CBI to extend annual and quarterly reporting deadlines

The Central Bank of Ireland (CBI) has decided to extend deadlines for a number of annual and quarterly reports and public disclosures for (re)insurers under its supervision.

The European Insurance and Occupational Pensions Authority (EIOPA) recommended that national supervisory authorities exercise a degree of supervisory flexibility for upcoming reporting and disclosure deadlines for (re)insurers. Recognising the operational difficulties some (re)insurers are currently facing amid the ongoing COVID-19 pandemic, the CBI decided to extend deadlines on some of the reporting requirements. These measures will be available to all (re)insurers but the Central Bank encouraged those in a position to meet the existing reporting and disclosure deadlines to continue to do so.

In summary, the measures cover the following areas:

  1. Annual reporting: Either a two-week or an eight-week extension in deadlines, with an expectation that the impact of COVID-19 be discussed in the Solvency and Financial Condition Report (SFCR) for most (re)insurers.
  2. Quarterly reporting: A one-week extension for most templates, noting that this will be the first submission to reflect the impact of COVID-19 on the financial position of (re)insurers. As such the CBI is encouraging early submissions and is emphasising that the Own Funds template (S.23.01) should include an estimation of the Solvency Capital Requirement (SCR) for the end of the quarter reference date.

These measures are described in more detail below.

Annual reporting for undertakings with a financial year-end between 31 December 2019 and 31 March 2020 (inclusive)

The range of deadline extensions the CBI will implement is split out below.

Quantitative Reporting Templates

  • The submission of the following Quantitative Reporting Templates (QRTs) is extended by two weeks:
    • Content of the submission (S.01.01)
    • Basic information (S.01.02)
    • Balance-sheet (S.02.01)
    • Cash flow projections for life business (S.13.01)
    • Long-term guarantees (S.22.01)
    • Own Funds (S.23.01)
    • SCR calculation (S.25.01, S.25.02 or S.25.03)
  • All other annual QRT deadlines have been extended by eight weeks.
  • Where a split submission is provided, the second submission must contain all QRTs, including those already submitted at the earlier deadline.
  • The CBI will accept situations where the QRTs are completed in advance of the submission of the associated accuracy statement or completion of an Actuarial Opinion on Technical Provisions (AOTP), which are now both accepted with delayed deadlines as set out below. Where the completion of the accuracy statement results in a restatement of the QRTs, the CBI will consider these resubmissions as the only submission from the undertaking.

Solvency and Financial Condition Report

  • The key quantitative disclosures from the Solvency and Financial Condition Report (SFCR) may be published, and submitted to the Central Bank, up to two weeks after the publication deadline (including completion of audit requirements within this time). These key disclosures include:
    • Balance-sheet (S.02.01)
    • Long-term guarantees (S.22.01)
    • Own Funds (S.23.01)
    • SCR calculation (S.25.01)
  • The final SFCR may be published and submitted to the CBI up to eight weeks after the publication deadline.
  • Undertakings are required to disclose appropriate information on the nature and effects of any major developments. The CBI expects that the current COVID-19 pandemic will be considered a major development to the majority of (re)insurance undertakings. It is expected then that the SFCR mentioned above should include disclosures related to COVID-19 impacts.

Regular supervisory report

  • The regular supervisory report (RSR) deadline has been extended by eight weeks for both full RSR submissions and summary reports for material changes.

Other submissions

  • The AOTP associated with the annual QRTs may be submitted up to two weeks after the submission deadline.
  • There is no change to the submission process associated with the actuarial report on technical provisions (ARTP), which supports the AOTP and is only submitted at the request of the CBI. However, the CBI will be conscious of the current situation when issuing any requests for ARTPs or the associated Peer Review Report.
  • The directors’ accuracy statements supporting annual QRTs and the RSR together with the compliance statements required under section 25 of the Central Bank Act 199 may be submitted up to eight weeks after the submission deadline.
  • Note that, where the CBI has issued a request for an undertaking using a (partial) internal model to submit an additional estimate of the SCR determined using the standard formula, this estimate may be submitted eight weeks after the deadline.

Quarterly reporting for undertakings with a financial quarter-end on or after 31 March 2020 but before 30 June 2020

This upcoming quarter will be the first to reflect the impact of COVID-19 on the financial position of (re)insurers. As such the CBI is encouraging early submissions and is emphasising that the Own Funds template (S.23.01) should include an estimation of the SCR for the end of the quarter reference date. The CBI has also said that, if necessary, undertakings may consider a proportionate approach to less material aspects of the calculations while still focusing on the overall accuracy of the submission.

The timetable for quarterly QRTs has also been extended:

  • Most quarterly QRTs may be submitted up to one week after the submission deadline.
  • The closed derivatives template (S.08.02) may be submitted up to four weeks after the submission deadline.
  • Where a split submission is provided the second submission must contain all QRTs, including those already submitted at the earlier deadline.

Before using any of these extensions, it is worth confirming that your company has been formally notified of the availability of the extensions or contacting your desk officer if no notification was received.

A complete summary of the new reporting deadlines is given in this exhibit:

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