Supervisory Statement SS2/25 from the Prudential Regulation Authority (PRA) provides guidance on prudential considerations for UK insurance and reinsurance undertakings transferring risk to Special Purpose Vehicles (SPVs). It clarifies expectations for ensuring such transfers comply with Solvency II requirements, focusing on risk transfer validity, capital relief recognition, and supervisory approval processes. This matters because it aims to enhance transparency and risk management in reinsurance arrangements, reducing potential regulatory arbitrage while supporting efficient risk mitigation for insurers amid evolving market dynamics.
What Changed
Risk Transfer Validation: Firms must demonstrate that SPV risk transfers provide genuine economic risk transfer (ERT), not just accounting or regulatory capital relief, with PRA emphasizing substance over form (e.g., no "orphan" SPVs without genuine third-party capital).
Capital Relief Criteria: Introduces stricter tests for recognizing capital relief, including full collateralization requirements, independent third-party guarantees, and prohibitions on circular reinsurance structures where the cedent retains excessive risk.
Governance and Documentation: Mandates robust board-level oversight,...
What You Need To Do
- Immediate Review (by Q1 2026)
- Governance Updates
- Pre-Transaction Processes
- Reporting Enhancements
- Remediation
Key Dates
July 2025 Publication date of SS2/25.
31 December 2025 End of consultation period (feedback due on draft issued earlier in 2025). DEADLINE
1 January 2027 Effective date for new SPV risk transfers; all material transactions post this date require PRA pre-notification.
30 June 2027 Deadline for firms to review and remediate existing SPV arrangements for compliance (with phased reporting starting Q1 2027). DEADLINE
from 2027 .
Compliance Impact
Urgency: High โ This is not a full regime shift but imposes immediate review obligations on firms with SPV exposure (estimated 20-30% of PRA-regulated insurers). Non-compliance risks capital add-ons, transaction disapprovals, or enforcement under PRA's Fundamental Rules, especially as PRA ramps up thematic supervision post-2025. Matters for capital efficiency in a high-interest-rate environment where SPVs are popular for cat risk.