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 responsible roles, specific committees, their tasks, position, and scope of responsibilities.
- New quarterly reporting template QMC.01 requirements for internal model firms, including supporting qualitative information and narrative documentation, with submission deadlines of 55 business days after quarter-end.
Suggested Considerations
- *Immediate Actions (January-February 2026):
- *Review consultation paper: Obtain and analyze CP22/25 in full to understand proposed amendments
- *Assess applicability: Determine which reporting requirements apply to your firm (internal model status, portfolio types, reporting obligations)
- *Identify gaps: Compare current reporting processes against PRA expectations outlined in the supervisory statement (SS4015)
- *Engage supervisory contacts: Discuss any planned changes to reporting methodology (e.g., accident vs. underwriting year classification) with PRA supervisory contacts prior to implementation
- *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 DEADLINE
end; - Deadline for quarterly QMC.01 submission (internal model firms) 100 business days after financial year DEADLINE
end; - Deadline for annual AoC.01 submission (internal model firms and groups) Consultation period
- Specific end date not provided in search results; firms should confirm via PRA website Compliance Impact
Urgency Rating: HIGH
Who is Affected
References
AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.
Summary
Consultation paper