The Insurance Reporting Challenge:

Building an Integrated Framework

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Solvency II Pillar III increases reporting requirements in terms of volume, frequency, timeliness and complexity. These, in turn, have a direct bearing on insurers’ data, processes, methodologies and organization. The pressure put on insurers to enhance their reporting calls for a revamped closing and reporting framework where integration is part of the approach. Beyond the new Solvency II requirements, reporting, in our view, remains a pressing issue at the global level.

Thanks to renewed field-testing, dry runs and preparatory exercises, the operational challenges of closing the books in the new Solvency II regime have been explored, including issues such as timeliness of actuarial calculations, completeness of control checks, the operability of the required look-through approach, the comprehensiveness of the data and the

embedding of the entire data and information production value chain into insurers’ existing frameworks. These issues (and others) should be addressed via action plans to find ways to simplify, rationalize, and automate processes, methods and organization. Responding to these is necessary, we believe, but not sufficient to addressing the reporting challenge facing insurers.

Finance, risk and prudential closings are more or less functionally linked, and their production processes and organizational definitions should not be treated in silos. Failure to embrace a comprehensive perspective may jeopardize insurers’ capacity to effectively address regulatory demands. The multitude of regimes such as Generally Accepted Accounting Principles (GAAP), International Financial Reporting Standards (IFRS) and the Market Consistent Embedded

Value (MCEV), will require the closing of books under each standard. This should encourage insurers to approach these standards and requirements using an integrated framework covering processes, systems and people dimensions. Solvency II and its pillars should be embedded into this integrated framework.

With legal submission deadlines becoming stricter up until 2020―for year-end as well as quarter-end reporting―and with new reporting requirements concerning multiple stakeholders from the accounting and actuarial areas, insurers are encouraged to streamline their finance and risk reporting and production processes. This could allow forward-looking insurers to set up a more efficient and effective reporting framework.

Introduction

In recent months, the reporting component of Solvency II has become a major concern for insurance companies operating in Europe.

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With the January 1, 2016 implementation of Solvency II, insurers might find themselves having to address both Solvency I and II regulatory requirements over the near term. This will essentially double the reporting burden faced by insurers’ operational teams. And, with the looming addition and changes to reporting requirements such as IFRS (impacting assets and liabilities), new capital standards (impacting own funds), new National Specific Templates (NST) and statistical reporting requirements from the ECB (European Central Bank) and the FSB (Financial Stability Board), they will also be encouraged to integrate their processes and adopt a different operating mindset.

To avoid major bottlenecks and congestion in submitting their different regulatory packages to national supervisors on a timely basis, and to deal with multiple closings in a short time frame, insurers should be planning their next move to avoid building “reporting factories” they won’t be able to effectively manage or maintain in the long run.

Mutualizing efforts, reducing time spent on producing and correcting data, industrializing and accelerating the entire reporting production chain are part of the overall approach. However, by themselves, these actions cannot deliver timely and quality reporting on a consistent basis. As insurers are challenged to do more with less, they should be thinking about how to improve

the entire closing and reporting process. We see speed, efficiency, quality, compliance and control as the central features of every closing blueprint.

Insurers are also encouraged to switch gears from a “fastidious close” mindset to a “fast close” approach allowing them to consistently close their books on time, to multiple standards, and report at expected closing dates with less effort and fewer challenges. Greater speed, and increasing flexibility to submit reports covering multiple financial and prudential standards, can be delivered by building an integrated closing and reporting framework where quantitative and qualitative information are produced in an integrated manner until financial communication.

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Source: Accenture analysis based upon publicly available information from: European Insurance and Occupational Pensions Authority, European Commission, International Accounting Standards Board, International Association of Insurance Supervisors and the Financial Stability Board, October 2015

Figure 1. High-level Global Regulatory Roadmap (as of October 2015)

As shown in Figure 1 below, there are multiple, complex reporting requirements, with variations and divergences in basic components such as valuation approaches which need to be reconciled. As insurers respond to pressure to meet new capital, accounting and prudential rules, they are transforming their finance and risk operations

to produce what has been termed an “avalanche of information.1”

Regulations can act as a catalyst for transformational change, but insurers are encouraged to anticipate the content of future rules. This will help them better understand how the different standards

and elements should be produced and reported by the different functions and at different frequencies. Figure 2 shows how switching from a layered approach to a synchronized and integrated one is in our view key to sustainably meeting the insurance reporting challenge.

