European insurers like the tone of EIOPA’s push to cut Solvency II reporting, yet they’re warning the execution risks missing the mark.
The draft Implementing Technical Standards (ITS) include positives, such as clearer transparency on how supervisory data gets used. That part is welcome.
But when you dig into the numbers, the story shifts. EIOPA projects a 26% cut in data points.
Insurers running the math say it’s closer to 10–15% once new templates, fresh reporting under the Insurance Recovery and Resolution Directive, and additional natural catastrophe disclosures are added.
The industry’s blunt view: that doesn’t feel like simplification, it feels like swapping one pile of paperwork for another.
Carolien Afslag, Senior Policy Advisor for Prudential Regulation, summed it up plainly: counting datapoints doesn’t equal cutting workload. Removing complexity does. Adding new layers disguised as simplification only moves the burden sideways.
EIOPA’s direction of travel is positive, but the reform must go further to deliver tangible relief for insurers. Counting data points alone does not capture the operational effort behind reporting.
Carolien Afslag, Senior Policy Advisor, Prudential Regulation
“Real simplification means removing complexity, not replacing it with new layers,” said Carolien Afslag, Senior Policy Advisor, Prudential Regulation.
Groups and financial stability reporting show little improvement under the draft, which insurers see as a gap. They want proportionality to stretch beyond just small or “non-complex” undertakings. Broader scope, they argue, would spread the relief more fairly across the market.
Another frustration sits with governance. The industry is calling for tighter coordination between EIOPA and the ECB.
ECB-related templates appeared late in the process, weren’t clearly outlined in taxonomy notes, and left insurers scrambling.
From their perspective, transparency means not just publishing data use, but avoiding last-minute additions that undercut planning.
We think the next round of revisions will be a test of whether EIOPA listens. Insurers are backing the direction, but patience runs thin when simplification reads like reshuffling instead of cutting. Europe’s insurance sector wants clarity, not more clever templates.
Insurers are pushing back against EIOPA’s claims of burden relief, pointing to gaps between estimated savings and the grind of implementation.
On paper, the authority projects a 26% reduction in data points. In practice, early testing suggests barely half that. New IRRD templates, plus fresh demands on pensions and natural catastrophes, eat into anticipated savings.
Add revisions to SFCR, RSR, liquidity, and sustainability reporting, and the so-called relief looks slim. Annual QRT savings drop to 10–15%, quarterly ones closer to 5–10%. The numbers fall short of the headline figure.
The measurement method itself is under fire. Counting templates and datapoints doesn’t track with the effort inside insurers’ systems. Even small tweaks can trigger costly IT updates.
The industry argues that wholesale template deletion delivers meaningful relief, not minor edits. QRT S.19 on non-life claims is a case in point. Small changes ended up creating outsize workload.
Group reporting barely benefits. Only one group template shrinks, while most deletions land at solo level. Undertakings inside groups feel no easing.
Meanwhile, financial stability reporting still overlaps Solvency II, forcing double work. The result: two sets of numbers for the same purpose, with higher thresholds but no less effort.
Proportionality is another sticking point. EIOPA ties it tightly to SNCUs, yet these undertakings cover only a sliver of the market.
Analysts argue the Commission’s 25% relief target can’t be met without spreading exemptions to smaller non-SNCUs or firms with simple profiles.
Climate templates like S.06.04 and new NatCat requirements could be cut by size or materiality, not just status. Without this, relief looks skewed and the level playing field suffers.
Timing is also on the table. The preferred option is aligning Taxonomy 2.10.0 with the Directive and Delegated Acts, meaning Q1 2027.
Running parallel taxonomies piles on cost. Insurers want a four-week extension for the Q1 2027 deadline and to skip templates already marked for deletion when filing 2026 annual reports. If EIOPA can delete them earlier, even better.
Some tweaks land well. Broader validation tolerances, longer gaps between ITS updates — both earn cautious support. The idea of centralised publication of SFCR QRTs gets nods too, but only if undertakings no longer have to prepare them at all.
Publishing from supervisory databases could free resources, though firms insist they must retain control over their published figures. Legal details here remain murky.
International players also call out currency lists. Interest rate coverage shrank, leaving insurers to build curves manually for currencies they still use. That’s not just busywork, it erodes comparability across firms.
Sustainability is another weight. Legal demands keep piling up. Rather than weaving new requirements into Solvency II, the market suggests bundling them into one framework.
A separate track avoids duplicate layers and aligns with existing disclosure regimes.
And then there’s the ECB. Additions slipped into later updates of Taxonomy 2.10.0 without clear notes, leaving firms puzzled. References to ECB Regulation 2014/50 were vague, links absent.
This lack of transparency rattles confidence. Industry remembers earlier phases, when ECB and EIOPA engaged directly — that style of dialogue, they say, should return.
The rollout of template E.05.01 on “Price of insurance” only deepened frustration. It landed without warning, with no guidance on scope.
Other templates, like SE.17.01.17 and SE.17.03.16, gained ECB fields but weren’t flagged as significant, making material updates harder to catch.
Clarity on all of this won’t arrive until PWD 2, slated for 2026. That’s a long time to wait, insurers argue, and uncertainty at this scale drives cost.
For them, simplification means fewer moving parts, not rebranded complexity. EIOPA says it’s cutting the burden, but insurers don’t yet feel lighter.
