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Solvency II reporting & compliance
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IFRS insurance contract consulting
The new IFRS standard for Insurance Contracts is very challenging for insurers on an operational and strategic level. Its implementation requires the right combination of modelling and actuarial skills.
The new IFRS standard for insurance contracts will require a lot of attention in order to have an accurately performing IFRS reporting process ready in time.
The IFRS project for Insurance Contracts has gone a long way, but finally the IFRS 17 Standard has been published and will be effective from 1 January 2023.
The IASB predecessor, the IASC, set up a Steering Committee in 1997 to carry out the initial work to develop a fair value based accounting measurement for insurance contracts.
Phase I of IFRS 4 Insurance Contracts was issued in March 2004 and became effective as of January 2005 when IFRS reporting became mandatory for listed companies in Europe. Phase I was intended only as an interim standard which allowed insurers to continue to use various local accounting practices pending the completion of a comprehensive standard. It did, however, specify that contracts without any transfer of insurance risk should be considered as financial instruments (falling under IAS39) and introduced an additional Liability Adequacy Test to check the accounting figures against the underlying economic situation.
In 2007, a first discussion paper was issued to set the ultimate accounting measurement for insurance contracts. This was followed by an exposure draft in 2010 and a revised exposure draft in 2013, which readdressed some of the most controversial topics. In this period, the original concept of “fair value” was refined to “exit value” first and then to “fulfilment value”. A final Standard called IFRS 17 was published in May 2017 with a transition period of over three years and an effective date of 1 January 2021.
The main measurement approach consists of a current Fulfilment Value, which is a risk-adjusted valuation of the cost, from the perspective of the insurer, of fulfilling all insurance obligations.
The objective is to have individual contracts as unit of account, but aggregation is allowed provided that it matches with this objective.
The goal of this margin is to avoid the recognition of all future profits at inception of the contract.
Instead, the contractual service margin is released as insurance services are provided and is adjusted when the best estimate cash flows for the future are revised.
A risk adjustment must be added as a compensation for the uncertainty inherent in the fulfilment cash flows.
An insurer can choose a method that best fits with its own view on risk compensation—for example as used in pricing, but should report the corresponding quantile to make a comparison possible (“Confidence Level Equivalent”).
The best estimate should reflect the mean value of the expected cash flows required to fulfill all contract obligations. This includes premiums, claim benefits, administration expenses and directly attributable overhead expenses, but excludes indirect overhead expenses.
These cash flows must be discounted by using a discount rate (curve) that is consistent with the characteristics of the insurance liabilities and observable market prices.
Onerous contracts: A negative contractual service margin is not allowed. Future Losses must be recognized immediately. If the situation improves in the future, then firstly all losses must be reversed before a positive margin can be booked.
Short-term liabilities: For short-term liabilities (usually a coverage period of 12 months or less), the unearned premium is considered as a reasonable approximation (“Premium Allocation Approach”). This waives the use of separate building blocks and of discounting.
Reinsurance contracts: Insurance liabilities should be measured gross of reinsurance and reinsurance contracts held by insurers (as cedant) should be presented separately by using the same General Model approach. Unlike the General Model approach, however, the CSM for reinsurance contracts can be positive or negative.
Directly participating contracts: For contracts that participate directly in the return on underlying items, a modification of the General Model is used as the CSM requires more flexibility to adjust for the variability of the fee the insurance entity is earning (“Variable Fee Approach”).
The proposed measurement is similar, but not identical, to MCEV and Solvency 2 measurement.
Differences could include treatment of overhead expenses, choice of discount rate, risk adjustment methodology, contract boundaries, grouping and fair value approach for in-force business.
The proposed fulfilment value is a current value measurement that requires updating at each reporting date, using actual contract information, actuarial assumptions and economic parameters such as the discount rate.
The difference between two consecutive reporting dates can have various sources. The allocation of the differences arising from each source depends on the nature of the source.
Moving one period forward implies that a part of the Contractual Service Margin and Risk Adjustment can be released in P&L, proportionate to the services provided and change in risk during the period.
Additionally, there is the time value of money where the discount rate is being unwound over the entire period. This unwind is released in P&L.
