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CP22/25 – UK Solvency II reporting and disclosure: Post-implementation amendments

AI Analysis

Executive Summary

CP22/25 is a consultation paper on post-implementation amendments to UK Solvency II reporting and disclosure requirements, published by the PRA on 4 December 2025. The consultation addresses feedback and queries from insurance firms following the substantial reduction in reporting templates implemented at the end of 2024, clarifying expectations for compliance with the revised Reporting Part of the PRA Rulebook across multiple technical areas including accident/underwriting year reporting, annuity reporting by currency, and internal model governance disclosures.

What Changed

The consultation introduces clarifications and amendments to Solvency II reporting requirements in several critical areas: Reporting Framework Modifications - Accident or underwriting year reporting: The PRA sets expectations for how firms should apply options within the Reporting Part of the PRA Rulebook regarding temporal classification of claims. - Annuity reporting by currency: Specific guidance on reporting annuities stemming from non-life obligations disaggregated by currency. - RBNS claims development: Clarification on reporting of reported but not settled (RBNS) claims and their development patterns. Internal Model Requirements - Firms using partial or full internal models for Solvency Capital Requirement (SCR) calculation must describe governance information including responsibl

What You Need To Do

  • *Immediate Actions (January-February 2026)
  • *Review consultation paper
  • *Assess applicability
  • *Identify gaps
  • *Engage supervisory contacts
  • *Medium-term Actions (February-June 2026)

Key Dates

4 December 2025 - PRA published CP22/25 consultation paper
31 December 2025 - Baseline date for commencement of new annual quantitative reporting template requirements (AoC.01) for firms with financial year-end on or after this date
31 December 2025 - Baseline date for commencement of quarterly QMC.01 reporting for internal model firms with financial year-end on or after this date
55 business days after quarter-end - Deadline for quarterly QMC.01 submission (internal model firms) DEADLINE
100 business days after financial year-end - Deadline for annual AoC.01 submission (internal model firms and groups) DEADLINE
Consultation period - Specific end date not provided in search results; firms should confirm via PRA website

Compliance Impact

Urgency Rating: HIGH

Who is Affected

*Primary Affected Firms:Insurance firms subject to UK Solvency IIregulated insurers, including life and non-life insurersInternal model usersMatching adjustment portfolio usersGroups with internal model permission*Secondary Stakeholders:PRA supervisory contacts and compliance teams within affected firms

Summary

Consultation paper

Relevant Firm Types

Insurance
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