Life after the removal of Excel-based CRD IV reporting in Portugal

In June 2014, to ease the transition to its new CRD IV reporting regime, the Bank of Portugal introduced a free reporting system based upon the completion of Excel spreadsheets. Not surprisingly, very many Portuguese financial institutions took this easy way out and for the past year have been filing their CRD IV returns using this method.

Only XBRL accepted from the end of June 2015

However, as was fully explained at the time, reporting in Excel was introduced as an interim step only, and the ability to use the spreadsheet-based system is about to disappear. From the end of June 2015 the large number of filers currently using the Excel-based reporting application will have to find an alternative approach.

Seahorse, the XBRL lifeline

Seahorse®, CoreFiling’s cloud-based XBRL conversion software, will provide a lifeline to Portuguese financial institutions now that they need to find ways of converting their spreadsheet data into fully validated XBRL instance documents before submission to the Bank of Portugal. Seahorse provides an easy to use, risk-free solution to the problem of complying with the CRD IV XBRL mandate. It is a SaaS-based application, readily accessible from any internet browser. There is no software to install or maintain, and Seahorse requires no effort on the part of the user when taxonomy changes occur, as these are handled behind the scenes.

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The count-down to Solvency II Pillar 3 reporting – 5

How do I keep up to date with XBRL taxonomy changes?

The whole process of gathering relevant data and implementing an effective workflow to turn that data into valid XBRL reports is daunting enough, but the challenges do not stop there. What happens when the underlying XBRL taxonomy changes, as it undoubtedly will? What solutions are available to help smooth the reporting process?

The impact of Solvency II taxonomy changes

Without specialist insight into the taxonomy structure it is difficult to understand what changes have occurred from one version to the next and, more significantly, how the changes might impact both technical considerations and the preparation of XBRL reports.

Compliance with EIOPA business rules

The business rules imposed by EIOPA and the NCAs may also be amended from time to time, and this could have a profound effect on the data that needs to be reported. How will your reporting systems cope with frequent updates? How will you make sure that your systems remain current, producing totally valid XBRL documents that will not be rejected at the point of submission?

Some systems rely on hard-coding and may prove inflexible, so you would do well to make sure that you will not incur massive system and cost overheads just to bring your reporting into line each time.

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The count-down to Solvency II Pillar 3 reporting – 4

How do I report to my NCA?

Although it remains at the discretion of the individual NCA, many regulated firms will find that they must now submit their quantitative reports in XBRL, which may be an unfamiliar format presenting a new set of challenges, particularly since there is now so much more data to be handled (at a recent conference estimates were quoted at over 10K data items for solo reporting, and 200K for group reporting during the preparatory phase, increasing to around 40K and 800K data items respectively when full scope reporting arrives in January 2016).

Integration or standalone?

How to handle the data is a key issue. Many insurers will have existing workflow and security processes in place, but must now integrate them with the less familiar requirements of XBRL preparation, validation and rendering, so both the IT department and the business will need to engage to ensure that the relevant data can be captured and turned into the required reports.

Decisions need to be made: whether to create a standalone environment or embed reporting into current architecture; whether to rely on process professionals to provide the specialist XBRL capabilities (which may be outside their core competence), or to seek help from a dedicated XBRL technology company.

Continue reading “The count-down to Solvency II Pillar 3 reporting – 4”

The count-down to Solvency II Pillar 3 reporting – 3

What do I report?

As mentioned in the previous Blog Post, even firms that begin reporting during the Solvency II preparatory phase will notice a hefty increase in the number of templates they need to complete when full scope reporting arrives in January 2016.

Quantitative and qualitative reporting

Solvency II Pillar 3 brings a huge increase in the amount of data that needs to be reported. For example, for the first time detailed asset data must be included. Firms will also need to take into account a new set of reporting requirements, relating to both quantitative and qualitative disclosures. Under Pillar 3, the main focus is on two particular reports, which require both qualitative and quantitative data:

  • SFCR – Solvency and Financial Condition Report
  • RSR – Report to Supervisors

Public vs private reporting

Reporting also occurs on two levels – public and private. For example, a few of the quantitative templates and qualitative data will be made public in the SFCR, whereas all quantitative templates and a detailed set of qualitative data must be reported privately to the regulator in the RSR.
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The count-down to Solvency II reporting – 2

Do I need to report and when?

In the second of our blog series, we examine which insurance undertakings will have to begin reporting under the preparatory phase that EIOPA has introduced as a precursor to full Solvency II reporting which finally takes effect in January 2016.

While all insurers are expected at least to start preparing for the full implementation of the Solvency II regime, only certain organisations meeting prescribed thresholds will need to report to their NCA during the preparatory phase, but this is due to begin in June 2015, so time is very short.

Interpretation of the EIOPA thresholds

The thresholds specified by EIOPA are:

  • Individual annual reporting for firms representing at least 80% of the national market share
  • Individual quarterly reporting for firms representing at least 50% of the national market share
  • Group quarterly or annual reporting for firms with more than EUR 12 billion (period ending during 2012)

Continue reading “The count-down to Solvency II reporting – 2”

The count-down to Solvency II Pillar 3 reporting – 1

The insurance industry prepares

Although there are still several months to go before full scope reporting begins under the new Solvency II Pillar 3 regime, the deadline for preparatory reporting is imminent for those insurance undertakings included in the first phase.

The focus of Pillar 3 of the Solvency II regime revolves around supervisory reporting and transparency requirements, and will mean a seismic shift upwards in the volume of data to be extracted and reported as well as the frequency of the report submissions.

Reporting formats

So that it can manage and analyse the large amount of data reported under Solvency II, EIOPA has specified XBRL (eXtensible Business Reporting Language) as the filing format. Although XBRL is only mandatory between National Competent Authorities (NCAs) and EIOPA, some NCAs are insisting that their regulated firms also submit their quantitative returns in XBRL, with narrative returns submitted in some other electronic format. For example, the Bank of England/PRA requires quantitative reports in XBRL and narrative reports in PDF format. This will, however, vary from country to country.

Continue reading “The count-down to Solvency II Pillar 3 reporting – 1”