This paper offers a proposal for public risk disclosure under Solvency II, as a basis for discussion on the implementing measures for articles 50-55 of the EU Solvency II Draft Directive. The CRO Forum advocates a principles-based approach: Section B of this paper establishes five main principles for public risk disclosure which should be adhered to by all undertakings. These are aligned with the Guidance paper on public disclosure by insurers provided by the International Association of Insurance Supervisors (IAIS) in 2002. Next, section C outlines the general scope of public risk disclosure. However, in line with the proportionality principle set out in Solvency II, the required scope and level of detail may vary, depending on the nature, scale and complexity of an undertaking’s business. Finally, the appendix provides an example of a Report on solvency and financial position for a multi-national Group with a complex business structure. The public risk disclosure requirements under Solvency II add to the existing requirements under IAS 1, IFRS 4 and IFRS 7. In order to avoid duplication, the CRO Forum proposes combining public risk disclosure with financial reporting and using referencing where appropriate. However, this raises the question of auditing, which is not currently required for public risk disclosure: IFRS 7 only allows references to information or sections outside the audited statements if the referenced figures are also audited. Further clarification is required on the auditing of capital requirements and Solvency II valuations. In addition, this paper does not yet include a description of the methods used for the valuation of assets and liabilities, as described in article 50 (1) (d) of the Solvency II directive.
