National competent authorities (NCAs) in certain Member States, including the UK and Sweden, intend to consult insurers over the next few months on plans to introduce national specific templates (NSTs). The French supervisor has already consulted on its NSTs. The NSTs are aimed at accommodating business lines unique to individual Member States and cover any data gaps in standard pan-European quantitative reporting templates (QRTs) designed by the European Insurance and Occupational Pensions Authority (EIOPA).
But there is a danger that NSTs, if drawn too wide, could gold-plate existing reporting requirements in operation among Member States and undermine the Solvency II goal of a harmonised reporting regime. Olav Jones, deputy director-general of Insurance Europe in Brussels, says: "Solvency II reporting requirements are already very extensive and will involve insurers in significant effort and cost. Insurance Europe would not wish to see double or additional reporting requirements placed on EU insurers. It believes standardisation of reporting across Europe is the best way to ensure transparency and consumer confidence."
Sweden, France and the UK are known to be developing NSTs for their home markets. The Swedish and UK regulators have yet to set a date for consultations on their NST proposals.
Member States may need to maintain national specific reporting requirements in order to meet broader regulators' requirements beyond prudential standards. "What is difficult is that national requirements have evolved explicitly and implicitly to meet other considerations than purely prudential regulation – such as fairness between policyholders and shareholders and between classes of policyholder. Such considerations could justify continuing nationally specific requirements", says Seamus Creedon, a former Solvency II project manager at the Brussels-based European actuarial association Groupe Consultatif Actuariel Européen and a member of EIOPA's insurer and reinsurer stakeholder group (IRSG). He adds that it would be a "shame" if an NCA used an NST to retain its own reporting standards after implementation of Solvency II.
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