A Wave of Changes

Insurers are facing a rapidly evolving regulatory environment with new and changing standards imposed by different national, regional and global regulatory authorities.

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FT: Field TestingFTA: First Time AdoptionG-SII: Global Systemically Important InsurerHLA: Higher Loss AbsorbencyIAIG: Internationally Active Insurance GroupICS: Insurance Capital Standard

IFRS: International Financial Reporting StandardsOMD II: Omnibus II DirectiveSRMP: Systemic Risk Management PlanRRP: Recovery and Resolution Plan

Glossary:

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5

Glossary:

ORSA: Own Risk and Solvency Assessment

Source: Accenture, October 2015

Figure 2. The Insurance Finance and Risk-wide Reporting Structure

However, the operational frameworks developed and deployed by insurers may be a long way from being completely embedded, autonomous, and consistent with their intended targets. To close the last mile and help meet compliance targets for Day One Reporting, insurers may need to undertake additional initiatives.

Beyond Solvency II, there are other regulatory changes in the finance and risk area. These include requirements specific to reporting templates from the ECB, or those such as the NST or the new IFRS 9 (financial instruments) and IFRS 4 Phase II (insurance contract) requirements. To this we would add global capital standards such as Basic Capital Requirements, Higher Loss

Absorbency, Insurance Capital Standards and future Solvency II changes, including XBRL (eXtensible Business Reporting Language) taxonomy fine-tuning or Standard Formula calibration. From that perspective, insurers’ finance and risk production factories should be able to respond to regulators’ evolving demands in addition to addressing the insurers’ organic changes, including new product launches or M&A activity.

Preparing for Day One Reporting is a top priority, and supervisors expect timely submissions from insurers. But meeting deadlines at the expense of staff compensating for the inefficiencies of technology or processes is not sustainable.

Insurers should be thinking strategically about the overall architecture and framework of their reporting production. The ultimate objective should be a “smart factory” for producing regulatory reporting in a lean, rationalized, and reliable way. By combining efficiency and timeliness, insurers can address the sometimes conflicting demands of compliance: Meeting deadlines and providing high-quality data. Supervisors have called for greater reporting maturity in insurance, which could lead to future regulations regarding audit standards for Solvency II and create an even greater need for high quality public disclosure.2

Upcoming Changes Beyond Solvency II

Solvency II regulatory reporting goes into effect on January 1, 2016. For many insurers, the effort to comply with Solvency II requirements has been costly in terms of time, money and effort.

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In addressing complex and sometimes conflicting insurance reporting requirements, insurers’ boards and management teams should ask some fundamental questions about their existing reporting frameworks:

• Do our tools fit our business needs and is our architecture efficient and seamlessly integrated between systems?

• Are our processes properly designed and understood at the right level by the business teams that need to follow them?

• Is our organization sufficiently equipped in terms of skills, seniority mix, capacity, technology and other resources?

• Is the transformation roadmap clear and correctly phased so as not to disrupt the production teams?

• Is our overall reporting framework progressively improving and are we on the right track?

• How do we transition into business as usual and establish a sustainable mode of operation?

In a more operational model, key questions would include:

• Which target are we following to define our end-state insurance reporting process (2016 and beyond?)

• What is the scope of standards we want to envision (i.e. local GAAP, IFRS, Solvency II Phase III, other Solvency II requirement, other regulatory standards, internal reporting?)

• Which level of process granularity are we looking at defining, for example, cross-departmental steering versus internal department needs?

• Which reporting deadlines are we trying to meet internally within our group and/or corporate structure?

• How do we coordinate individual and consolidated processes with financial communication expectations?

• How do we coordinate quantitative with qualitative reporting production such as narrative appendices, regular supervisory reporting for the Solvency and Financial Conditions Report (RSR-SFCR), and reference documents?

Reporting requirements may be a driver of structural change. The whole production value chain offers possibilities for finding and fixing deficiencies or insufficiencies, including such areas as:

• Model changes and computational challenges

• Links between Pillar I and Pillar III

• Links with accounting

• Links with ORSA

• Quarterly reporting

• XBRL validation and submission

• Multiple standards reconciliation

• Internal reporting

• Consolidation and group specific issues

• Embedding within business as usual

Insurers should be clear about how they address these and other specific issues.

Dealing with Proliferating Insurance Reporting Requirements Current reporting processes―as well as dry runs to prepare for Solvency II requirements―are time-consuming and resource-intensive. They have been compared to running a marathon each quarter.

