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

From reconciling QRT submissions to internal model output across three Solvency II reporting cycles, the loss of asset look-through granularity is the cut that will force the most practical workflow change for actuarial and risk teams, even though the press summaries issued by law firms and trade associations have focused almost entirely on the technical provisions template changes. The reinsurance recoverables detail being removed from the quarterly cadence is a close second in impact, and together these two areas are where the reporting reform will actually land on a working actuary's desk.

The April 7 package is not a single rulemaking event but the beginning of a multi-year transposition process. The European Commission now has three months to review and endorse the ITS amendments before they pass to the European Parliament and Council for scrutiny. National supervisors (BaFin, ACPR, the Central Bank of Ireland, and the peer authorities across the EU 27) begin updating their supervisory reporting taxonomies this quarter, with the amended templates expected to be mandatory for the Q1 2027 reporting reference date and first submitted in the May 2027 filing window.

What EIOPA Actually Submitted on April 7

The April 7, 2026 package is a Final Report on the Implementing Technical Standards for supervisory reporting and public disclosure, published in parallel with a transmission letter to the European Commission. The package is the culmination of a consultation that opened in the second half of 2024 and received more than 220 stakeholder responses across trade associations, individual insurers, audit firms, and consultancies. Deloitte, EY, KPMG, PwC, and the Association of Mutual Insurers and Insurance Cooperatives (AMICE) were among the most active commenters, with the ABI, GDV, and Insurance Europe representing the carrier side.

The Final Report documents the templates that EIOPA has decided to retire, merge, or reshape, together with the reporting frequency changes on the templates that remain. The 26 percent figure that has dominated the press commentary covers the quarterly templates specifically; on an all-template basis (quarterly plus annual), the reduction is in the range of 15 to 20 percent depending on how one counts partial merges versus full retirements. EIOPA's own press materials frame the change as a reduction in "data items" rather than templates, with the cited number of data items removed or relocated running into the thousands across the template set.

Three design choices in the Final Report will matter most to actuarial reporting teams. First, the asset look-through reporting structure (currently captured primarily through S.06.02 and S.06.03) is being simplified, with fund-of-fund look-through detail moved to an annual frequency rather than quarterly. Second, the reinsurance recoverables detail on S.30 and S.31 is being consolidated, with quarterly submissions narrowed to a summary view and the full cession-by-cession detail moved to annual. Third, the technical provisions templates by line of business (S.17 for non-life, S.12 for life) are being reshaped with fewer data points required quarterly and a sharper annual view that combines several currently separate templates.

Why the Asset Look-Through Cut Matters Most

Asset look-through has been the most operationally demanding part of Solvency II quarterly reporting since the regime went live. For insurers with significant exposure to collective investment undertakings (CIUs) such as UCITS funds, AIFs, and segregated managed accounts, look-through means reporting the underlying holdings at the security level on a quarterly basis, translated into Solvency II asset categories and complementary identification codes (CICs). Insurers with concentrated investment management arrangements (for example those outsourced to a single asset manager) can automate the pipeline, but insurers with fragmented asset management, including most mid-sized European mutuals and many smaller composite insurers, rely on quarterly data sweeps from asset managers that are expensive to maintain.

Under the amended ITS, quarterly look-through is expected to shift to a summary aggregated view by asset class and counterparty tier, with full security-level look-through retained only on the annual filing. That change reduces the quarterly data payload materially. It also removes the quarterly feedback loop that many actuarial functions have relied on to identify drift in their SCR market risk calculation between formal quarterly SCR runs.

For internal model firms, the effect is sharper. Internal models are typically calibrated to underlying asset exposures (single-name equity volatility, sector beta, credit spread sensitivities by issuer tier), and the quarterly look-through has been the routine reconciliation point between the model's assumed exposure universe and the actual portfolio. Moving to annual look-through does not change the model calibration requirements (those remain under Article 121 of the Solvency II Directive), but it removes the default quarterly reconciliation from the regulatory reporting pipeline. Model validation teams will need to either build an internal quarterly look-through process or accept that their quarterly model output is reconciled only to the asset-class-level exposure data that remains in the quarterly templates.

