# Solvency and Financial Condition Report: [Undertaking name], [Year]

> Public annual Solvency and Financial Condition Report (SFCR) for an
> insurance or reinsurance undertaking under Solvency II: a short part
> for policyholders and beneficiaries, and a detailed part for market
> professionals covering business and performance, system of
> governance, risk profile, valuation for solvency purposes, capital
> management and sustainability, with the public quantitative
> templates. Based on Directive 2009/138/EC (Solvency II) Articles 51 to
> 56 as amended by Directive (EU) 2025/2 (applies from 2027-01-30) and
> Commission Delegated Regulation (EU) 2015/35 Articles 290 to 303 and
> Annex XX as amended for the same date. UK Solvency UK and other
> regimes are noted as comparisons. Replace every `[bracketed]` value
> and every row marked *Example*. This is a documentation format, not
> legal, actuarial or financial advice; check the current official
> text, your supervisor's instructions and a qualified professional.

<!--
Guidance: How to use this template
- Purpose: produce the public SFCR in the prescribed order, with each
  section traceable to the article that requires it, and with numbers
  that agree with the quantitative reporting templates (QRTs) and the
  audited balance sheet.
- Which rules apply: reports on financial years under the pre-2027
  framework follow the original Articles 51 to 56 and Delegated
  Regulation Articles 290 to 298 (one report, five sections A to E).
  Reports under the amended framework follow the two-part structure in
  this template. Check with your supervisor which reporting year is the
  first under the new structure, together with the implementing
  technical standards on templates.
- Keep Part 1 (policyholders) to five pages or fewer, plain language,
  and with the prescribed description of the SCR and MCR. Part 2
  carries the detail.
- The worked example uses the fictional Quillmere Assurance SE, a
  non-life insurer in an EU Member State, figures in EUR million at
  31 December 2027. Every number is recomputed in the report.
- Related templates: ORSA Report (`finance/orsa-report`), Risk Appetite
  Statement (`finance/risk-appetite-statement`), Stress Testing
  Programme (`finance/stress-testing-programme`), IFRS 17 Insurance
  Contracts Memo (`finance/ifrs-17-insurance-contracts-memo`), Audit
  Committee Report (`finance/audit-committee-report`) and Insurance
  ACORD Solution Design (`industry/insurance-acord-solution-design`).
-->

## Document control

<!-- Guidance: Record the reporting date, the regime and the disclosure date. Supervisors check that the disclosed version is the approved one. -->

| Field | Value |
|---|---|
| Document ID | [SFCR-YYYY-ENTITY] *Example:* SFCR-2027-QAS |
| Undertaking | [Legal name, legal form, LEI] *Example:* Quillmere Assurance SE, LEI [20-character LEI] |
| Solo or group report | [Solo / Group / Single group-wide SFCR] *Example:* Solo |
| Reporting date | [YYYY-12-31] |
| Regime | [Solvency II as amended by Directive (EU) 2025/2 / pre-2027 Solvency II / Solvency UK] |
| Supervisory authority | [Name] |
| External auditor and audit scope | [Firm, scope under Article 51a] |
| Disclosure date | YYYY-MM-DD |
| Version | [0.1] |
| Status | [Draft / In review / Approved by AMSB / Disclosed] |
| Owner | [@chief-financial-officer] |
| Approvers/reviewers | [@board-chair], [@chief-risk-officer], [@actuarial-function-holder], [@audit-committee-chair] |
| Last updated | YYYY-MM-DD |
| Classification | [Public on disclosure; Internal before] |

### Approvals

| Role | Name | Decision | Date |
|---|---|---|---|
| Chief financial officer | [@name] | [Prepared] | YYYY-MM-DD |
| Actuarial function holder | [@name] | [Reviewed technical provisions sections] | YYYY-MM-DD |
| Audit committee | [@name] | [Recommend approval] | YYYY-MM-DD |
| Administrative, management or supervisory body (AMSB) | [@name] | [Approve for disclosure] | YYYY-MM-DD |

### Revision history

| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | First draft from year-end QRTs |
| 0.8 | YYYY-MM-DD | [@name] | *Example:* Auditor comments on balance sheet cleared |
| 1.0 | YYYY-MM-DD | [@name] | *Example:* Approved by the AMSB and disclosed |

