

Article: Article 35 of SII Directive

Template: S.02.01

Status: Final

Date of submission: 07 Jul 2022

Question

We are an insurance company that will adopt IFRS 17 next year, and we have some questions regarding the implementation. IFRS 17 is conceptually based on a prospective cash view. All expected future cash flows arising from the contract are considered and reflected in one position, the insurance contract asset or liability. There is only a distinction between received and future cash flows. If future cash flows are due or not, it does not make a difference from IFRS 17 perspective. Also deferred acquisition costs are not presented as a different line item, but are a (negative) component of the liability for remaining coverage. Generally, an entity shall include in the measurement of a group of insurance contracts all the future cash flows within the boundary of each contract in the group. Those future cash flows include, inter alia: • premiums expected to be received (premiums receivables) and claims and expenses expected to be paid, for insurance contracts; • premiums expected to be paid and claims expected to be received, for reinsurance held. The future premiums need to be accounted for the future cash flows until they are actually paid (i.e. on a cash basis) and not only until they are due (i.e. on a accrued basis).Therefore, the measurement of the insurance contract asset or liability under IFRS 17 is affected by the receipt of premiums and for liabilities should reflect the risk of non-payment of premiums by policyholders. This is because the insurance contract asset or liability reflects the financial position resulting from an entity’s rights and obligations at the reporting date. Above means that past due date (re)insurance receivables and payables, which for Solvency II purposes are measured and presented separately from provisions, need to be included within cash flows estimations under IFRS 17. This raises a question how to fill in S.02.01 (MVBS), column C0020 (statutory accounts), row R0020 (Deferred acquisition costs), row R0360 (Insurance and intermediaries receivable), row R0370 (Reinsurance receivables), row R0820 (Insurance & intermediaries payables) and row R0830 (Reinsurance payables) under IFRS 17 – shall all of them be set to nil?

Background of the question

IFRS 17.33. An entity shall include in the measurement of a group of insurance contracts all the future cash flows within the boundary of each contract in the group (see paragraph 34). Applying paragraph 24, an entity may estimate the future cash flows at a higher level of aggregation and then allocate the resulting fulfilment cash flows to individual groups of contracts. […] IFRS 17.34. Cash flows are within the boundary of an insurance contract if they arise from substantive rights and obligations that exist during the reporting period in which the entity can compel the policyholder to pay the premiums or in which the entity has a substantive obligation to provide the policyholder with insurance contract services (see paragraphs B61–B71). A substantive obligation to provide insurance contract services ends when: (a) the entity has the practical ability to reassess the risks of the particular policyholder and, as a result, can set a price or level of benefits that fully reflects those risks; or (b) both of the following criteria are satisfied: (i) the entity has the practical ability to reassess the risks of the portfolio of insurance contracts that contains the contract and, as a result, can set a price or level of benefits that fully reflects the risk of that portfolio; and (ii) the pricing of the premiums up to the date when the risks are reassessed does not take into account the risks that relate to periods after the reassessment date. IFRS 17.35. An entity shall not recognise as a liability or as an asset any amounts relating to expected premiums or expected claims outside the boundary of the insurance contract. Such amounts relate to future insurance contracts.

EIOPA answer

EIOPA agrees that for IFRS 17 users, row R0020 (Deferred acquisition costs), row R0360 (Insurance and intermediaries receivable), row R0370 (Reinsurance receivables), row R0820 (Insurance & intermediaries payables) and row R0830 (Reinsurance payables) / C0020 in S.02.01 should be nil​.