Asked if the impact assessment will delay the Solvency II implementation date, Mr De Rynck said, “The trilogue parties continue to work on the basis of 1 January 2014 as the first date of application of Solvency II and are working to ensure an agreement of Omnibus II in September 2012.” A number of other political issues, including in relation to third country equivalence, will be discussed at the trilogue.
Solvency II Wire has learned that according to a draft proposal, EIOPA will be asked to conduct an impact assessment on the three measures of the long term guarantee package: the Counter-cyclical Premium, Matching Adjustment (now also for certain non life insurance obligations) and the Extrapolation. It may also be asked to consider transitionals for the package of measures. The assessment will be conducted between October and December of this year and a final report will be submitted in March 2013. A source at the European Parliament said it was not yet clear whether EIOPA or the Commission will write the final report.
It is not immediately apparent what impact this will have on the Solvency II implementation date given that it may be possible to activate these measures in the Level 2 text (as revealed by Solvency II Wire 13 July 2012). It is understood these options will be under discussion in the technical trilogues leading up to the political meeting on 18 September. The situation is perhaps best summed up by an unnamed commentator familiar with the negotiations who said, “I think January 2014 is greatly at risk whatever happens.”
Note: Trilogue or Trialogue? Its Trilogue. The terms are used interchangebly on various EU sites but recently trilogue looks like the preferred form.