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There is no “one size fits all” approach to financial reporting, but we have found that there are some key actions which are consistently undertaken by insurers, such as:

• Engaging stakeholders to absorb the content of final Solvency II Level 3 texts (Implementing Technical Standards and Guidelines) to facilitate implementation and improve ownership

• Gauging the extent of required changes to meet Day One Reporting standards (in terms of IT, process, organization and methods) to fill in what is missing

• Reassessing current status and being able to share this information with local controllers (progress reporting, problems encountered, actions taken and other items)

• Supporting the continued ownership of evolving requirements by the entire company and build a culture of multi-standard reporting

• Defining priorities and next steps to increase overall consistency and build synergies among Solvency II pillars and other reporting needs

• Establishing a monitoring structure to consistently and continuously improve the reporting framework and maintain momentum from stable state to steady state

To effectively address the increasing multistandard reporting requirements and the need for internal control over improved financial and prudential information, we believe insurers should consider:

• Modeling the multistandard processes in a holistic, integrated approach and consider reporting as a consistent object on a data production line, where systems, business teams and issues can address multiple concerns

• Designing processes at the macro level with the ability to access greater details concerning sub-processes, interdependencies and points of contention. This can help identify the best options for simplifying, streamlining and industrializing processes, and for organizing the annual, quarterly or biannual calendar runs

• Establishing a governance and control framework across the entire value chain to help secure multistandard productions with the required audit trail and quality levels, respecting deadlines and sign-offs, including those needed for inter-standards reconciliations

• Defining a target state―and a roadmap for getting there―and revisiting both regularly to facilitate compliance by using a progressive, step-by-step approach to allow continuous improvement and to maintain flexibility

• Monitoring and anticipating regulatory changes far enough in advance to allow for implementation―particularly in systems―and to prevent potential side effects associated with imposing one standard over another

• Integrating the different business and IT teams in a culture of multistandard reporting and fostering the implementation of sound practices in the organizations, including, in our view, moving from a project mode basis to a production mode basis both at the operational and management levels

• Regularly benchmarking against market practices on day-to-day issues while recognizing each company’s uniqueness and specificity

Addressing Areas of Concern

Through the use of technologies such as big data, analytics and digital―combined with a robust methodology―we may envision an innovative user experience in which an insurer’s solvency ratio is available on demand. The digitally connected Chief Financial Officer (CFO) and Chief Risk Officer (CRO) need only look at his or her smartwatch and see in real-time the company’s Solvency II ratio

as it responds to market developments related to its investment portfolio or to its policies. Though hypothetical, this may be the future of prudential management.

Accenture is committed to help clients embed analytics and digital approaches. We work with clients to tackle quantitative calculations and reporting, and deliver analytically-driven

information that supports quicker, smarter and more confident decision making. Accenture brings agility to client assignments, the capabilities to connect people to technology and the skills and know-how to support sustainable interactivity in the day-to-day management of the client’s business.

Insurance Reporting on Demand

The Possible CFO and CRO Reality Levers and Benefits

Insurer 2.0

SOLVENCY II ratio195%

11 June10:56

Big data/Analytics/Cloud

Digitalized processes

Operational über-simplicity

On-demand real-time key performance indicators

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To do this, insurers should keep five key points in mind:

1) Understand the dynamics of reporting templates.

In responding to Solvency II requirements, knowing how the Solvency II Quantitative Reporting Templates (QRTs) work together in addressing business and technical validations is, in our view, essential to building a robust closing framework.

The production of QRTs can be compared to a railway network, both at the IT and process levels, with cross-platform interchanges between systems and where junctions may bridge gaps between actuarial engines and reporting applications, or between an upstream system and an accounting tool. The different QRT processes meet at major points of reconciliation (hubs) such as the balance sheet (e.g. BS-C1) or the own funds (e.g. OF-B1).

Increasing the efficiency of the entire process depends on understanding the precise linkages between current regulatory standards, processes, sub-processes, reconciliations and other elements. As suggested by Figure 4, smart workflow design and implementation of the Solvency II closing framework may help insurers reap tangible and scalable benefits, particularly in dealing with shorter closing deadlines associated with IFRS 4 Phase II.

Building a Holistic Reporting Framework

Meeting the challenge of insurance reporting calls for a balanced view, with both detailed and big-picture understanding of the reporting requirements and how they translate into operational actions.

