Question ID: 3593
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Topic: Narrative Reporting, Public Disclosure, Disclosure Templates
Status: Final
Date of submission: 11 Jun 2026
Question
Could EIOPA clarify the applicable language requirements for these disclosures? Specifically, is it permissible to publish both the policyholder-oriented SFCR summary and the full SFCR in English, or must the summary SFCR be published in the local language of the respective Member State? If local-language publication requirements apply, should insurers expect a harmonised EU approach, or will the language requirements need to be confirmed with each national supervisory authority individually?
Background of the question
With the Solvency II review amendments becoming applicable from 2027, insurers will be required to publish both the new policyholder-oriented SFCR summary and the full SFCR.
EIOPA answer
Currently the language requirements refer only to the group and single Solvency Financial and Condition Report (SFCR) where according to Article 360 and respectively Article 366 of Delegated Regulation 2015/35 group/single SFCR shall be disclosed in the language or languages determined by the group supervisor with the possibility to also disclose the report in another language most commonly understood by the other supervisory authorities concerned, as agreed in the college of supervisors.
There are no language requirements of the insurance and reinsurance undertaking's SFCR (solo SFCR). Hence, the language of the SFCR is subject to the requirements set out in the national law of the respective Member State either explicitly with regard to the SFCR or according to generally applicable rules.
With the Solvency II review the general language requirements of the solo SFCR have not been changed by Commission Delegated Regulation (EU) 2026/269. However, additional clarifications regarding the part of the solvency and financial condition report targeted at policy holders and beneficiaries have been introduced in Articles 292(1) and 298a of Commission Delegated Regulation (EU) 2026/269.
Furthermore, recital 45 explains the rationale behind these Articles and clarifies that that part of the SFCR should be made available upon request from policyholders from another Member State in the languages used by the insurance or reinsurance undertaking in its operations under the freedom of establishment or the freedom to provide services in that Member State.
Against this background, the solo SFCR including its two parts will continue to be published in the same language(s) as under the current requirements of Solvency II.
Regarding the new language requirements of the single SFCR please consult Article 366 of Commission Delegated Regulation (EU) 2026/269 and for the group SFCR Article 374.
EIOPA advises to discuss any related questions with the relevant National Competent Authority.