TFRS 17 after year one: making the process work in practice

The main challenges are not in understanding the standard itself, but in applying it consistently. Issues around data, system integration, governance over key judgements, and the quality of disclosures are becoming more visible. 

As organisations move from implementation to business-as-usual reporting, the focus is shifting towards creating processes that are sustainable, well-controlled, and less reliant on manual intervention. 

1. Data quality remains a core challenge 

A recurring issue across many implementations has been the difficulty of maintaining consistent and reliable data throughout the reporting process. TFRS 17 requires alignment between actuarial models, sub-ledgers, and the general ledger, and this has not always been straightforward. 

Common challenges include inconsistencies between data sources, manual adjustments outside core systems, and difficulties in reconciling outputs back to reported figures. These issues often surface late in the process, when timelines are already tight. 

Insight: There is increasing benefit in focusing upstream. Establishing clearer data ownership, reducing manual interventions and strengthening reconciliation processes will have a more lasting impact than relying on additional review at the end of the cycle. 

2. Integration across functions is still evolving 

TFRS 17 is not a purely actuarial or finance exercise. It requires coordination across finance, actuarial and IT functions, and this integration is still maturing in many organisations. 

Challenges typically arise from overlapping responsibilities, misaligned timelines and continued reliance on manual handoffs between teams. While workable in the short term, this introduces inefficiencies and makes the process harder to control. 

Insight: A more integrated operating model is becoming necessary. Clear accountability, aligned timelines and reduced duplication across functions will be key to achieving both efficiency and consistency. 

3. Governance over judgements is becoming more important 

TFRS 17 introduces a number of significant judgements, including discount rates, risk adjustments and contract boundaries. While methodologies were established during implementation, the ongoing governance of these judgements is now coming into greater focus. 

Areas that require attention include documentation of assumptions, consistency in application over time, and evidence of review and approval. 

Insight: As reporting matures, the emphasis is shifting from methodology design to governance. Clear documentation and consistent application will be important not only for internal control, but also in supporting external assurance. 

4. Making disclosures more meaningful 

As more financial statements are published, differences in the quality of disclosures are becoming more evident. While most organisations meet baseline requirements, the clarity and usefulness of information varies considerably. 

In some cases, disclosures are still highly technical, with limited explanation of the key drivers of results or movements during the period. This makes it difficult for users to clearly understand the impact of TFRS 17 on performance. 

Insight: Disclosures should be considered as part of the overall reporting process rather than a final step. Clear explanations of movements and results will make financial statements more meaningful and easier to understand. 

5. Moving towards sustainable processes 

The first year of reporting has often relied on a combination of new systems and interim solutions. While this enabled delivery, they may not be sustainable in the longer term. 

Reliance on manual adjustments, limited process documentation and inconsistent control application can increase operational risk over time. 

Insight: The next phase should focus on stabilising processes. Reducing manual workarounds, embedding controls within systems and ensuring processes are repeatable will be important in supporting future reporting cycles. 

6. Building audit readiness into the process 

TFRS 17 has raised expectations around documentation and audit trails. Where these are not embedded during the reporting process, additional effort is often required at year end to support the audit. 

This can place unnecessary pressure on teams and increase the risk of inconsistencies. 

Insight: Audit readiness should be considered throughout the reporting cycle. Keeping documentation up to date and maintaining clear supporting evidence will improve both efficiency and overall control. 

Conclusion 

The first year of TFRS 17 has done what it needed to do by getting insurers reporting under the new standard. The next phase is less about technical interpretation and more about making the process work in practice. 

The focus should now be on improving data flows, tightening governance, and simplifying how different functions work together. Organisations that address these areas early will find future reporting cycles more manageable and less dependent on manual intervention.