Reinsurance Recoverables: The Second Quiet Cut

The second reporting change that the law firm alerts have largely missed is the reinsurance recoverables detail on S.30.02 and S.31.01. Under the current ITS, those templates capture quarterly detail on reinsurance arrangements including counterparty name, rating, Solvency II retention, and treaty characteristics. The amended ITS moves much of that cession-level detail to the annual filing, retaining only a counterparty-aggregated summary on a quarterly basis.

For cedents with large reinsurance programs (especially life reinsurance blocks where recoverables can exceed 20 percent of gross technical provisions), the quarterly submission has been the regulatory anchor that kept cession-level data disciplined. Moving that to annual has two knock-on effects. First, the counterparty default risk module of the SCR (Module C under the standard formula) depends on exposure-at-default by counterparty, and moving the underlying data to annual increases the risk that intra-year counterparty rating changes, dispute activity, or commutation events are not reflected in the quarterly SCR calculation. Second, the reinsurance recoverable balance tests that actuarial functions perform to validate the ceded best-estimate liability are easier to reproduce when the regulatory data is refreshed quarterly.

The working assumption among European actuarial directors appears to be that insurers will retain cession-level quarterly data internally for ORSA purposes even though it is no longer submitted to the supervisor. That is a reasonable working assumption, but it creates a divergence between internal management information and regulatory reporting that has not existed at this scale under Solvency II until now. Boards and audit committees should expect to receive explicit statements in the ORSA about how the carrier is maintaining visibility on reinsurance recoverables between annual filings.

Technical Provisions by Line of Business: The Headline Change

The press coverage has concentrated on the technical provisions templates because they are the most visible part of the reporting set and because the names of the retired templates are easy to list. Several of the S.17 (non-life) and S.12 (life) sub-templates are being consolidated, with duplicative data points across the SFCR and RSR layers being removed. The net effect for most insurers is that the technical provisions section of the quarterly submission moves from five or six separate sub-templates to two or three.

This change matters operationally but not strategically. The underlying best-estimate liability calculations, risk margin methodology, and technical provision audit trails are unchanged. What changes is the mapping from the carrier's reserving system output to the regulatory template structure. Carriers that have invested in flexible reporting tools (SAP Analytics Cloud, Oracle Financial Services Analytical Applications, Prophet, and the various insurance-specific reporting platforms) can redirect the data mapping without rebuilding the underlying actuarial process. Carriers still operating on legacy Excel-driven workflows for technical provisions reporting will find the template redesign a forcing function for longer-delayed modernization projects.

The ORSA interaction on technical provisions is worth flagging. Under Article 45 of the Solvency II Directive, the ORSA must include a forward-looking assessment of technical provisions under the insurer's own risk assessment, not just the regulatory view. If the regulatory quarterly view contains less technical provisions granularity after the ITS amendment, the ORSA writer should not take that as license to reduce the granularity of the forward-looking view. EIOPA has been explicit in recent supervisory letters that the ORSA is the insurer's own view, and the simplification of regulatory reporting does not simplify the ORSA requirements.

The NatCat Adaptation Measures Consultation: A Structural Capital Shift

Running in parallel with the ITS package is an EIOPA consultation on natural catastrophe adaptation measures, which closes on April 17, 2026. The consultation proposes to allow insurers to reflect physical risk mitigation measures (for example flood defences, wildfire-resistant building standards, or parametric hedging arrangements) in the standard formula SCR calculation for the natural catastrophe risk module. That would mark the first time the standard formula explicitly incorporates adaptation measures as capital relief, rather than capturing them only through internal models.

For standard formula users, the consultation is materially important because it would change the SCR capital number for cat-exposed portfolios with meaningful adaptation investment. Retail property insurers in flood-exposed regions (the UK, the Netherlands, parts of Germany, the Rhône Valley in France), wildfire-exposed portfolios in southern Europe, and insurers with parametric hedging arrangements on specific perils would all benefit from a standard formula that rewards adaptation. For internal model firms, the consultation is less directly binding but still relevant because internal model approvals are benchmarked against the standard formula under Article 101(3), and a more adaptation-sensitive standard formula will reshape the benchmarking exercise.

