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International ORSA Regulatory Requirements Chart

ORSA means the Own Risk and Solvency Assessment insurers are required to perform in their respective jurisdictions. An ORSA concept is described in Insurance Core Principle 16 of the International Association of Insurance Supervisors.
DISCLAIMER: The content of the International ORSA Regulatory Requirements Chart (the Chart) has been provided by individuals at the request of the Joint ORSA Subcommittee of the Insurance Regulation Committee and the Enterprise and Financial Risk Committee of the IAA. This information has been
collated and presented for educational and informational purposes to the members of the IAA and interested parties. The IAA assumes no responsibility for the accuracy, completeness, currency, reliability of the information in the Chart or access to any information contained on any site linked within the
Chart. The IAA, its employees and officers shall not be liable for any loss or damage, direct or indirect, which may arise or occur as a result of the use of or reliance upon any of the material in the Chart.

ORSA Regulatory Requirements Description Australia Bermuda Canada China EEA Japan Mexico Singapore South Africa Switzerland United States

SARMRA (Solvency
Aligned Risk ARSI (Autoevaluación de
Common name for the
1 Reporting requirement ICAAP CISSA ORSA Management ORSA ORSA Riesgos y Solvencia ORSA ORSA ORSA ORSA
requirement.
Requirement and Institucionales)
Assessment)

April 4, 2015; the first


one must be presented in
Date on which the requirement 2015-2-13(with 1-Jan-15 (will vary by
2 Effective date 01-Jan-13 01-Jan-11 01-Jan-14 01-Jan-16 27-Mar-15 the first half of 2016, 01-Jan-14 01-Jan-16 01-Jan-16
becomes effective. transitional period) state)
evaluating the whole
2015.

Solvency II Directive
(2009/138/EC),
COMMISSION
DELEGATED REGULATION
Life Insurance Act: (EU) 2015/35 General Law of Insurance
http://www.comlaw.gov. Both can be found @ and Bonds Institutions,
au/Series/C2004A04860 CISSA 2011 http://ec.europa.eu/fina article 69, section I a
Life Insurance Instructions nce/insurance/solvency/s through e
Regulations: olvency2/index_en.htm http://www.cnsf.gob.mx/
Handbook
http://www.comlaw.gov. (together with their CUSFELECTRONICA/LISF/L
Insurance Act 2015,
au/Series/F1996B00625Li amendments) ISF_3_1_S3. Single Notice Individual state laws
Relevant law or regulation that fe Insurance Act: http://www.bma.bm Guideline E-19 ORSA Law of insurance of Insurance and Bonds,
MAS Notice 126 in expected to be enacted
(NAIC model law "Risk
(http://www.osfi- conjunction with section in H2 2015, along with Swiss federal insurance
3 Basis for requirement provides the regulatory authority http://www.comlaw.gov. /document- (Edited version 3rd EIPOA Guideline can be Insurance Business Act chapter 3.2, rule 3.2.6 Management and Own
bsif.gc.ca/Eng/Docs/e19. 64(2) of the Insurance supporting subordinate law ("AVO")
for requiring regulatory compliance. au/Series/C2004A04860 centre/reporting- March 2009) found @ thru 3.2.9 Risk and Solvency
pdf) Act (Cap. 142) legislation (currently
General Insurance Act: https://eiopa.europa.eu/ http://www.cnsf.gob.mx/ Assessment Model Act")
forms-and- under development)
http://www.comlaw.gov. GuidelinesSII/EIOPA_Gui CUSFELECTRONICA/CUSF
au/Details/C2014C00564 guidelines/Insurance delines_on_ORSA_EN.pdf /CUSF3_2 and 7.4.2. for
General Insurance /Forms/DispForm.as Dynamic Solvency test
Regulations: px?ID=17 Small insurers not http://www.cnsf.gob.mx/
http://www.comlaw.gov. covering risky business CUSFELECTRONICA/CUSF
au/Details/F2011C00193 are excluded from the /CUSF7_4
scope of the Solvency II
Directive and hence they
are not required to do
ORSA

