159 Days to the Revised Solvency II Framework: what should management have under control by now?

With 159 days to go until the revised Solvency II framework applies on 30 January 2027, firms should now be well beyond identifying the changes that affect them.¹ Management should have a clear and documented view of the material financial and operational impacts, the work still required, the decisions that remain outstanding and the main dependencies between now and implementation.

That does not mean everything needs to be complete. Some elements of the framework are still being finalised, and implementation work will continue through the remainder of 2026 and into early 2027. What matters now is that the remaining work is understood, owned, and managed through a credible implementation plan. The regulatory position is sufficiently developed for firms to make substantial progress. The revised Delegated Regulation has been published, while EIOPA completed its mandated Guidelines and draft technical standards in July. Irish transposition and related domestic work continue.²

The Central Bank of Ireland has also made clear that firms should continue preparing where the available regulatory material provides a reasonable basis to do so. For reporting, for example, it has encouraged firms to start preparations using the latest draft requirements rather than wait for formal adoption.³

At this stage, firms should increasingly be able to demonstrate implementation rather than simply regulatory analysis.

1. The material financial and business impacts should be understood

The Review includes changes across technical provisions, long-term guarantee measures, own funds, elements of the standard formula, reporting, proportionality, and group solvency.⁴ The impact will vary considerably by firm. Management should by now understand where the material exposures are and have a sufficiently developed view of the likely balance-sheet, capital and, where relevant, profit-and-loss implications.

The numbers do not all need to be final, but management should know which impacts are quantified, which remain provisional and what could materially change the position. This matters beyond the solvency ratio. Depending on the firm, the Review may have implications for capital planning, dividend capacity, investment decisions, reinsurance, product economics, and the wider business plan. A detailed change inventory remains useful, but management also needs a documented view of what those changes mean for the firm and the decisions that may follow.

2. Regulatory analysis should now be translating into implementation

Most firms will have spent considerable time identifying the relevant changes and assessing their implications. The focus should increasingly be on what needs to change in practice. That may include models and calculations, systems and data, policies, governance arrangements, regulatory reporting, controls, and documentation. For material changes, there should be a clear connection between the requirement, its impact on the firm, ownership, any decision required and the implementation work needed before January 2027.

An actuarial change may require model development, validation, and revised controls. Reporting changes may involve Finance, IT, data owners, and governance processes. A proportionality measure may require regulatory engagement alongside internal analysis. Reporting provides a useful example. For most calendar year-end firms, the first quarterly returns under the amended regime will be Q1 2027. The Central Bank has encouraged firms to prepare using the latest draft reporting requirements even though the QRT changes are not formally final.⁵ Where the direction and substance of a requirement are sufficiently clear, firms should be progressing the work that can reasonably be done now.

3. Remaining regulatory uncertainty should be actively managed

There are still areas where the final position is developing. EIOPA published its latest package of Guidelines and draft technical standards on 15 July 2026. Its revised Guidelines will apply from 30 January 2027, while draft technical standards remain subject to European Commission adoption.⁶

Firms need to distinguish between matters where final regulatory detail is genuinely required before work can progress and those where implementation can proceed using the material already available. Where the direction and substance are sufficiently clear, the latest regulatory material can provide the implementation baseline. Items still subject to adoption should be tracked through change control, with the final requirements checked once adopted and implementation adjusted where necessary.

A stitch in time saves nine applies here: resolving known implementation issues now is likely to be easier than discovering them during testing or close to the January deadline.

For each significant open point, management should know what remains outstanding, whether it affects delivery, what can proceed in the meantime and when the position will next be reviewed.

4. Material decisions and regulatory engagement should be visible

Important decisions should not remain within individual technical workstreams without clear management visibility. Some may affect capital, implementation effort, regulatory engagement, or the firm's operating model and therefore require senior management or Board involvement. The revised proportionality regime is a current example. The Central Bank has established a pre-application process for non-SNCU firms considering proportionality measures, with submissions open from 1 to 30 September 2026. The pre-application itself does not amount to pre-approval.⁷

A firm considering that route needs to determine which measures are relevant, whether the expected benefit justifies the work involved and what needs to happen internally and with the regulator. The programme should distinguish clearly between decisions already taken, decisions still required, regulatory applications or engagement, external dependencies and implementation issues that are becoming delivery risks.

5. Cross-functional delivery and evidence should be under control

Solvency II implementation will naturally involve several functions. Actuarial, Risk, Finance, Compliance, IT, and data teams may all own parts of the implementation, making the interfaces between workstreams as important as the individual workstreams themselves. The risk is that individual workstreams progress while dependencies between them are identified too late. Reporting changes, for example, can affect data, systems, controls, governance, and sign-off processes.⁸

Liquidity requirements may also have implications for investment processes, stress testing, management information, and escalation arrangements.⁹ Management should have confidence that cross-functional dependencies have been identified and that changes led by one function are reflected in the processes, controls, and evidence of others. The evidence supporting implementation is also becoming more important. Identifying a requirement and allocating an owner may have been sufficient at an early stage. It is not sufficient evidence that implementation has taken place.

Progress should increasingly be supported by completed analysis, documented decisions, model or systems changes, testing, updated documentation, approved policies, and implemented controls. If the regulator asked the firm tomorrow to explain and evidence its implementation position, there should be a clear trail showing how the relevant requirements were assessed, what decisions were taken and what supports the reported progress.

6. Management and the Board should be seeing the material position

Senior management and the Board do not need a detailed summary of every Solvency II amendment. They do need a reliable and documented view of the matters that could affect the firm's financial position, regulatory obligations, or ability to implement on time.

That should normally cover:

• material balance-sheet, capital, and business impacts;
• significant decisions still required;
• regulatory dependencies and applications;
• implementation areas at risk of delay;
• material cross-functional issues;
• evidence supporting reported progress; and
• matters requiring management or Board action.

The underlying governance matters as well. The position should be supported by appropriate papers, recorded decisions and evidence of how material issues have been considered and escalated. A programme can look tidy on the dashboard while there is still significant work under the bonnet. For management and the Board, reporting needs to translate into what matters for the firm: financial consequences, outstanding decisions, uncertainty, delivery risks, and actions required.

If the CEO or Board asked tomorrow for a concise written update on the firm's Solvency II Review position, the programme should be able to provide one that can be read and understood without a lengthy verbal explanation.