EIOPA is consulting on a package of interim guidelines that will require national supervisors to ensure that insurance companies implement elements of Solvency II ahead of the regime's full application, now unlikely to take place before 2016.
Some countries such as Denmark have already implemented Solvency II's methodology for extrapolating the risk-free rate for discounting liabilities to an ultimate forward rate owing to ultra-low interest rates. Sweden is currently consulting on a proposal to introduce this approach.
"As time goes by if we don't have any push to have a consistent and convergent approach we will have a situation where we start to see some differences. We already see some of them emerging for good reasons… but it is better to do it in a convergent way", Bernardino says.
National supervisors, he says, support the proposed interim measures and will make "all efforts" to comply with them. But the pace of implementing the guidelines will differ between Member States due to differences in the legal powers of national authorities to implement new rules and that inconsistencies may still arise as a result, he says.
"What we expect is that national authorities will start on January 1, 2014 to implement in their own national frameworks these guidelines and then we will see an evolution. The aim is to have the same level of preparedness from supervisors and the industry at the end of this exercise when Solvency II is implemented to have a much bigger level of preparedness from supervisors and the industry."
Bernardino also says insurers will benefit from the guidelines, as it will enable supervisors to provide feedback on their preparation for Solvency II, such as on the quality of their reports.
"The focus [of the guidelines] is not enforcement; the focus is on improving the quality. In that sense I don't really see why both national supervisors and the industry will not be in a shape to comply with these guidelines as it is in their own interests. I would say it is a win-win situation at the end of the day, and will put us in a much better situation when Solvency II is in force", he says.
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