Solvency II readiness concerns revealed: E&Y

While 57% of insurers across Europe think they are on track to comply with Solvency II by January 2014, readiness varies significantly country by country, according to a survey of 160 large insurance companies across Europe carried out by Ernst & Young.

Seventy to ninety per cent of British, Dutch, Greek, Polish and Spanish insurers (self-assessed) expect to be ready to comply before 1 January 2014; whereas 60% to 70% of Belgian, French, German and Italian insurers won’t be ready until after 1 January 2014. However, while almost 90% of respondents are on track to meet the 1 January 2015 deadline proposed by the European Commission, 34% of German, 17% of Italian and 13% of Spanish insurers do not think they will be ready to comply until after 1 January 2015, according to the European Solvency II Survey.

Readiness for Pillar 1 is fairly consistent across Europe, with insurers in almost all countries saying that they will meet most Pillar 1 requirements. Readiness for Pillar 2 is more divided – insurers in the UK, Germany and the Netherlands are confident that most requirements will be met but the rest of the market is only on track to partially meet the requirements.

Readiness for Pillar 3, however, is lagging, according to the Ernst & Young report. Eighty per cent of respondents acknowledged that they have made little progress to date not in meeting the Pillar 3 requirements. Insurers in Britain, France and the Netherlands are relatively well prepared in comparison to others, but even in those markets 60% to 70% of insurers have yet to meet most of the requirements for Pillar 3.

Martin Bradley, partner in financial services and global solvency II lead at Ernst & Young comments: “We know from those organisations that have started their Pillar 3 projects, the emerging data deficiencies and significant process, control and IT challenges present an ambitious target to achieve within the current timeframes.”

Only 17% of insurance companies have formally assessed their risk management systems and determined their effectiveness in relation to outcomes.

“There is a risk that respondents have overestimated their readiness for Pillar 2, perhaps by placing greater emphasis on the existence and nature of a component than on the effectiveness of their risk management systems,” adds Bradley.

Nearly 69% of insurers say they have only met some or have not yet met any of the SII data management requirements. Eighty-one per cent are struggling in particular with data integration standards and their applications across group and external partners.

Jan Leiding, partner in Financial Services at Ernst & Young says: “Making the data landscape work requires firms to integrate multiple complex IT systems and is a massive challenge. The survey shows that progress in implementing appropriate ownership, governance and controls is particularly slow. The shifting EIOPA deadlines have offered excuses but these will be viewed as fundamental failings and now require prompt attention.”

Seventy per cent of insurers plan to focus on a range of capital optimisation strategies during 2013 and beyond. Almost 50% of respondents are already working on asset matching and hedging strategies and counterparty credit risk management.

"Capital optimisation is too important for insurers to wait for either complete certainty in the rules or a full set of metrics to explore opportunities. Instead they are engaging in activity where the impact is either relatively certain or where they see an opportunity to mitigate a negative impact of SII,” says Bradley.

The survey shows that half of respondents are now developing partial or full internal models. Insurers currently estimate an average decrease in SCR of 16% from using an internal model and many insurers expect the savings to be much more substantial: 26% of insurers expect their SCR to decrease by 20% to 30% and 14% of insurers expect it to decrease by more than 30%.

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