## Contents

<!-- Guidance: Keep this list aligned with the headings. The order follows Annex XX, Section A, as amended; check the annex before finalising. -->

1. [Regime, scope and timeline](#1-regime-scope-and-timeline)
2. [Part 1: Information for policyholders and beneficiaries](#2-part-1-information-for-policyholders-and-beneficiaries)
3. [Part 2, A: Business and performance](#3-part-2-a-business-and-performance)
4. [Part 2, B: System of governance](#4-part-2-b-system-of-governance)
5. [Part 2, C: Risk profile](#5-part-2-c-risk-profile)
6. [Part 2, D: Valuation for solvency purposes](#6-part-2-d-valuation-for-solvency-purposes)
7. [Part 2, E: Capital management](#7-part-2-e-capital-management)
8. [Part 2, F: Sustainability-related information](#8-part-2-f-sustainability-related-information)
9. [Public quantitative templates](#9-public-quantitative-templates)
10. [Non-disclosure, updates and means of disclosure](#10-non-disclosure-updates-and-means-of-disclosure)
11. [Production process and controls](#11-production-process-and-controls)
12. [Glossary and references](#12-glossary-and-references)
13. [Standard and licence note](#standard-and-licence-note)

## 1. Regime, scope and timeline

<!-- Guidance: Internal working section, removed before disclosure. State which version of the rules applies and the deadlines. Common pitfall: applying the new two-part structure to a reporting year still under the old rules, or the reverse. -->

Confirm the legal basis for this reporting year. Directive (EU) 2025/2
amends Solvency II: Article 51 is replaced (the SFCR becomes two parts,
one for policyholders and beneficiaries and one for market
professionals), Article 51a is inserted (audit of the solvency balance
sheet for undertakings other than small and non-complex undertakings
and captives, with national options to extend it), and Article 256c
applies the audit to groups. Member States transpose by 2027-01-29 and
apply the rules from 2027-01-30. The Commission's amending Delegated
Regulation, C(2025) 7206, replaces Articles 290 to 294, 296 and 297 of
Delegated Regulation (EU) 2015/35, inserts Articles 297a and 298a,
replaces Annex XX and applies from the same date.

The annual deadline is set by Article 51(7) of the Directive as
amended. Under the pre-2027 rules the solo SFCR was due 14 weeks after
year end and the group SFCR 6 weeks later. Confirm the amended
deadlines in the consolidated text and any supervisory transitional
statement before you build the timeline.

| Item | Value |
|---|---|
| Rules applied for this report | [Amended framework / pre-2027] |
| Small and non-complex undertaking (SNCU) status | [Yes / No, basis] *Example:* No, gross written premium above the quantitative threshold |
| Captive or reinsurer election to omit Part 1 | [Yes / No] *Example:* No |
| Balance sheet audit required (Article 51a) | [Yes / No, national extension] *Example:* Yes, balance sheet only |
| Disclosure deadline | [Date, legal basis] |
| Supervisor submission (Article 304(1)(a) of the Delegated Regulation) | [Date] |

## 2. Part 1: Information for policyholders and beneficiaries

<!-- Guidance: This part must not exceed five pages and must be clear to a non-specialist. Article 292 of the amended Delegated Regulation lists the content and prescribes a fixed description of the SCR and MCR: insert that text exactly as published in the Official Journal. Common pitfall: pasting market-professional detail here and breaching the page limit. -->

Open with the statement on language versions required by Article 292(1)
and links to versions in other languages (Article 298a: on request,
the undertaking sends a translation within 10 working days unless one
is online). Then cover the items below in plain language, with no
abbreviations left unexplained.