1. the insurance
companies and branches
of foreign insurance
All federally regulated companies legally
insurers including incorporated under the
All Insurers and Insurance
Canadian operations of approval of CIRC
Groups subject to the
foreign life and property 2. CIRC will categorise Insurers with gross
Solvency II directive
Class E, 3A, Class 3B, and and casualty companies companies into Class I premium over US$500
(individual Member State Insurance Groups and
Class 4 insurers operating in Canada on a insurance companies and Applies to any licensed Every insurer (solo million (excluding
implementations may solo insurers category 1,
Size or type of insurer to which the branch basis, as well as Class II insurance All Insurers and Insurance All Insurance and Bond insurer (except a captive requirement) and affiliate reinsurance
4 Applicability threshold All insurers vary in respect of entities 2 and 3. Insurers
regulatory requirement applies. http://www.bma.bm/ins fraternal benefit societies companies according to Groups companies. insurer or a marine insurance group (group assumed) or Insurance
not falling under the categories 4 and 5 are
urance/licensing/SitePag operating in Canada, the years of mutual insurer). requirement). Groups with gross
scope of the Solvency II exempt
es/Home.aspx except for regulated establishment, business premium over US$1
directive still applying
insurance holding size (premium and/or billion
some or all of those
companies and non- total assets) and risk
rules)
operating insurance features, different
companies solvency risk
management
requirements are
proposed respectively.

Domestic Regulator, so
Whether domestic regulators would No, unless based on an Yes, with some
far, DOES NOT allow the Yes, if it covers
Sufficiency of filing another allow the submission of a foreign established equivalence conditions (It covers
5 No Yes No No submission of a foreign No No No requirements in US ORSA
country's ORSA report ORSA report to comply with the decision that applies to ORSA on Japanese
ORSA report to comply Guidance Manual
requirement. ORSA as well subsidiary/branch, etc.)
with the requirement.
ORSA Regulatory Requirements Description Australia Bermuda Canada China EEA Japan Mexico Singapore South Africa Switzerland United States

ORSA can be prepared ORSA can be prepared


either on individual either on individual
insurer basis or on group insurer basis or on group
basis. Group ORSA should basis. If the individual
give adequate Yes. ORSA is not carried out
consideration to business 1. Insurance groups shall then Group ORSA should
and risk profile of abide by SARMRA. give adequate
individual insurers in 2. CIRC will conduct consideration to the Where entities form an
group and the particular regulatory assessment in reason for the choice of insurance group, an ORSA
circumstances of the terms of the solvency risk the Group; a description should also be produced
markets in which it management capability of how the governance at group level. However, A single Group ORSA
operates. The of insurance groups on requirements are met at insurance groups could must be filed. This ORSA
components of the Group an annual basis, to the level of these request a dispensation must be of such
An insurer which belongs
ORSA that are used to determine their control undertakings and in from the Regulator not to granularity to include
For this purpose, an insurance to a group may make use
support an individual risk. particular how the produce ORSA specific information on
group is defined as a collection of of its group’s ORSA
No, but can rely on Group insurer’s ORSA should be 3. The assessment administrative, Insurance group holding supervisory reports for the "most important"
Requirement for group reporting affiliated insurance entities while a report, provided the
6 ICAAP if it meets all APRA Yes consistent with criteria for solvency risk management or company is required to No solo entities, but a single group entities, including Yes
with type of group if required composite group is defined as a required details specific
regulatory requirements expectations of E-19. management capability supervisory bodies submit ORSA report. group supervisory report all entities that are under
group of both insurance and non- to the insurer, is clearly
of insurance groups will (AMSB: the body that, providing enough solo supervision. It
insurance entities. documented in the
be provided additionally. under SolvencyII, has information for the should also include
report
4. An insurance group ultimate responsibility Regulator to exercise its information on material
shall calculate minimum for running the entity) of supervisory duties in off-balance sheet
control risk capital the subsidiaries are respect of solo entities positions
according to appropriate involved in the approved under
assessment results and assessment process and aforementioned
relevant requirements of approval of the outcome; dispensation.
CIRC. Specific calculation and a description of how
criteria will be provided the single ORSA
additionally. document is organised in
order to allow the group
supervisor to separate
individual assessments
for the other supervisors

