EIOPA Cuts 26% of QRTs: The Solvency II Reporting Reset for 2027

Commentary has concentrated on the technical provisions templates, which are the most visible part of the set. The change that lands hardest on an actuarial desk is the asset look-through cut.

Key Takeaways

• The 26% figure covers quarterly templates only; on an all-template basis the reduction runs 15% to 20% depending on how partial merges are counted.
• Security-level asset look-through moves from quarterly to annual, with the quarterly filing narrowing to a summary by asset class and counterparty tier.
• Cession-level reinsurance recoverables detail on S.30.02 and S.31.01 also moves to annual, retaining only a counterparty-aggregated quarterly summary.
• Internal model calibration requirements under Article 121 are unchanged, so the reconciliation the quarterly filing used to supply now has to be built internally or given up.
• Bermuda and Switzerland are moving toward more granularity, not less, so cross-border groups keep the higher standard regardless.

What the April 7 Package Contains

The Final Report closes a consultation opened in the second half of 2024 that drew more than 220 stakeholder responses, with Deloitte, EY, KPMG, PwC and AMICE among the most active commenters and the ABI, GDV and Insurance Europe representing carriers.

The 26% headline covers quarterly templates specifically. Counting quarterly and annual together, the reduction falls to 15% to 20% depending on whether a partial merge counts as a retirement. EIOPA frames the change in data items removed or relocated rather than templates, running into the thousands across the set.

Three design choices carry most of the operational weight. Asset look-through, currently captured mainly through S.06.02 and S.06.03, is simplified, with fund-of-fund detail moved to annual. Reinsurance recoverables detail on S.30 and S.31 is consolidated, with quarterly narrowed to a summary view. And the technical provisions templates by line of business, S.17 for non-life and S.12 for life, are reshaped with fewer quarterly data points, taking most insurers from five or six sub-templates to two or three.

Process runs long from here. The Commission has three months to review and endorse before Parliament and Council scrutiny, while BaFin, ACPR, the Central Bank of Ireland and the other national supervisors update their reporting taxonomies.

The Cut Removes a Reconciliation, Not Just a Filing

Look-through has been the most operationally demanding part of quarterly reporting since the regime went live. For an insurer holding collective investment undertakings, it means reporting underlying holdings at security level each quarter, mapped into Solvency II asset categories and complementary identification codes. Insurers with a single outsourced manager can automate it; those with fragmented arrangements, which is most mid-sized European mutuals and many smaller composites, run expensive quarterly data sweeps.

Removing that requirement removes real cost. It also removes the diagnostic that came with it. Market risk SCR is highly sensitive to the composition beneath a fund wrapper, and the quarterly filing has been the near-real-time check on whether manager decisions shifted the underlying risk profile in ways that would appear at the next recalculation. Moving it to annual makes the market risk diagnostic a year-end exercise in practice, with intra-year drift visible only when the full recalculation runs.

For internal model firms the loss is sharper. Models are calibrated to underlying exposures, single-name equity volatility, sector beta, credit spread sensitivity by issuer tier, and the quarterly look-through has been the routine reconciliation between the model's assumed exposure universe and the actual portfolio. Article 121 calibration requirements do not change, so the obligation survives the data that fed it. Validation teams either build an internal quarterly look-through or accept that quarterly model output reconciles only to asset-class-level exposures.

The reinsurance change works the same way. Cession-level detail on S.30.02 and S.31.01, including counterparty name, rating, retention and treaty characteristics, moves to annual. The counterparty default risk module of the standard formula depends on exposure at default by counterparty, so intra-year rating migrations, disputes and commutations may sit outside the quarterly SCR until the annual filing catches them. For life blocks where recoverables can exceed 20% of gross technical provisions, that is a material share of the balance sheet reconciled once a year.

The Data Falls Away Faster Than the Obligation

The working assumption across European actuarial functions is that carriers will keep cession-level and security-level data internally for ORSA purposes even though the supervisor no longer asks for it. That assumption holds at first and erodes on a predictable schedule.

Prior simplification cycles, the 2018 IFRS 9 reporting rationalization among them, show the pattern: granular data is retained internally for one to two years, then scaled back as cost pressure accumulates, until internal granularity converges on whatever the regulator requires. Nothing in this package changes the incentive that produces that convergence, and the firms least able to absorb the retention cost are the fragmented mid-sized insurers for whom the quarterly sweep was expensive in the first place. The simplification lands hardest, in both directions, on the same population.

That creates a divergence between management information and regulatory reporting on a scale Solvency II has not carried before. Boards and audit committees should expect explicit ORSA statements on how the carrier maintains visibility on reinsurance recoverables and underlying asset exposures between annual filings, because the alternative is a governance record that treats an annual reconciliation as continuous oversight.

The jurisdictional picture removes the saving for the largest firms entirely. The UK's reforms have targeted the risk margin and matching adjustment rather than template volume. FINMA updated Swiss Solvency Test reporting in 2024 with moderate granularity increases. The Bermuda Monetary Authority tightened long-term reinsurance reporting through 2023 and 2024 with further tightening expected. A group writing across the EU, Bermuda and Switzerland therefore maintains security-level and cession-level pipelines for its non-EU obligations whatever EIOPA asks for, and captures none of the promised relief. The reduction reaches the mid-sized single-jurisdiction insurer, which is the firm whose diagnostic capacity depended on the filing most.

Further Reading

• IFRS 17 Implementation 2026 – How the first year of IFRS 17 filings is reshaping financial reporting for European insurers, and how the IFRS 17 and Solvency II reporting layers interact.
• LDTI (ASU 2018-12) Guide – The US GAAP parallel to IFRS 17 for long-duration contracts, useful context for multinational life groups managing both regimes alongside Solvency II.
• ASOPs 2026 Update – Current Actuarial Standards of Practice revisions, including model governance and reinsurance adequacy opinion requirements that parallel the EU Article 48 actuarial function role.
• Bermuda Reinsurance: Private Credit and War Risk in 2026 – The BMA's enhanced reinsurance disclosure regime, diverging from the EIOPA simplification and adding pressure to EU cedents on Bermuda counterparties.
• NAIC Weighs Jump from AI Bulletin to Enforceable Model Law – The US regulatory parallel to the EU's tightening of model validation expectations, useful context for multinational groups.

Sources

• EIOPA Publications Archive
• EIOPA: Solvency II Regulation and Policy
• EIOPA: Supervisory Reporting
• EIOPA: Open and Closed Consultations (NatCat Adaptation Measures)
• EU Commission: Delegated Regulation (EU) 2015/35 (Solvency II Delegated Acts)
• EU Commission: Directive 2009/138/EC (Solvency II Directive)
• BaFin: Insurance Supervision
• ACPR (France): Insurance Supervision
• Bank of England PRA: Insurance Publications
• FINMA: Insurance Supervision
• Bermuda Monetary Authority: Insurance Supervision
• Insurance Europe
• AMICE: Association of Mutual Insurers and Insurance Cooperatives