Figure 3. High-level QRT Table of Elements

Figure 4. High-level Reporting Linkages

Source: Accenture, October 2015

Source: Accenture illustrative analysis based on publicly available EIOPA documents, October 2015

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60 89 26 29 16 3287 Data Validations

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2) Set up a tentative system of insurance reporting beyond QRT.

Having identified the components of the EIOPA QRT and grasped their theoretical complexity, insurers can use this as a building block to address other insurance reporting requirements. This, we feel, is instrumental to addressing in an integrated and effective manner the various demands, requirements and granularity of requests from the different regimes including local GAAP, IFRS (IFRS 9 and IFRS 4 Phase II) and ORSA.

3) Build a process which bundles Gantt and PERT (Program Evaluation Review Technique) dimensions.

This is important for understanding and visualizing the dependencies between reporting templates on the critical production path and the expected completion time for each assigned task. By integrating logical and chronological dimensions, the coordination team can help steer the production of financial and prudential deliverables and guide the business teams in aligning their activities to the closing framework, and thus promote operational excellence (see Figure 5).

4) Establish a balanced process. Insurers need the ability to access detailed information and, if required, use an integrated approach to address specific issues on a timely basis.

This capability should be built on knowledge and skills at both the micro and macro levels. For example, defining a holistic multinorm process or defining the specific needs of a sub-process such as financial or prudential communication should be integrated as part of a whole, in order to avoid discrepancy in the expected end states. As seen in Figure 6, investor relations communication should be fueled by upstream key risk and performance indicators (KRIs and KPIs) and outputs from the closing processes including Solvency II.

5) Despite unknowns, a proactive mindset is encouraged.

Even if there are many unknowns surrounding the implementation of Solvency II and other major regulatory directives, insurers are encouraged to prepare the high-level production process of the full reporting package, with all components identified, and with details

addressed when published. This proactive mindset and approach may help avoid potential future problems.

Ideally, reporting should not be a siloed activity. It overlaps multiple functions and operations across the enterprise. Getting reporting and the associated production process right can help insurers better understand their data capabilities and may help them convert their data into valuable insights. An integrated reporting framework comprising multiple dimensions supporting regulatory requirements and demands (as seen in Figure 7), and the right technology, could help improve the efficiency of the reporting process and the organization’s operational focus. This also helps management gain access to appropriate and timely KPIs and KRIs without stretching their people, process and technology resources.

Figure 5. Example of a High-level Reporting Flow in a Solvency II-era

Figure 5 presents an illustrative and generic view of a high-level target reporting plan in a Solvency II-era. This should be customized to address the insurer’s particular situation and completed with its relevant finance and risk workstreams (depending upon factors such as the insurer’s internal ambitions around closing dates, its geographic presence and its product portfolio among others).

Source: Accenture, October 2015

94 60 89 26 2987

FSR: Financial Stability ReportingSolo Group

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January February March April May June July AugustOctober DecemberSeptember November September

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Figure 6. Integrating Solvency II within External Communication

Figure 7. Connecting the Different Insurance Standards in a Consistent Way

Source: Accenture, October 2015

Source: Accenture, October 2015

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Conclusion

By now, insurers should have developed a roadmap to prepare for the January 1, 2016 Solvency II implementation and Day One requirements.

There are numerous areas requiring attention and fine-tuning. These include the effectiveness and efficiency of the Solvency II production reporting framework, the proper grasp and understanding of final QRT content and requirements, accelerating the calculation and reporting process, and alignment with other data collection needs (both qualitative and quantitative.)

The introduction of new, complex reporting requirements such as Solvency II Pillar III, IFRS 9 and IFRS 4 Phase II, and the convergence of financial and prudential standards, finance and risk, and static and dynamic data calls for a sophisticated and holistic approach to reporting using solid capabilities. Insurers may take advantage

of the changes in reporting standards to strengthen their reporting frameworks from an integrated (end-to-end) perspective and thus benefit the entire company.

We believe insurers who see beyond their short-term compliance efforts and, instead, implement an effective reporting function, position themselves to improve the overall performance of their business units while avoiding compliance issues. They can reach this desired state by addressing reporting process issues in a holistic approach.

Streamlining production frameworks in an integrated way―with deep functional understanding and knowledge in the IT area―is not an easy task. However, we encourage insurers to follow this path as this may help the data production value chain run more smoothly and reliably. This provides a benefit to all insurers addressing regulatory regimes that are still in flux.

