On 1 June, the Central Bank published Consultation Paper CP 104 on the External Audit of Solvency II Regulatory Returns / Public Disclosures. On 30 September, it published a Feedback Statement to CP 104 (the Feedback Statement). The Feedback Statement summarises the responses received to the consultation paper and outlines the Central Bank's decisions in relation to the themes arising from the comments received.

CP 104 set out the Central Bank's proposal in relation to Regulation 37 of S.I. No. 485 of 2015 European Union (Insurance and Reinsurance) Regulations, 2015 (the Regulations) which enables the Central Bank to require that elements of the quantitative information submitted by insurance and reinsurance undertakings be audited, and that the audit report should include a reasonable assurance opinion on the elements of the Solvency and Financial Condition Report relevant to the balance sheet, own funds and capital requirements. Section 3 of the Feedback Statement sets out the Central Bank's requirement in this regard and will apply to all (re)insurance undertakings subject to Solvency II for financial years ending on or after 31 December 2016.

Comments on the proposed scope and the application of proportionality, appeals for further explanation in some areas, and various queries relating to audit technical points were some of the key themes in the responses. To provide greater clarity as to the purpose of the requirement the Feedback Statement incorporated a number of high level observations and recommendations to enhance the proposals made in CP 104.

A link to the Feedback Statement and all of the responses is here.