Internal Model Validation: Where the Cuts Bite

Internal model validation has always been the most labor-intensive part of a Solvency II internal model firm's annual calendar. Under the Guidelines on Validation (EIOPA-BoS-14/259, most recently updated in 2021), firms must document sensitivity testing, back-testing, stress testing, profit and loss attribution, and statistical quality tests on the model output. Much of that documentation has historically leaned on the quarterly regulatory reporting data as the external reference point against which internal model output is benchmarked.

When the quarterly reference set narrows, validation teams face a choice. They can either continue to build the quarterly benchmark internally (duplicating the data pipeline that used to feed the regulatory templates) or they can move to annual-only benchmarking and rely on intra-year monitoring that uses less granular data. In my experience, firms that have high-quality model point reconciliation and well-disciplined data lineage will preserve the quarterly internal benchmark and use the reporting simplification as a cost pressure point against the regulatory returns function. Firms that are already under resource pressure on their validation function may quietly let the quarterly benchmark lapse, which is precisely the outcome that EIOPA's prudential supervisors will want to monitor through the annual validation reports.

The specific validation tests most affected by the ITS change are:

• Profit and loss attribution. P&L attribution tests decompose actual profit and loss into the risk drivers that the internal model recognises. The asset-side component of that attribution has historically drawn on quarterly look-through data to separate effects by issuer, sector, and duration bucket. With annual-only look-through, the quarterly P&L attribution will need to rely on internally maintained data.
• Back-testing of market risk SCR. The one-year 99.5 percent SCR for market risk is tested against realised portfolio returns. When the regulatory reporting captures the underlying exposures only annually, the back-testing exercise either uses annual snapshots (losing statistical power) or relies on internally maintained quarterly data.
• Statistical quality tests on reinsurance recoverables. The counterparty default sub-model depends on exposure-at-default by counterparty rating bucket. Annual-only cession-level data reduces the statistical richness of the validation sample for this sub-module.
• Standard formula benchmarking. Article 101(3) requires internal models to be benchmarked against the standard formula in specified cases. When the regulatory quarterly data is simplified, benchmarking against peer data becomes harder because EIOPA's own peer analytics (the quarterly supervisory data hub) will be working with the reduced data set.

ORSA Governance Implications

Article 45 of the Solvency II Directive requires every insurer to perform its own risk and solvency assessment (ORSA) on at least an annual basis, with additional ORSAs triggered by material changes in the risk profile. The ITS amendments will not change the ORSA legal requirements directly, but they create a substantive governance question for the actuarial function holder (AFH).

The AFH is typically the senior actuary with formal responsibility for the reliability of technical provisions and the opinion on underwriting policy and reinsurance adequacy. Under Article 48 of the Directive, the AFH role is distinct from the chief actuary or head of reserving and carries explicit governance weight. When the regulatory reporting granularity decreases, the AFH faces a choice that should be made explicitly at the board or board risk committee level: does the carrier retain the granular data internally as part of its own risk management, or accept the reduced granularity as the new management-information norm?

Three governance artefacts should be updated in response to the ITS simplification:

1. The ORSA Policy. The policy document governing the ORSA process should reference the data sources used and explicitly state what is retained internally beyond the regulatory quarterly view. If the carrier is maintaining asset look-through quarterly internally even though the supervisor no longer requires it, that decision should be documented in the policy rather than left as an operational practice.
2. The Data Quality Policy. EIOPA's guidelines on the valuation of technical provisions (EIOPA-BoS-14/166) require a data quality framework that covers the data supporting both regulatory reporting and the ORSA. A reduction in regulatory reporting scope should not automatically reduce the scope of the data quality framework if the underlying data is still used for internal purposes.
3. The Risk Appetite Statement. Boards should consider whether the risk appetite statement needs to make explicit reference to the granularity of market risk and counterparty default monitoring. If the board's risk appetite framework relies on a quarterly view of asset look-through or counterparty exposure concentrations, that reliance should be made explicit rather than embedded in an assumption that regulatory reporting will always provide the relevant view.