When cash flows occur as expected, they form together with the released Contractual Service Margin and Risk Adjustment the insurance contract revenue of that period.
As the Fulfilment Value is a current value measurement, the discount rate must be updated every reporting period. Especially for long term liabilities, this can mean an enormous shift in the current value.
The IASB has therefore decided to allow insurers to split the effect of discounting in the income statement. Under the General Model, the effect of discounting can be split into:
Updates of the actuarial assumptions underlying the applied cash flow projections will lead to new best estimates and/or risk adjustment.
As far as these updates relate to future coverage and other future services, these changes can be absorbed by adjusting the contractual service margin.
If this margin falls to zero, however, the remaining adverse changes should immediately be taken in P&L. For an onerous contract, previous losses must be unwound in the P&L before a positive Contractual Service Margin can be created again.
New business must be added each period according to the General Model Approach, Premium Allocation Approach or Variable Fee Approach. This adds to the existing contractual service margin or creates an immediate loss for onerous contracts.
On top of that, additional benefits from a contract modification should be recognized as a new contract. This would then create multiple premium components and (where the VFA does not apply) multiple locked-in discount rates within one contract.
Note that the total positive contribution in the year to CSM from new business needs to be shown separately in the disclosures,so the disclosures will include a measure of value of new business. But it will not be the same as that which would be calculated under an MCEV approach.
The requirements of the new standard go well beyond any accounting measurement used so far.
At each reporting date, best estimate future cash flows need to be projected and discounted in an appropriate way, using actuarial assumptions and methods. For embedded options, stochastic projections (1000+ scenarios) may be required.
At best, insurers can start from similar measurement frameworks like MCEV or Solvency 2, but will face new challenges from:
Insurance companies that hold on to a Fast Close of their accounting reports will need to design a calculation process that gives flawless results from the first time. The February deadline for publishing accounts will be a key issue if firms want to leverage any tools used in Solvency II reporting (which happens in May).
They will need sufficient processing power to have the current measurement and the analysis of movement for the Income Statement ready in time.
Companies may want to consider a fundamental upgrade of their ICT capacity, for instance by using cloud computing.
The extensive disclosures required under the new Standard will also add to the challenge for companies.
The new IFRS standard for insurance contracts has a huge impact on how the performance of an insurer is presented to its stakeholders.
Methodological choices that affect the way that future profits will be determined and released should be well-chosen and properly understood by management.
All stakeholders, including Boards of Management, staff, investors and external communicators will need to be educated on the new standard. The change is likely to result in restatements of the balance sheet when the standard is first applied and this will need to be explained.
The launch of the new insurance contracts IFRS standard will come shortly after, but will not coincide, with the mandatory effective date of IFRS9.
The way the measurement and statement of covering assets interacts with that of insurance contracts will have a huge impact on balance sheet and income statement volatility.
Accounting mismatches are to be minimised or explained carefully to users of the accounting reports.
Companies will need to decide how the ALM target will be set. Is it management of volatility of IFRS earnings or management of the solvency ratio, both of which are based on different value frameworks.
There will be a transition period of just over three and a half years.
This gives insurers very limited time:
There are three possible approaches which can be used at the transition date. The Full Retrospective Approach should be used unless impracticable. If this is impracticable, a Modified Retrospective Approach or Fair Value Approach may be used. The Fair Value Approach involves determining the CSM at the transition date as the difference between the fair value of the insurance contract at that date and the fulfilment cashflows measured at that date.
The new IFRS standard for insurance contracts promises to have a transformative effect on insurers' financial reporting.
IFRS calls for a more nuanced and comprehensive approach to risk modelling—an approach that will require not just specialized actuarial expertise, but also unprecedented processing speed to meet strict auditing timeframes.
Milliman has considerable experience with Solvency II and other regulatory regimes, coupled with groundbreaking systems implementation and industrialisation capabilities.
Whether you’re looking for a basic model or a full-service actuarial solution, there’s an Integrate solution for you.
Milliman Mind is a flexible and easy-to-use web-based platform that offers you a cost-effective IFRS 17 calculation tool.
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