There have been a number of recent developments relating to the regulation of insurance undertakings by the Central Bank of Ireland (the "Central Bank").

Fitness and Probity Regime for (re)insurance undertakings under Solvency II - Policy Notice October 2015 

The Central Bank has published a Policy Notice outlining the changes that will be made to the Fitness and Probity Regime for all (re)insurance undertakings subject to the Solvency II requirements and the requirements of the Domestic Actuarial Regime and Related Governance Requirements under Solvency II. 

As part of the preparation for Solvency II implementation, the domestic Fitness and Probity Regime was reviewed in order to determine compatibility with Solvency II.  The changes that will be made to the Fitness and Probity Regime include:

  • the requirement for all undertakings to appoint a Head of the Actuarial Function ("HoAF");
  • PCF20 (Chief Actuary) and PCF44 (Signing Actuary) will be removed as PCFs, Pre-Approved Control Functions, from the Fitness and Probity Regulations. These amendments do not affect the role or responsibilities held by these individuals but simply remove the roles from the pre-approval provisions of the Fitness and Probity Regime. 

For a link to the Policy Notice, please click here.

Central Bank publishes feedback statement and submissions on Consultation Paper 92 

The Central Bank has published a feedback statement on Consultation Paper 92 Domestic Actuarial Regime and related governance requirements under Solvency II. 

In this statement the Central Bank addressed numerous queries, including:

  • queries regarding the Reserving Requirements for Non-Life Insurers and Reinsurers;
  • the text regarding the requirement of pre-approval of PCF roles prior to appointment;
  • the requirement that the responsibilities be held by one individual within the undertaking and whether this inferred that the HoAF role could not be outsourced; and
  • the membership and the role of Non-Executive Directors in the Reserving Committee. 

For a link to the feedback statement, please click here.

Publication of September Edition of Solvency II Matters 

The latest edition of Solvency II Matters was published on 22 September 2015.  This publication provides an update on recent reorganisation of the Insurance Directorate.  These updates include:

  • the establishment of a new supervision division which will be responsible for all firms supervised by the directorate;
  • the establishment of a new Advisory, Analytics and Actuarial Division;
  • specific domestic requirements regarding the actuarial function which shall apply to all (re)insurance undertakings subject to Solvency II have been introduced by the Central Bank;
  • all High and Medium High impact undertakings are required to submit quarterly data in respect of Q3 2015 in November 2015; and
  • three different elements will be required from insurance companies in order to fulfill their future reporting requirements; (i) the introduction of Quantative Reporting Templates (“QRTs”) under the Solvency II regime; (ii) the introduction of Statistical National Specific Templates ("SNSTs") under new ECB requirements; and (iii) the introduction of Prudential National Specific Templates ("PNSTs") to capture elements of the local market for supervisory purposes.

For a link to the document, please click here.

Survey issued to insurance undertakings on 16 September 2015 

On 16 September 2015, the Central Bank issued a survey on preparedness for Solvency II to compliance officers of all undertakings subject to the Central Bank guidelines.  This online survey will remain open until close of business on 30 October 2015. The survey aims to:

  • assess compliance with the Solvency II preparatory guidelines published by the Central Bank in November 2013;
  • provide information on how the industry is preparing overall for full implementation of Solvency II; and
  • provide insight into the main difficulties faced by undertakings in the lead up to full Solvency II.