CBI Consultation Paper CP104
“External Audit of Solvency II Regulatory Returns / Public Disclosures”
Consultation Paper Overview
The CBI has issued a consultation paper on “External Audit of Solvency II Regulatory Returns / Public Disclosures” (CP104). The consultation is open from the 1st June to 29th of July 2016 and feedback can be sent to the CBI via email.
The CP sets out the following key points:
- The proposals apply to all undertakings in scope for Solvency II for financial years ending on / after 31st December 2016. In the pre-Solvency II regime reinsurance entities were not subject to any audit requirements in respect of the regulatory returns.
- Regulation 37 of S.I. No. 485 of 2015 (“Regulation 37”) enables the Central Bank of Ireland to require certain elements of quantitative information submitted by insurance and reinsurance undertakings be audited, and that report should include a reasonable assurance opinion on elements of the SFCR.
- Entities using full internal models are excluded from the proposals.
- For entities using partial internal models it is proposed that the elements of the SCR template calculated using the standard formula modules will be included in the scope.
- Auditors must include procedures in respect of the opening balance sheet to support their reasonable assurance opinion as at the year end, however a separate audit opinion on the opening balance sheet is not required.
- For Solvency II groups the CP proposes that the SCR and own funds QRT’s will be in scope.
- It is the intention of the Central Bank that the incumbent auditor would undertake the audit of Solvency II regulatory returns / public disclosures engagement.
- Appendix 2 and 3 of the CP set out the proposed QRTs in scope for solo entities and groups respectively.
- The external audit requirements would be required on an annual basis in line with pre-set submission deadlines.
How Can We Help
To the extent you have any questions in relation to CP104 above or you would like to discuss how we could potentially help you close any gaps arising as a consequence of the proposed requirements above, please feel free to give us a call or arrange a face to face meeting with us.