The Mexican legislation


does not allow the
establishment of foreign Currently no branches of
branches. Participation of foreign insurers are
Depends on state law for
foreign insurers in the allowed in South Africa.
Branches are not the branch's state of
Mexican insurance and However, there is a
required to provide ORSA Applies to insurers of "entry" into the U.S.
surety markets is proposal to allow
Required for all insurers on their own category 1, 2 and 3 (but Most states treat
Requirement applicability to Whether the requirement applies Required for all insurers Yes, given that branches Required for all insurers permitted only through See applicability branches of foreign
7 licenced in Canada Based on proportionality, Yes not 4 and 5), branches using their
branches to branches of legal entities or not. licenced in Australia roll up into legal entity licenced in China the establishment of threshold reinsurers to operate in
(including branches) branches may/should be independent of branch state as the state of entry
domiciled subsidiaries. South Africa. It would
covered in the status as if the branch were a
Subsidiaries have to then be expected that
solo/group ORSA domestic insurer in their
comply with the same these branches will be
state.
requirements than the required to conduct an
domestic companies. ORSA.
Required for all insurers
licenced in Mexico

Comprehensive
Guidelines for
Supervision of Insurance
Two separate documents Companies : "Does an
Both. A process and
are produced (1) a Primary focus: helping insurance company make
When undertaking its corresponding process
Summary Statement, decision making by the ORSA periodically and The guidelines focus on
ORSA Summary Report ORSA, the insurer shall description must be in
Basis of regulatory guidance: ORSA which summaries the OSFI expects an insurer CIRC assesses the AMSB maintain risk and capital CNSF expects an insurer what is to be achieved by
needs to be filed (some document the rationale, place (focused on the
8 process or regulatory reporting of capital assessment and to have processes in insurers and issues control process, to to have processes in the ORSA rather than on Report
specific (minimal) calculations and action reporting process). Also a
ORSA management processes, place to conduct an ORSA SARMRA report The ORSA also should be monitor whether itself place to conduct an ORSA how it is to be
content is prescribed) plans arising from this report must be produced
and (2) an annual report reported to the satisfies both the performed.
assessment. and signed off at
on the implementation of supervisor requirement on
executive level.
the ICAAP economic capital and the
capital requirement
based on solvency margin
regulation? "

CIRC issues SARMRA


The ICAAP is approved by report and knows the Management information
the Board. A copy of the solvency risk Report to AMSB ORSA must be presented on risk and capital Report signed by at least
ORSA must be presented ORSA report with the
ICAAP Report is to be management capability Report to Local and to the board and a copy management should be one Group executive.
to the board and a copy ORSA report to the Report to Board, Authority within 2 weeks
Recipient of ORSA report as per Primary audience of the ORSA provided to the Regulator of insurer by SARMRA Group Supervisor submitted to the provided to senior Report may be a full or
9 submitted to the Board, Key Metrics Report to JFSA from the date which the Lead state regulator
regulatory guidance report. annually. The ICAAP report; Insurer's capital Summary information of supervisor (Comision management and the summary report. Board
Bermuda Monetary Report to OSFi (see also A.12) ORSA report is approved
Summary Statement is to requirement (MC) of certain aspects to the Nacional de Seguros y Board must be involved in the
Authority by its board of directors.
be provided to the control risk is determined Public Fianzas) ORSA report to the ORSA process.
Regulator on request by SARMRA report supervisor.
results.
ORSA Regulatory Requirements Description Australia Bermuda Canada China EEA Japan Mexico Singapore South Africa Switzerland United States

To present to the board:


