Implementing Technical Standards (ITS) amendments on Supervisory Reporting & Public Disclosure under Solvency II

The proposed amendments will undergo public consultation from July to October 2025, with final submission to the European Commission expected in March 2026. If adopted, the changes will come into effect in January 2027.

What are the proposed ITS Amendments?

The proposed amendments include a series of updates aimed at both introducing new data requirements and reducing the overall reporting burden. All template updates will impact life insurers, with the exception of templates S.16 (Information on annuities stemming from non-life insurance obligations), S.19 (Non-life insurance claims), and the new natural catastrophe (Nat Cat) templates, which are specific to non-life insurers. Updated guidelines and proportionality measures will need to be reviewed by all firms.

1. New Data Requirements

EIOPA proposes enhancements to pension data reporting by modifying Template S.14.01.01.02 (Life Obligations Analysis). This update introduces two additional columns to distinguish between occupational and personal pensions. As a result, the ECB template E.02.16 will be discontinued.

For natural catastrophe data, two new templates will be introduced for annual reporting. These templates will collect claims and exposure data at the CRESTA level for direct insurers and at the country level for reinsurers. These additions aim to improve supervisory oversight and support climate risk analysis.

2. Reporting Reduction

To ease the reporting burden, EIOPA proposes:

• Deleting templates such as S.29s (Excess of Assets over Liabilities) and S.37.03 (Risk concentration: split exposure by asset class and rating)
• Reducing the frequency of templates S.28.01 and S.28.02 (Minimum Capital Requirement) to annual reporting
• Simplifying templates, including S.06.04 (Climate change-related risks to investments), S.16.01, and S.19.01

Proportionality measures will be introduced, particularly for Small and Non-Complex Undertakings (SNCUs), which may be exempt from certain reporting requirements. The threshold for identifying reporting entities will be raised from €12 billion to €20 billion, resulting in a 24% reduction in the number of reporting groups and a 53% reduction in solo undertakings. This change reflects inflation and aims to streamline reporting.

Several guidelines will be deleted, including:

• GL 3 (Currency)
• GL 16 (Means of Reporting)
• GL 17 (Supervisory Reporting Formats)

Additionally, EIOPA is reviewing guidelines on the supervision of third-country branches and financial stability reporting. For third-country branches, 22 out of 61 guidelines are proposed for deletion due to redundancy. References to templates such as GLs 44, 45, and 47 will be updated accordingly.

3. Evolving Risk Models

A significant aspect of the amendments focuses on Long-Term Guarantee (LTG) measures. The current Smith-Wilson methodology for extrapolating risk-free rates will be replaced with an alternative method that utilises more market data. A phasing-in mechanism will allow undertakings to adopt the new approach gradually, subject to supervisory approval.

The Volatility Adjustment (VA) will also be restructured to include undertaking-specific components such as:

• Credit Spread Sensitivity Ratio (CSSR)
• Risk-Corrected Spread (RCS)

For EUR-denominated liabilities, a macro VA will replace the current country-specific VA. These changes will impact several life insurer templates, including:

• S.01.02 (Basic Information — General)
• S.22.01 (Impact of long-term guarantee measures and transitionals)
• S.22.06 (Best estimate subject to volatility adjustment by country and currency)
• A new template, S.22.07, which will provide public disclosure of VA by currency and country

How Fovis Mazars can help

Our Prudential Risk experts understand that regulation remains a key driver of strategic priorities for financial institutions. We specialise in guiding clients through complex regulatory landscapes, working closely with them to identify obligations and develop strategies for full compliance.

Whether you’re a life or non-life insurer preparing for these upcoming changes, our team is ready to support your organisation through the transition.