Question ID: 914
Regulation Reference: Guidelines on reporting and public disclosure
Article: 303, 307, 308, 364
Status: Final
Date of submission: 16 Dec 2016
Question
Should comparative information be provided in the first RSR narrative report for 2015, above the 1st Day reporting?
I.e. comparison between Solvency II and earlier regulation/period 2015, should be made for the policy for internal control (art. 308.5.c) and policy internal audit function (art 308.6.b)?
And for underwriting result divided by line of business (art 307.2.a) and investment result 307.3.a).
Please note that corresponding disclosure according to comparison with 2015, for underwriting and investment performance, are exempted article 303 and 364.
For the SFCR report “Where a comparison of the information with that reported on the previous reporting period is required in accordance with this Chapter, insurance and reinsurance undertakings shall comply with such a requirement only where the previous reporting period covers a period after the date of application of Directive 2009/138/EC..” (Article 303).
EIOPA answer
Although there is no specific rule for the RSR, when comparative information is requested under the RSR, the same principles as laid down in article 303 and 364 of the Delegated Regulation for SFCR should be followed, i.e. insurance and reinsurance undertakings shall comply with such a requirement only where the previous reporting period covers a period after the date of application of Directive 2009/138/EC.
However please note that there is a difference between comparative information and any significant changes during the reporting period. Concretely:
References to article 308 (5) and 308 (6) refer to the inclusion of any significant changes during the reporting period. In this case, it is expected that this is reported already in the first RSR;
References to article 307 (2) and (3) refers to comparison of the information with that reported on the previous reporting period and the reasons for any material changes, it is expected that this is not required in the first RSR (following the principle above);
References in article 307 (2) and (3) to projections performed before entering into force of Solvency II should not lead to a re-calculations of the projections as of day one.
Any comparison of solvency capital requirements could be done using day 1 calculations.