"The level of compliance
of the operational areas
... of the limits, targets,
The Commercial Insurer’s policies and procedures
Solvency Self-Assessment for overall risk
(CISSA) is a regime that management ... an
requires insurers to analysis of the overall The objectives of the
perform an assessment Document the ORSA solvency needs taking ORSA include to:
of their own risk and process and help decision into account their -ensure that the group's
solvency requirements. making by the Board specific risk profile, the board of directors and
CIRC assesses the risk
This provides the BMA Provide information to risk tolerance limits senior management
In conducting its ORSA, management capability
with the insurer’s the Supervisor on the approved by the board understand the risks that To inform the regulator
an insurer should and the level of control To assess the adequacy
perspective of the capital ORSA process and results To make suitable risk of directors and its originate from its about the insurer's risks
determine its own capital risk of the insurers, of risk management, and The report is a summary
resources (referred to as control and keep enough business strategy, strategic/business plan and solvency position.
For example, to allow Boards to needs and establish its determines the MC of current and projected of all components of the
CISSA capital) necessary The undertaking should solvency level over time. including a review of and its overall capital "The Commissioner will
take key decisions, to inform Internal Targets based on control risk of the future solvency position ORSA-relevant processes
10 Purpose of the ORSA report to achieve its business take into account the (by Comprehensive potential future impacts requirements; utilize the ORSA
Boards, to report the results of an internal assessment of insurers. As a result, MC with a time horizon (risk management, capital
strategies and remain results of the ORSA and Guidelines for the solvency based on -contribute to the Summary Report to gain
ORSA processes to the regulator. all material risks, of control risk will which is consistent with management, planning,
solvent given its risk the insights gained Supervision of Insurance the performance of the improvement of risk a high-level
including the results of directly impact the that used in its business governance)
profile, as well as insight during the process of this Companies) Dynamic Solvency management and the understanding of the
the enterprise risk solvency ratio and planning.
into the risk management assessment in at least: a) Test...compliance of the harmonisation with insurer's ORSA."
management process Integrated Risk Rating
and governance its capital management; investment liquidity and capital
(IRR) of the insurers.
procedures surrounding b) its business planning; requirements, technical management; and
this process. Risk profile c) its product reserves, reinsurance, -develop and implement
considers all reasonably development and design guarantees, warranties, appropriate control
foreseeable material risks Solvency Capital and measures
arising from its minimum capital
operations or operational Requirements... the
environment. extent to which its risk
profile deviates from the
assumptions underlying
the calculation of RCS is
based, regardless of the

Annual;
Insurers should produce
In the case of any
the full assessment at
significant changes to the Annual report, although
Tier 1 insurer: annually least annually and when
solvency risk Annual or upon update of group capital
Requirement for the frequency of (at least) there is a significant Annual or upon request
11 Frequency of the ORSA report Annual Annual Annual management capability significant change in risk Annual Annual assessment can be
ORSA reporting. Tier 2 insurer: every third change in the insurer‘s by FINMA
of an insurance company profile requested in the interim
year risk profile due to
within the year, CIRC may if material changes occur.
internal or external
conduct the assessment
conditions changing.
again.

Insurer’s Board should


review and discuss ORSA
as well as any changes to
ORSA. Board should " Have a presentation of The Board must ensure
understand decisions, the ARSI report to define that ORSA is integrated
plans and policies being and adopt the necessary into the strategy setting
undertaken by Senior measures to correct the and planning and must
The insurer/insurance
Management with shortcomings in the be aware of (and
group should ensure that
respect to ORSA and its The board of directors comprehensive risk responsible for) the
its Board and senior
potential impacts on the takes the ultimate The AMSB should take management, if any, content in the ORSA
management take an
For example, approve the ORSA insurer. It should probe, responsibilities for the active part in the ORSA, that have been detected The Board takes report. Processes whose
Role of the Board with respect to Execute ORSA under active part in the ORSA Receive a copy of the
12 report, review the ORSA report, Approve ICAAP Review CISSA question and seek effectiveness of the use ORSA results in as a result of the responsibility for the outcome form part of the
ORSA. responsibility of Board including providing ORSA report
receive the ORSA report. assurances from Senior overall risk management decision making and completion of the ARSI. ORSA. report (planning, risk
steering on how the
Management that these framework and the approve the ORSA The board of directors reporting, capital
assessment is to be
are consistent with related decisions. shall instruct and management) must be
performed and
Board’s own decisions monitor the operational reviewed regularly by the
challenging its results
and Board-approved areas responsible board and the board
business and risk strategy institution or mutual must ensure that these
of the insurer, and that company to adopt such are appropriate for
corresponding internal measures." steering.
controls are sound and
being implemented in an
effective manner.

Whether quantitative assessments


Required quantitative assessment
13 are required, encouraged, or Yes Yes Yes Yes Yes Yes Yes Yes Required Yes Yes
of risk and solvency
neither.

