Review of the Insurance Solvency Standards

Normally, solvency figures calculated on a different basis to the mandatory solvency disclosures should not be included as part of the solvency disclosure.  This is because reporting 2 sets of solvency figures on different bases is likely to create confusion over the regulatory solvency position of the insurer.

However, for some insurers the anticipated impacts of the proposed second amendment to the ISS may be sufficiently material that the solvency position being reported in the mandatory solvency disclosures is significantly different to the solvency position as if the second amendment of the ISS was already in effect.  That is, the mandatory solvency disclosures may not be a good guide to the future solvency position of some insurers if the second amendment comes into effect.

In light of this, we are comfortable for insurers to disclose, alongside the mandatory solvency disclosures, additional solvency figures calculated as if the second amendment to the ISS was already in effect, provided:

• the mandatory solvency figures are clearly labelled as the regulatory solvency position required under the applicable version of the ISS or earlier solvency standard(s)
• the additional solvency figures use the second amendment to the ISS, as issued (if it has been issued) or as proposed on our website (if not) – no other basis can be used
• the additional solvency figures are for the latest as at date reported in the mandatory solvency disclosure, in other words are not a projection
• the additional solvency figures are clearly labelled as incorporating the second amendment to the ISS, which is not yet finalised (if this is the case as at the reporting date)
• there is a statement that the additional solvency figures do not represent the regulatory solvency position
• the insurer’s Appointed Actuary has calculated or reviewed the additional solvency figures, and there is a statement to this effect, and
• there is a link to the proposed or issued (as applicable) second amendment to the ISS on our website. 

Insurers are able to make commentary as part of solvency disclosures, as long as it is accurate and not misleading.

For some insurers the anticipated impacts of the proposed second amendment to the ISS may be sufficiently material that it may be reasonable for insurers to provide some explanation of the implications for the future solvency position.

Any such commentary should be clear:

• that the second amendment to the ISS does not affect the regulatory solvency position unless and until it comes into effect
• if the second amendment is not yet issued, that this is only a proposed amendment
• if the second amendment is issued, that this is the case and state the effective date of the amendment
• avoid technical jargon where possible
• be relatively short (for example, no more than a few paragraphs), and
• if figures are provided, they should be limited and follow the above guidance (“can solvency figures on a different basis be disclosed alongside the mandatory figures”).

We have published a consultation paper with proposals to address parts of the ISS that need clarification or are not working as intended. The consultation paper also covers other minor issues which fall within the scope of stage 1 of the Review of the Solvency Standards. This scope relates to addressing NZ IFRS 17 and improving the structure of the solvency regime.

The most significant proposals relate to:

• re-basing the underwriting risk capital charge to appropriately reflect pricing risks rather than NZ IFRS 17 accounting outcomes;
• reinstating credit risk capital charges on interest-sensitive assets;
• explicitly excluding reinsurance cash-flows related to future primary contracts from “insurance items” to allow their recognition in solvency capital as a non-insurance item;
• clarifying that contract clauses allowing early cancellation should not establish a boundary; and
• clarifying how to handle tax, acquisition expenses and risk adjustments in the “modified PAA” method.

As well as the consultation paper, we are publishing a draft of the Amendment Standard, a Consolidated Standard and a Guide to the Standard. We are looking for feedback on all of these documents. You can email any consultation questions to [email protected]. 

• Consultation paper on the Draft Interim Solvency Standard Amendment Standard 2024 (PDF, 376.96KB)
• Draft Interim Solvency Standard Amendment Standard 2024 (PDF, 481.94KB)
• Draft Interim Solvency Standard 2023 (consolidating amendments to 1 June 2024) (PDF,1.4MB)
• Guide to the Interim Solvency Standard 2023 (PDF, 649.42KB)
• Webinar: IPSA and Solvency Standard Reviews presentation (PDF, 666.44KB)
• Insurance solvency discussion - webinar questions and answers (PDF, 122.23KB)

We identified a small number of minor errors in the Interim Solvency Standard 2023 (the Standard). We issued an ‘Amendment Standard’ to correct them. We also took the opportunity to ease sign-off requirements for solvency returns so you can specify signatories by the conditions of an insurer’s licence.

Stakeholders made us aware of a number of additional issues with the Standard, and we thank them for raising these. We intend to address these issues over the coming months by consulting on and issuing a further amendment. We will prioritise this work over stage 2 of the Solvency Review (the detailed review of methods and parameters). We will advise the schedule for work on this further amendment in due course.

References in conditions of licence to the ‘Interim Solvency Standard 2023’, from 1 August 2023, refer to the Standard as amended by the Amendment Standard.

Interim Solvency Standard Amendment Standard 2023 (PDF 247 KB)

Interim Solvency Standard 2023 (as amended) (PDF 1.75 MB)

In its 20 September 2022 meeting the Board of the Reserve Bank issued the Interim Solvency Standard 2023.  The standard is the culmination of more than two years of work and consultation and is designed to streamline solvency calculations and facilitate continued sound solvency management once NZ IFRS 17 (the new accounting standard for insurance contracts) becomes mandatory.  It is accompanied by a regulatory impact statement.

While the standard comes into force on 1 January 2023, it will be applied to individual non-exempt insurers by changes to the condition of licence. These changes will be provided to affected insurers in coming months.  Our intention is that the new standard will apply from the date that each non-exempt insurer begins its first annual reporting period under NZ IFRS 17 (the incoming accounting standard for insurance contracts)

Non-exempt insurers should now assume that the Interim Solvency Standard 2023 will apply at relevant future dates for the purposes of projecting solvency margins. Such projections need to be made in solvency returns, in financial condition reports and for the purposes of sections 24 and 127 of IPSA.

