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EIOPA has published its final guidelines for the phasing-in of the Solvency II regime, with the regulations announced to come into force on 1st January 2016. Prior to that date, European insurers have two other deadlines to meet:- A pre-application to the relevant regulator must be submitted in or around September 2014
- A full application to the relevant regulator must be submitted by 1st June 2015
While many insurers are focused on getting their risk and capital calculation models right, those who have already started the Solvency II application process will know that the main barrier to achieving compliance lies in managing the source data.
Whether applying for a Standard Formula, partial internal model or full internal model approach, all insurers must be able to demonstrate that the data used to conduct their economic capital calculations is, in EIOPA’s words, complete, accurate and appropriate.
These three words are easily said, but in practice they take a huge effort to achieve. Data is locked up in disparate systems, in emails and spreadsheets, in paper archives, and even inside employees’ heads. Experience has shown it can take a year or more to properly conduct the necessary exercises:
- Identify all of the systems (digital and physical) where the data resides
- Locate all of the required data within those systems
- Digitise any data that is held in a physical format
- Assign the data to its correct Solvency II classification (which may be different from its internal or local regulatory classification)
- Standardise the data (e.g. taxonomy, currency, date formats) for consumption by one or more risk calculation engines
- Validate all of the data prior to running the calculations
- Ensure data can always be collected, validated and processed in time to meet Solvency II reporting deadlines