The insurer can choose


its own definition of
Yes (Managements are required capital, but it
Whether the alignment between required to understand must be able to show an
Linkage to required regulatory No (BSCR capital is the
14 "own" required capital and Yes Yes Yes Yes the difference of Yes Yes assessment of the Yes No
capital actual requirement)
jurisdiction's required capital. regulatory and economic material differences
capitals) between its own required
capital to the regulatory
required capital
ORSA Regulatory Requirements Description Australia Bermuda Canada China EEA Japan Mexico Singapore South Africa Switzerland United States

EIOPA Guidelines (see


Whether stress and scenario testing Point 3) require
15 Required stress/scenario testing Yes Yes, for all material risks Yes Yes Yes Yes Yes Required Yes Yes, for all material risks.
is required or encouraged. stress/scenario testing
where appropriate

3-year capital
projections:
Stress test(under Pillar I):
annual basis, including
The undertaking should
base scenario and stress
ensure that its
scenario. Under base
assessment of the overall
scenario, insurance
solvency needs is forward- "long enough to capture
company needs to
looking, including a the adverse effects
project the solvency
medium term or long thereof, so as to capture
ratios for the next two
term perspective as the responsiveness of the Time horizon should
Time period over which the accounting years. Under
Horizon for forward looking Three year capital appropriate (EIOPA 1.21). administration to these Has to be consistent with correspond with the Planning horizon, at least Business planning
16 assessment is required to be Planning horizon Planning horizon stress scenario, insurance 3 to 5 years as example
assessment projections As the ORSA should pass effects. The projection the business planning. business planning cycle. three years horizon
conducted. company needs to
the use test, i.e. it should period for life insurance, (typically 3 – 5 years)
project solvency ratio for
also be used by the will be at least five years,
the next accounting year.
company in its planning, and for the non life, at
Pillar II: Life & Health
the horizon probably least two years
insurance companies
usually is consistent with
should run regular cash
the business planning
flow stress test, which
period
includes base scenario
and stress scenario. Cash
flow stress test is part of
liquidity risk
management tools.

Where an
insurer/insurance group
uses a valuation basis
different from the SAM
basis for assessment of
its overall solvency
needs, it has to explain
how the chosen basis
ensures better
consideration of its risk
profile, approved risk
C-ROSS basis: GAAP appetite (and related
based assets and tolerances) and business
liabilities valuation strategy.
Solvency II basis can be
approach, excluding a Mexican Statutory The chosen basis should
IFRS (same basis of used, or any basis that Japanese Statutory (and IFRS (same basis of
few adjustments to the Accounting, similar to comply at all times with Insurer's choice, but must Insurer's choice, but must
17 Valuation basis Australian Economic Balance Sheet reporting for public and the AMSB considers more Economic reporting for public and
asset and liability Solvency II (economic the overarching disclose disclose
statutory purposes) appropriate than the (recommended)) statutory purposes)
measurement standards basis) governance principle of
Solvency II basis
made by the CIRC for the sound and prudent
purpose of regulation on management of the
solvency business.
The chosen basis should
be used consistently
throughout the
insurer/insurance group’s
own assessment of
overall solvency needs.
The insurer/insurance
group should provide an
assessment of the
material differences
between its chosen basis

Insurers’ capital Insurers’ capital


assessments will reflect The insurer can choose assessments will reflect
their own choice of data its own basis for risk their own choice of data
Regulatory capital (risk-
sets, distributions, Solvency II basis can be measurement, but it sets, distributions,
based approach per Regulatory (1year) and
Regulatory (1 Year, 99 measures, confidence used, or any basis that Japanese Statutory (and Regulatory (1 Year, 99.5 must be able to show an measures, confidence
Capital assessment basis (time Australian regulations) own assessment Insurer's choice, but must
18 TVaR) and Own Risk levels, time horizons, the AMSB considers more Economic VaR) and Own Risk assessment of the levels, time horizons,
horizon, risk metric) plus the internal target according to business disclose
Assessment valuation approaches, appropriate than the (recommended)) Assessment material differences valuation approaches,
capital above regulatory plan
financial tools and Solvency II basis between its own required financial tools and
capital (unspecified)
methodologies, capital to the regulatory methodologies,
appropriate to their own required capital appropriate to their own
unique profile unique profile
ORSA Regulatory Requirements Description Australia Bermuda Canada China EEA Japan Mexico Singapore South Africa Switzerland United States

The insurer (group)