Questions about the new standard can be addressed to [email protected].

Interim Solvency Standard 2023 (PDF 2MB)

Regulatory impact statement (PDF 1MB)

Non-technical summary (PDF 600KB)

We have published a ‘review version’ of the insurance Interim Solvency Standard, determining the minimum amounts of capital insurers must hold.

Following 2 initial consultation cycles, we published an exposure draft of an Interim Solvency Standard in July 2021. We ran a quantitative impact assessment in parallel to the consultation on the standard, and we published both results in a feedback statement in March 2022.

The review version of the Interim Solvency Standard contains several amendments over the July 2021 version. Although we are conducting a partial consultation on this version of the standard, we invite interested parties to comment on any technical or workability issues not previously identified.

We will also conduct a second quantitative impact assessment on a largely voluntary basis. We invite insurers that would like to participate to download the template provided below and submit it to: [email protected] by Friday 15 July 2022.

Interim Solvency Standard (review version – May 2022) (PDF 1.8MB) 

Quantitative impact assessment template May 2022 (XLSX 478KB)

We have released a feedback statement regarding the consultation on a Draft Interim Solvency Standard initiated on 22 July 2021. This statement contains a summary of the feedback received, indicative Reserve Bank responses, and an overview of impacts on capital measures. We have provided a file containing the full text of all non-confidential submissions.

If you have any questions about the feedback statement, please write to [email protected]. We will hold a webinar to discuss the standard on 22 May 2022. Please subscribe to the ‘Insurers’ updates on our mailing list if you want to attend.

Draft Interim Solvency Standard Public feedback statement (PDF 1.1MB)

Full submissions (PDF 6.5MB)

We exposed a draft Interim Solvency Standard for consultation on 22 July 2021, with the intention of coming into force on 1 January 2022. We chose this date to permit the use by early adopters of IFRS 17, the new accounting standard for insurance contracts.

During the consultation period, however, we have become aware that:

• there do not seem to be any insurers planning to early-adopt IFRS 17;
• many insurers might find it difficult to be ready by this date; and
• consultation feedback is likely to require some changes to the standard as drafted.

For these reasons, we have decided to change the date of implementation of the Interim Solvency Standard to 1 January 2023.  This date aligns with the date on which insurers must adopt IFRS 17. We will have time to address some of the more significant points raised in the consultation, and insurers will have sufficient time to prepare their systems and processes.

We are currently analysing the remaining feedback from the consultation and will publish a summary of this material in due course. We intend to use the additional time and further engage with industry and stakeholders over the coming weeks and months. We will aim for the final interim standard to be published by 1 October 2022. 

If you have any questions about the change of implementation date, please write to [email protected]

Over September, we will conduct a quantitative impact assessment exercise with selected insurers to help us understand the capital impacts of the draft Interim Solvency Standard. To assist other insurers and their advisers with their analyses, we are publishing the template for this exercise. Once we implement the standard, this template will likely form the basis for the Insurer Solvency Return.

Readers of the instructions document should note the following:

• These instructions were designed for the quantitative impact assessment and are not intended for other uses. We are releasing them to maximise transparency around the process.
• The instructions include certain treatments which may or may not become part of the enforced standard, and we have no obligation to adhere to these treatments in later versions of the standard.
• Submissions on the draft Interim Solvency Standard should reference the document published on July 22, not these instructions.

Template for quantitative impact assessment (XLSX 451KB)

Instructions for quantitative impact assessment (PDF 767KB)

We are publishing 3 documents relating to the Review of the Insurance Solvency Standard.

Feedback is invited on the standard and can be provided:

• Online, at a webinar at 10am on Thursday 5 August 2021. Please subscribe to our mailing list to express your interest in attending the webinar. An invite will be sent to our Insurance mailing list closer to the date.
• In writing, to [email protected] (early submissions relating to substantive issues are particularly welcome and will not preclude a more comprehensive later submission)

The consultation will run until 5pm on 1 October 2021.

A feedback statement from the earlier consultation on IFRS 17 and the structure of the solvency standards (PDF 860KB)

A draft of an Interim Solvency Standard intended to apply to almost all insurers from early 2022 for approximately three years (PDF 1.9MB)

An explanatory note to document the thinking behind the Standard and provide clarification to readers (PDF 1MB)

We have released a feedback statement relating to the consultation undertaken in the last quarter of 2020 on the principles guiding the Review. The statement describes several modifications to the principles being made in response to the submissions received.

The consultation on the structure of the solvency standards and our approach to IFRS 17 closed on 18 February 2021. We are considering submissions received and developing a feedback statement. This work will inform the development of draft interim standards, due for exposure during the third quarter of 2021.

Review of Insurance Solvency Standards: Principles and Timeline Consultation feedback statement (PDF 700KB)

Review of Insurance Solvency Standards: Principles and Timeline Consultation Summary of Submissions (PDF 4.5MB)

We have released a consultation paper about the structure of our solvency standards and our approach to IFRS 17. This paper is a precursor to the interim standard(s) that will be exposed later in 2021. It raises several issues relating to how solvency standards are applied and proposes certain options for their resolution.

Consultation paper on the structure of solvency standards (PDF 2MB)

Non-technical summary on the structure of solvency standards (PDF 302KB)

We have commenced a review of the Insurance Solvency Standards. An initial paper sets out the anticipated timeline for the review and exposes for consultation several principles intended to guide the review. A substantive consultation paper — responding to IFRS 17 and dealing with the structure of solvency standards — is expected to be issued in November 2020.

Insurance Solvency Standards review paper (PDF 648KB)