### 2.1 Who we are and how we performed

| Item (Article 292(2)) | Content |
|---|---|
| Name and legal form | *Example:* Quillmere Assurance SE, a European company |
| Supervisory authority and contact | [Name, address, website] |
| Holders of qualifying holdings | *Example:* Quillmere Holdings Ltd (100%) |
| Group | *Example:* Quillmere Group, [jurisdiction], group supervisor [name] |
| Significant events in the year | *Example:* Exit from marine cargo business on 2027-06-30 |
| Underwriting and investment performance, aggregate | *Example:* Underwriting result EUR 41.2m, investment return EUR 18.6m |

### 2.2 Our capital and our risks

Insert the prescribed SCR and MCR description from Article 292(3) of the
amended Delegated Regulation here, without changes.

| Item (Article 292(3)) | 31 Dec 2027 | 31 Dec 2026 |
|---|---|---|
| Solvency Capital Requirement (SCR) *(Example)* | EUR 182.4m | EUR 175.0m |
| Eligible own funds to cover the SCR *(Example)* | EUR 312.7m | EUR 290.5m |
| SCR coverage ratio *(Example)* | 171.4% | 166.0% |
| Minimum Capital Requirement (MCR) *(Example)* | EUR 45.6m | [Amount] |
| Eligible basic own funds to cover the MCR *(Example)* | EUR 277.4m | [Amount] |
| MCR coverage ratio *(Example)* | 608.3% | [Ratio] |
| Any breach of SCR or MCR in the year | *Example:* None | [None] |

Describe the main risks in a few sentences each, including
sustainability risks, any material change in the year and how the
undertaking reduces them (reinsurance, diversification, limits).

*Example:* Our largest risk is that claims from storms and floods are
higher than expected. We buy reinsurance so that a 1-in-200-year storm
costs us no more than EUR 35m after recoveries. Our second risk is a
fall in the value of the bonds we hold. Climate change is increasing
weather losses over time; we review prices every year and test our
capital against severe climate scenarios.

### 2.3 Other material information for policyholders

State whether the undertaking publishes transition plans under Article
19a or 29a of Directive 2013/34/EU and give the link (Article 292(4)).

## 3. Part 2, A: Business and performance

<!-- Guidance: Article 293. Numbers come from the financial statements and must agree with the public templates. Common pitfall: commenting on IFRS profit without explaining the line-of-business split the templates show. -->

### 3.1 Business

Give the legal entity identifier, supervisor and group supervisor,
external auditor and audit scope, qualifying holders by name, the
position in the group with an organisation chart, material lines of
business and geographies, and significant events (Article 293(1)).

```mermaid
flowchart TD
  H["Quillmere Holdings Ltd"] -->|"100%"| Q["Quillmere Assurance SE<br/>(reporting undertaking)"]
  H -->|"100%"| R["Quillmere Re DAC<br/>(captive reinsurer)"]
  Q -->|"100%"| S["Quillmere Claims Services GmbH<br/>(service company)"]
```

### 3.2 Underwriting performance

| Line of business | 2027 underwriting result (EUR m) | 2026 (EUR m) |
|---|---|---|
| Fire and other damage to property *(Example)* | 24.8 | 19.6 |
| Motor vehicle liability *(Example)* | 9.1 | 11.4 |
| General liability *(Example)* | 7.3 | 6.0 |
| Total *(Example)* | 41.2 | 37.0 |

### 3.3 Investment performance

Show income and expenses by asset class, gains and losses recognised
in equity, and investments in securitisations (Article 293(3)).

| Asset class | Income (EUR m) | Realised and unrealised gains (EUR m) | In equity (EUR m) |
|---|---|---|---|
| Government bonds *(Example)* | 9.4 | (1.2) | 2.1 |
| Corporate bonds *(Example)* | 7.8 | 0.6 | 1.4 |
| Collective investment undertakings *(Example)* | 2.0 | 1.5 | 0.0 |
| Investment expenses *(Example)* | (1.5) | 0.0 | 0.0 |
| Total *(Example)* | 17.7 | 0.9 | 3.5 |

Total investment return in the income statement: *Example:* 17.7 plus
0.9 equals EUR 18.6m, as stated in Part 1.

### 3.4 Other income, expenses and other information

Describe other material income and expenses (Article 293(4)) and any
other material information (Article 293(5)).