Accenture Finance & Risk Services brings together Accenture’s consulting, technology and outsourcing assets along with deep insurance industry knowledge to help insurers meet changing external market challenges and respond to their complexities with confidence. We understand the finance and risk space and work with insurers to deliver IT and business-oriented applications and systems to drive competitive advantage. Figure 8 offers a quick overview of how Accenture can help insurers address their finance and risk transformation.

As Solvency II is about to come into force, insurers are under pressure to incorporate data and content of greater quality into their financial reporting.

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Accenture Finance and Risk Integrated Insurance Reporting Transformation

Finance and Risk Optimization Triangle

CFOs and CROs in the insurance industry face a tsunami of regulatory changes and economic pressure requiring them to do more with less.

We bring together Accenture’s...

What is the burning platform?Key o�erings and services

What do we do?

Functional focus

Did you know...

For more information, visitwww.accenture.com/financeandrisk

• Increasing multistandards regulatory demands• Growing focus on finance and risk convergence• Intensifying pressures on cost reductions

Insurance Finance and

Risk functional knowledge

Technology Consulting

Operations capabilities

+ +

To address these looming challenges, firms should re-evaluate their operating frameworks and re-define the way their teams operate. They should define their specific transformation ambition articulating functional and IT scopes and levels of e�ciency and integration.

Our focus: Develop integrated solutions to help clients embed compliant, streamlined and e�ective processes into their business as usual activities. We help them to define and implement consistent, e�cient, operational, and fully-articulated, multiclose and multinorm target frameworks.

We help insurers streamline their operating frameworks in terms of process and organization, integrate finance and risk functions, align and integrate disparate sources of data, and deliver the technology solutions to operate in a seamless and integrated way (from collection to communication of data through calculation and reporting).

1. Solvency II (MVBS, ORSA, QRT, RSR…)

2. Integrated Fast-Close (Statutory/Prudential)

3. Accounting/Actuarial Convergence

4. End-to-End Reporting Framework

5. Financial Communication (KPI, Steering…)

6. Regulatory Reporting (NST, ECB, FSB…)

7. Process Remediation (Audit, Control…)

8. Finance and Risk Transformation

9. New Standards (IFRS 4/9, BCR, HLA…)

10. Business Intelligence and Analytics

We have finance and risk resources in

We provide services to all types of insurers

Actuary Accounting Reporting

Key areas we work with...

+40 Life/Non-LifeReinsurerSolo/Group…countries

Risk/ Calculating

business services

General/Technical

accounting, Investments, Consolidation

Regulatory/ Internal, Financial

communication

Focus on streamlining operational processes and operations to address regulations and cost pressures.

• Increased cost of operations• Need for timeliness, consistency and accuracy

• Increased capital, accounting, prudential and reporting requirements

Costs

Complexity Regulations

Streamline processes

Align data and

calculations

Deliver technology

Access talent

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Figure 8. Accenture’s Approach to Insurance Reporting Transformation

Source: Accenture, October 2015

Copyright © 2015 Accenture All rights reserved.

Accenture, its logo, and High Performance Delivered are trademarks of Accenture.

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References1. “Sergio Balbinot conference opening

speech – 27 May 2015,” Insurance Europe. Access at: http://www.insuranceeurope.eu/sites/default/files/attachments/7th%20International%20Insurance%20Conference%20-%20Opening%20address%20Sergio%20Balbinot.pdf

2. “Need for high quality public disclosure: Solvency II’s report on solvency and financial condition and the potential role of external audit,” European Insurance and Occupational Pensions Authority, June 29, 2015. Access at: https://eiopa.europa.eu/Publications/Other%20Documents/EIOPA_high%20quality%20public%20disclosure_Solvency%20II.pdf

About the AuthorsEric JeanneEric is a Managing Director – Finance & Risk Services, based in Paris. He specializes in Risk Management and Finance for the insurance industry, with a focus on Enterprise Risk Management framework, Solvency II and Risk and Finance architecture. Eric has been with Accenture for more than 15 years, leading large transformation projects at major insurance and reinsurance companies, and helping clients to transform their Risk and Finance capabilities and processes.

Fabien OulmontFabien is a Senior Manager – Finance & Risk Services, based in Paris. Specialized in Finance and Risk matters for the insurance industry, he works with clients to transform their processes, methods, tools and organization to drive value. With a focus on major regulatory agendas including Solvency II, he brings his cross-functional and technical skills to help insurers build, operationalize and streamline their end-to-end financial and prudential information capabilities.

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