The European Parliament has adopted the emergency Directive, which amends Solvency II by requiring the Member States to make their Solvency II rules by 30 June 2013, and firms to comply with them from 1 January 2014.
That's not a surprise. It's a problem solved: we no longer have to worry about Solvency II coming into force on 1 November 2012, revoking Solvency I and creating a vacuum as it does so.
But it does create a set of other problems: we already know there isn't enough time for the European Institutions to finalise Omnibus II and for the Member States to transpose the new regime by 30 June. (Sweden will be up to 6 months late, and other Member States will join their club.)
The result? Bifurcation was designed to ensure a level Solvency II playing field on day 1. So that's one key objective missed. There's also still a significant risk that the timetable have to slip again. My money's on more slippage. Where's yours?
