For insurers and consumers in the European Union, 2016 is a key year, since it is when the industry gets real experience of Solvency II, the newly implemented risk-based supervisory system. After a decade in the making, Solvency II officially came into force on January 1, 2016. While it had been a scramble by the industry to meet that deadline, ten months on as the road becomes less bumpy, what have we learned?
Insurers have met their numerous reporting requirements under the new regime, as well as calculated the Solvency Capital Requirement (SCR), prepared Own Risk and Solvency Assessments (ORSAs), and set out their risk management frameworks and rules of governance. Although this appears a straightforward task, in reality, the introduction of Solvency II has created a significant paradigm shift in insurance regulation, the biggest experienced in decades – with a corresponding cultural and strategic challenge to firms that do business in the European Union.
In September, I attended a conference in Slovenia’s capital Ljubljana, where industry participants gathered to assess where the industry has got to.
Has Anything Gone Wrong?
According Europe’s regulatory umbrella body, the answer to this question is an emphatic “no.” Manuela Zweimueller, the Head of Regulations at the European Insurance and Occupational Pensions Authority (EIOPA), added that although Solvency II is not quite perfect, regulators are continuing to refine the requirements. The main challenge according to EIOPA, is that Solvency II needs to be equally understood by regulators and (re)insurers over the next five years in order to close up the pockets of inefficiency and provide a level playing field for all those involved. EIOPA terms this “supervisory convergence.”
From the standpoint of European insurers and national regulators there are several core challenges. The German Federal Financial Supervisory Authority considers the combined demands of a complex internal model approval process, the need to work through complicated and lengthy reports and data, and appropriately train staff create challenges for supervised firms. From an industry perspective, Italian insurer Generali revealed that the main issues they face are around the complexity of internal model requirements and documentation. Both sides agree, however, that despite the burden of regulatory compliance and high level of technical detail involved, the use of an internal model for Solvency II to measure risk provides substantial benefits in the way of management, governance, and strategic decision-making. This makes Solvency II the only long-term solution for almost all insurers. For a brief discussion of the benefits of internal models, see my earlier blog post.
The additional demands of complying with Solvency II, however, have partly given rise to a surge in M&A activity. By going under the wing of a larger business, only one solvency return needs to be filed, which results in efficiencies and cost-savings. According to the Association of British Insurers (ABI), firms in the U.K. alone have already invested at least £3 billion (US$3.7 billion) to comply with the new solvency regulations. Strategic M&A activity is likely to rise, especially for small to medium-sized insurers which face problems maintaining the same levels of profitability as they did prior to Solvency II, and are seeking ways to defend their positions in the market.
What Does the Future Hold?
What’s needed next, according to EIOPA, is a period of stability for Solvency II – though there are still many more challenges that lie ahead. For instance, in the short term, insurance firms will undoubtedly feel the pinch, with many needing to invest more time and money into efficiently reporting their solvency ratios to the regulators. But there will be a preliminary review of the new directive in 2018 when EIOPA will address some of the complexities.
More widely, fears are increasing over the economic reality of low interest rates (which are hitting the life insurance market the hardest), decreasing corporate yields, and stock market volatility with Brexit. Although the consequences of Brexit have not been as bad as expected so far, these factors will still need to be managed in the balance sheet.
And despite all the difficulties that lie ahead for the industry as a whole, EIOPA stresses that we must remember that the ultimate goal of Solvency II is not just to unify a single EU insurance market, but to increase consumer protection – and adopting a consumer-centered approach is beneficial for all.