Solvency II Review 2027: what insurers need to change before 30 January.
The revised Solvency II framework applies from 30 January 2027. Insurers should assess technical provisions, risk margin, proportionality, liquidity, reporting, governance and the evidence used to demonstrate implementation.
Why January 2027 requires an implementation programme
The review changes the existing prudential framework rather than replacing it. Directive (EU) 2025/2 amends Directive 2009/138/EC, while Commission Delegated Regulation (EU) 2026/269 updates the detailed framework. EIOPA completed its review-mandate package in July 2026.
A calculation change can affect actuarial methodology, data, model documentation, finance outputs, reporting and governance evidence together. Assess every requirement against the operating model rather than routing it to one technical team. For the underlying framework, see the Solvency II overview.
Six workstreams to assess
1. Risk-margin methodology
The review introduces a time-dependent element commonly described as the lambda factor. EIOPA's revised technical-provisions guidelines address the new approach. Retain the approved interpretation, data and assumption lineage, model testing, result comparison, governance approval and downstream reporting impact.
2. Proportionality and small and non-complex undertakings
The revised framework introduces a new proportionality structure. Eligibility should not be inferred from size alone. Document the criteria, supporting data, governance conclusion, supervisory interaction and every simplification relied upon. EIOPA has published technical specifications for small and non-complex undertakings and groups.
3. Liquidity-risk governance
Trace liquidity-related changes into monitoring, escalation thresholds, management information, stress scenarios, contingency actions and evidence available to supervisors.
4. Matching adjustment and ring-fenced funds
Connect legal interpretation to portfolio designation, model logic, assumptions, controls, documentation and reporting. Confirm how revised guidance affects the treatment of ring-fenced funds.
5. Reporting and public disclosure
Inventory affected templates and instructions, compare old and new data definitions, update validation rules, test source-to-report lineage and preserve review and sign-off evidence. Review related dependencies in the Solvency II TPT guide.
6. Governance, ORSA and evidence
The ORSA remains part of the risk-management system under Article 45. Route material risk-profile and strategic impacts into the ORSA governance workflow, with an owner, affected policy or model, control, evidence and status for each change.
Solvency II Review 2027 implementation checklist
| Step | Question | Evidence to retain |
|---|---|---|
| Establish scope | Which Level 1, Level 2, guidelines and standards apply? | Source inventory, applicability decisions and legal review |
| Assess impact | Which calculations, models, reports, policies and controls change? | Requirement-to-process and control mappings |
| Assign ownership | Who owns interpretation, implementation, testing and approval? | RACI, governance minutes and escalation record |
| Update methodology | What assumptions, formulas, data or modelling steps change? | Method papers, model versions and approvals |
| Update reporting | Which templates, definitions and validation rules change? | Data dictionary, lineage, reconciliations and tests |
| Validate | Do new results flow correctly to every output? | Parallel runs, exceptions, remediation and sign-off |
| Operationalise | How will later regulatory changes be monitored? | Change workflow, alerts and review evidence |
A practical implementation timeline
September–October 2026: freeze the source inventory, identify affected entities and build the requirement-to-operating-model map.
October–November 2026: approve interpretations, update methods and data requirements, and design model, reporting and control changes.
November–December 2026: complete parallel calculations, reporting dry runs, control testing and governance review.
January 2027: deploy approved changes, confirm production lineage and access, complete sign-off and prepare the evidence package.
Connect prudential and accounting impacts through the Solvency II and IFRS 17 operating model.
Frequently asked questions
When does the revised Solvency II framework apply?
The principal reviewed framework and related changes are intended to apply from 30 January 2027. Firms should confirm the applicable EU instruments, national transposition and supervisory communications for every entity in scope.
Does the Solvency II review replace the existing Directive?
No. It amends the existing Solvency II framework. Implementation inventories should show what changed, what remained in force and which consolidated source version controls each conclusion.
Is the review only an actuarial calculation change?
No. It includes calculation-related changes, but it can also affect proportionality, governance, liquidity, reporting, disclosure, documentation and supervisory evidence.
What should an insurer finish before January 2027?
At minimum: an approved applicability assessment, updated methodologies and controls, tested calculations and reports, assigned ownership, resolved exceptions and a traceable evidence pack.
How should the review connect to ORSA?
Assess whether the changes affect the undertaking's risk profile, overall solvency needs, continuous compliance, scenarios or strategic decisions. Preserve the link between the regulatory change, ORSA analysis, management conclusion and resulting action.
This guide is general information, not legal or actuarial advice. Confirm national transposition, supervisory communications and the facts of each entity.