PwC insurance regulatory reform poll - Pillar 3

27 March 2014

  • 68% of insurers are still less than half way through their Pillar 3 reporting journey- PwC poll. 
  • 71% are still at the 'assess' stage of preparations, only 2% feel they are at an implementation stage.
  • 39% think there will be some impact on share price/valuations when Pillar 3 numbers are reported, and around one third of firms have not considered a possible effect.
  • The top three challenges of Pillar 3 reporting are seen as: technology, data sources and reporting time frames.

As Solvency II reporting deadlines get ever closer, a poll of insurance industry leaders and experts by PwC has highlighted that 68% of insurers are still less than half way through their Pillar 3 reporting journey. Nearly three quarters are at the 'assess' stage of their preparations, where they feel they have understood the reporting requirements and are aware of their systems deficiencies and gaps. Only a very low level (2%) of respondents have dry run Solvency II reporting and are ready to embed this into their business as usual reporting processes. Over a third of respondents (39%) think that the results of Pillar 3 reporting will impact share price, indicating the impact that putting Pillar 3 information into the public domain could have.

The poll, highlighting the industry sentiment around aspects of the Solvency II Pillar 3 reporting process, also reveals that the top three challenges for insurers are considered to be: technology, including changes to current systems architecture such as data storage and retrieval, and end user computing; data sources, i.e obtaining quality data that is internally consistent and reconcilable to other systems and financial reports; and reporting time frames -  managing solo and group annual and quarterly reporting within the required timeframes.

Charles Garnsworthy, partner and Solvency II leader at PwC, said: "Our poll of industry leaders has highlighted that there is still a lot to think about in the reporting of Pillar 3 to the regulator.  Insurers are still figuring out what it all means, but they recognise that the complexity of what is required is high. The purpose of Pillar 3 is market discipline. A lot of information will go into the public domain when companies report on Pillar 3, and the question is how is the market going to react? There will most likely be effects on valuation or share price as competitors, regulators and other stakeholders have transparent access to this new information.  

"Pillar 3 reporting is about making sure there is a story that flows the whole way through the Pillar 3 documents, taking the company's data and turning it into information that will satisfy the regulator. This may appear to be a simple objective from the outside, but it's not going to be a simple process. It's complex, and it is crucial that it is built into the DNA of the organisation.

"Insurers will need to decide how, and when, they are going to tell the story. Communicating to the market is just as important as getting the numbers ready and firms need to reflect on how this affects their current strategy. For example, enhanced disclosures may prompt changes to hedging strategies or reinsurance programmes and insurers must be able to make a clear link between what they tell the market and what is in the detailed disclosure."

The poll was conducted across a group of 60 business leaders across the UK insurance industry, including CFOs, COOs, FDs, FCs, heads of compliance, Solvency II leads, and non-executive directors.

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