Third-Country Comparisons: UK, Switzerland, and Bermuda

One of the more consequential strategic questions raised by the EIOPA ITS package is how it compares with the parallel supervisory regimes in the UK, Switzerland, and Bermuda. Since the UK's divergence from Solvency II through Solvency UK (announced in 2023 and operationalised through 2024 and 2025), the three European-adjacent reporting regimes have been pulling in different directions.

Jurisdiction	Reporting framework	Simplification trajectory	Key contrast
EU 27	Solvency II ITS (QRTs, SFCR, RSR)	~26% of quarterly templates retired in April 2026 package, effective Q1 2027	Largest reporting simplification since regime launch
UK	PRA Insurance Rulebook (Solvency UK)	Matching adjustment reform and reporting simplification phased 2024-2026	Focused on risk margin reduction and matching adjustment expansion, not volume-based template cuts
Switzerland	Swiss Solvency Test (FINMA)	Stable; FINMA updated SST reporting in 2024 with moderate granularity increases	Diverging toward greater granularity, not less
Bermuda	BMA Economic Balance Sheet and EBS Schedule of Reinsurance	Enhanced long-term reinsurance reporting finalised 2023-2024; further tightening expected	Moving toward greater transparency on asset-intensive reinsurance

The divergence is strategically important for multinational groups. A group with insurance operations in the EU, UK, and Switzerland now faces three meaningfully different reporting regimes that will not converge in the near term. The EU simplification reduces the cost of EU reporting but increases the relative cost of the UK and Swiss regimes, which will continue to require the granular data that the EU is retiring. In practice, groups with EU subsidiaries and UK or Swiss parents will need to maintain the more granular data set for the non-EU entities and cannot harvest the full cost savings that the EU simplification appears to offer.

The Bermuda comparison is particularly relevant for asset-intensive life reinsurance, where the BMA has been tightening scrutiny of the reserves backing long-term reinsurance. As we covered in the Bermuda reinsurance analysis, the BMA's enhanced Schedule of Reinsurance disclosures run in the opposite direction from the EIOPA simplification. EU cedents with material reinsurance recoverables to Bermuda counterparties will continue to need the cession-level data for their own counterparty monitoring, even as the EU template requirement moves to annual.

Transposition Mechanics: What Happens Next

The April 7 transmission to the European Commission is the first step in a legal process that has several more stages before carriers see the amended templates in production.

The European Commission has three months to decide whether to endorse the ITS amendments. Under Regulation (EU) 1094/2010 (the EIOPA founding regulation), the Commission can endorse, partially endorse, or reject the ITS. In practice, partial endorsement is rare for reporting ITS because the templates are technical documents and the Commission's policy levers are limited. Assuming endorsement by early July 2026, the ITS then passes to the European Parliament and Council for a three-month scrutiny period, during which either body can object. Assuming no objection, the ITS is published in the Official Journal and enters into force twenty days later.

The realistic timeline therefore runs:

• April 7, 2026. EIOPA transmits the ITS to the Commission.
• July 2026. Commission endorsement (expected).
• October 2026. End of Parliament and Council scrutiny (expected, assuming no objection).
• November 2026. Publication in the Official Journal and entry into force.
• Q1 2027 reference date. First quarterly submission under the amended templates, filed in May 2027.
• Year-end 2027 reference date. First annual submission under the amended templates, filed in the May 2028 window.

That timeline gives actuarial reporting teams roughly six months between the formal entry into force and the first live reference date. National supervisors typically update their local data taxonomies (DPM, XBRL) in parallel with the EU legal process, and most supervisors will expect a dry run of the amended templates with the year-end 2026 data before the Q1 2027 live submission.

What Actuarial Reporting Teams Should Do Now

The practical work for Q2 and Q3 2026 falls into five workstreams.

Inventory the affected templates. The first step is to produce a carrier-specific map of which current templates are affected by the ITS amendment, which data points will be retired, and which will be moved from quarterly to annual frequency. That map is the foundation for all subsequent workstreams and should be reviewed by both the reporting team and the actuarial function holder.

From tracking similar simplification exercises in the past, the biggest risk in this step is assuming that the templates named in the press commentary are the only ones affected. The reality is that the ITS amendment touches secondary templates (asset concentration, duration mismatches, liquidity metrics) as well as the headline technical provisions and reinsurance templates. A comprehensive inventory is worth the effort.