An insurer shall support should have in place at
the measurement of its least the following
risk with documentation documentation on the
that provides detailed ORSA:
ORSA Policy; a proper
descriptions and a) ORSA policy;
record of each ORSA; and Must document the
Yes - ICAAP Summary No - CIRC assesses the explanations of the risks b) Record of each ORSA;
Required documentation of ORSA Yes - ORSA processes and internal report and a ORSA process and results
19 Statement and annual Yes insurer and issues Yes Yes covered, the c) Internal management Yes
process results possibly different report internally (for possible
ICAAP report SARMRA report annually measurement information on risk and
to the supervisor of each supervisory review)
approaches used and the capital management
ORSA
key assumptions made. (Internal report on
Such documentation ORSA); and
should be signed or d) ORSA supervisory
verified by report.

Solvency Regulatory Position Paper 34 (v 7) -


Guidelines No. 11: http://www.mas.gov.sg/ Own Risk and Solvency
Comprehensive NAIC ORSA Guidance
ORSA guidance or other regulatory LPS 110 Solvency Aligned Risk ~/media/resource/legisla Assessment Currently in
CISSA 2011 Instructions EIOPA_Guidelines_on_O Guidelines for Only the CUSF already Manual - July, 2014. Also
20 Relevant guidance guidance within which the ORSA GPS 110 OSFI Guideline E-19 Management tion_guidelines/insuranc Position Paper 107 (v 6) – development. To be
Handbook RSA_EN.pdf Supervision of Insurance mentioned the applicable state
requirement is specified. CPG110 Requirements and e/notices/MAS%20126_A Own Risk and Solvency released by Q3 2015
Companies (II-3-5) law(s).
Assessment pr%202013.pdf Assessment - Further
Guidance

LPS 110:
http://www.apra.gov.au/
lifs/PrudentialFramework
/Documents/LPS-110-
Capital-Adequacy-January-
2013.pdf
http://www.naic.org
GPS 110:
http://www.bma.bm/doc http://www.osfi- https://eiopa.europa http://www.mas.gov.sg/ http://www.fsb.co.za/De /documents/commit
http://www.apra.gov.au/ http://www.fsa.go.jp http://www.cnsf.gob.mx/ ~/media/resource/legisla partments/insurance/Pag
ument-centre/reporting- bsif.gc.ca/Eng/Docs/e19. http://www.circ.gov.cn/ Currently in
Regulatory website with guidance Link guidance most relevant for GI/PrudentialFramework/ .eu/GuidelinesSII/EI tees_e_isftf_group_s
21 forms-and- pdf, http://www.osfi- web/site0/tab5225/info3 /common/law/guide CUSFELECTRONICA/CUSF tion_guidelines/insuranc es/assesManage1.aspx development. To be
links users. Documents/GPS-110- OPA_Guidelines_on_ olvency_related_ors
guidelines/Insurance/For bsif.gc.ca/Eng/Docs/13- 951923.htm /ins/02c.html /CUSF3_2 e/notices/MAS%20126_A released by Q3 2015
Capital-Adequacy-January-
ms/DispForm.aspx?ID=17 1663_ORSA_ins.pdf ORSA_EN.pdf pr%202013.pdf a_feedback_pilot_pr
2013.pdf
CPG110:
oject.pdf
http://www.apra.gov.au/
CrossIndustry/Pages/CPG-
110-Internal-Capital-
Adequacy-
Assessment.aspx

All groups must also


submit a Form F -
Enterprise Risk Report,
which may be partially
satisfied by referencing
Form F material already
supplied via an ORSA
report (for those subject
The Solvency II directive to an ORSA requirement).
is transposed into the http://www.naic.org/doc
For example, whether application of
legislation of each uments/committees_e_is
22 Other relevant information. guidance varies by country within
Member State, thus local ftf_group_solvency_relat
region, other key information.
implementations may ed_form_f_orsa_comp.p
vary df (Latest status of
ORSA adoption and Form
F are found on pages 7
and 4 respectively of the
following link
http://www.naic.org/doc
uments/committees_e_r
elated_smi_dashboard.p
df

Last updated by
23 6th of November, 2016 8th of November, 2016 8th of November, 2016 22nd of April, 2015 10th of November, 2016 13th of November, 2016 11th of November, 2016 6th of May, 2015 27th of May, 2015 6th of May, 2015 10th of November, 2016
respondent/reviewer

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