Decide the internal retention strategy. For each data point being removed from quarterly reporting, the carrier should decide whether to retain the data internally at the same frequency, move to annual, or abandon it. That decision should be logged centrally, signed off by the actuarial function holder, and referenced in the ORSA.

Update the internal model validation plan. Internal model firms should update their annual validation plan to account for the reduced quarterly regulatory reference set. That includes identifying the validation tests most affected (P&L attribution, market risk back-testing, counterparty default sub-module) and specifying the internal data sources that will replace the retired regulatory data.

Engage with the asset manager community. For insurers with meaningful CIU and AIF exposure, the asset manager side of the look-through pipeline is the most expensive part of quarterly reporting to maintain. Carriers should engage with their asset managers in Q3 2026 to discuss whether the reporting simplification means the quarterly look-through data feed can be reduced (and the corresponding fee renegotiated), or whether the carrier prefers to continue receiving the full look-through feed for internal purposes.

Brief the board and risk committee. The reporting simplification is not a routine operational change. Boards should receive a single briefing in Q2 or Q3 2026 that covers the scope of the ITS amendment, the carrier's retention strategy, the ORSA governance implications, and the comparison with the UK, Swiss, and Bermuda regimes for multinational groups. That briefing does not need to be long, but it should be documented and revisited at year-end.

The Broader Direction of Travel

The April 7 package fits into a larger pattern in European insurance supervision. EIOPA under its current chair has been explicit about the priority of reducing non-prudential reporting burden while holding prudential standards firm. The ITS simplification is the most visible expression of that strategy in the reporting domain. Running in parallel, the Review of Solvency II (the legislative review that produced the Delegated Regulation amendments applied from early 2025) has recalibrated the standard formula in areas including interest rate risk, symmetric adjustment, and the volatility adjustment. The natcat adaptation consultation continues that trajectory by pushing physical risk into the standard formula capital calculation explicitly.

The net result for actuarial functions across the EU is a regime that is modestly easier to report under but somewhat harder to capitalise for, especially on physical climate risk and long-term reinsurance recoverables. The simplification is not a deregulatory drift; it is a reallocation of effort from routine reporting machinery toward the areas where EIOPA considers the prudential risk to concentrate.

For the UK and Swiss supervisors, the EIOPA reform creates a policy pressure point. Both supervisors have been monitoring how their regimes compare with the EU on reporting burden, with UK industry bodies in particular arguing that Solvency UK should match or exceed the EU simplification. How the PRA responds in the 2026-2027 cycle will be an important signal for whether the UK continues to diverge on a case-by-case basis or consolidates its reforms into a more systematic simplification package.

Why This Matters

The EIOPA reporting ITS is the largest Solvency II reporting simplification since the regime launched ten years ago. For the European insurance industry, it represents a real cost reduction in regulatory reporting operations and a genuine reallocation of effort toward the areas where prudential supervision is tightening. For actuarial functions specifically, the asset look-through and reinsurance recoverables cuts are the operationally consequential changes, even though the press commentary has focused on the more visible technical provisions templates. Internal model firms face the sharpest impact, with validation frameworks needing to be updated to reflect the reduced quarterly regulatory reference set.

The transposition process gives carriers most of 2026 to prepare. The practical work involves mapping the affected templates, deciding which data to retain internally, updating the validation plan, engaging with asset managers, and briefing the board. Groups with UK or Swiss operations need to maintain the more granular data set for those jurisdictions and cannot realise the full cost savings that the EU simplification appears to offer.

The EIOPA reform is not a standalone event. Read alongside the natcat adaptation consultation closing April 17 and the continued internal model validation expectations from EIOPA and national supervisors, the reporting simplification is part of a broader reallocation of prudential supervisory effort. The actuarial functions that treat the simplification as a cost-saving opportunity without redeploying the saved capacity into climate capital work and validation modernisation will find themselves under pressure from supervisors by 2028 at the latest. Those that read the reform as a reallocation rather than a reduction will be positioned for the supervisory cycle that follows.

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