## 4. Part 2, B: System of governance

<!-- Guidance: Article 294. Describe the structure, remuneration, material transactions with related parties and outsourcing. Common pitfall: listing outsourced functions without naming the providers and their jurisdictions, which Article 294(2) requires. -->

Describe the AMSB, its committees, segregation of responsibilities and
the key functions (risk management, compliance, internal audit,
actuarial), or the material changes since the previous SFCR. Explain
the remuneration policy, including fixed and variable components,
deferral, performance criteria and how the policy integrates
sustainability risks. Report material transactions with shareholders,
persons with significant influence and AMSB members.

| Key function | Holder | Reports to |
|---|---|---|
| Risk management *(Example)* | [@cro] | Board risk committee |
| Compliance *(Example)* | [@head-of-compliance] | Audit committee |
| Internal audit *(Example)* | [@head-of-internal-audit] | Audit committee chair |
| Actuarial *(Example)* | [@actuarial-function-holder] | AMSB |

| Outsourced critical or important function | Provider | Jurisdiction |
|---|---|---|
| Investment management *(Example)* | Fictional asset manager "Ostrel Capital Partners" | [Country] |
| Claims handling, motor *(Example)* | Quillmere Claims Services GmbH (intra-group) | Germany |
| Cloud hosting of policy administration *(Example)* | [Provider] | [Country] |

## 5. Part 2, C: Risk profile

<!-- Guidance: Article 297 of the amended Delegated Regulation sets the content for capital management and risk profile. Describe each material risk category, its measurement, concentrations, mitigation and sensitivity. Keep the risk numbers consistent with section 7. Common pitfall: listing risks without the sensitivities and stress results that show their size. -->

For each category (underwriting, market, credit, liquidity,
operational, other material risks including sustainability), describe
exposure, measurement, concentration, mitigation and the sensitivity or
stress tests performed. Cross-refer to the ORSA (`finance/orsa-report`)
for the forward-looking assessment without disclosing ORSA content the
supervisor has not asked to be public.

| Risk | Exposure measure | Mitigation | Sensitivity *(Example)* |
|---|---|---|---|
| Non-life catastrophe *(Example)* | Property sums insured in coastal zones | Catastrophe excess of loss reinsurance, retention EUR 35m | 1-in-200 windstorm: SCR ratio 171.4% to 152.0% |
| Interest rate *(Example)* | Bond portfolio duration 4.2 years vs liabilities 3.8 | Duration matching limits | Rates down 100 bp: ratio to 165.0% |
| Spread *(Example)* | Corporate bonds EUR 410m | Rating and issuer limits | Spreads up 100 bp: ratio to 160.5% |
| Liquidity *(Example)* | Cash need in a catastrophe | Liquidity buffer EUR 60m | Covered under all scenarios |

## 6. Part 2, D: Valuation for solvency purposes

<!-- Guidance: Article 296 as amended. For assets, technical provisions and other liabilities, state the Solvency II value, the basis and the difference to the financial statements. Common pitfall: an unexplained gap between IFRS equity and the excess of assets over liabilities. -->

### 6.1 Balance sheet summary

| Line | Solvency II value (EUR m) |
|---|---|
| Total assets *(Example)* | 1,395.6 |
| Technical provisions: best estimate *(Example)* | 858.9 |
| Technical provisions: risk margin *(Example)* | 43.4 |
| Technical provisions, total *(Example)* | 902.3 |
| Other liabilities, including subordinated debt EUR 30.0m *(Example)* | 175.6 |
| Excess of assets over liabilities *(Example)* | 317.7 |

### 6.2 Technical provisions

Describe for each material line of business the best estimate, the
risk margin, the methods and assumptions, the level of uncertainty, the
use of the matching adjustment, volatility adjustment or transitional
measures and the quantified effect of not applying them, and the main
differences from the financial statements.

### 6.3 Reconciliation to the financial statements

| Line | EUR m |
|---|---|
| Equity under IFRS *(Example)* | 286.9 |
| Revaluation of technical provisions net of reinsurance, IFRS 17 to Solvency II *(Example)* | 52.6 |
| Elimination of intangible assets *(Example)* | (14.3) |
| Deferred tax on valuation differences *(Example)* | (7.5) |
| Excess of assets over liabilities *(Example)* | 317.7 |

## 7. Part 2, E: Capital management

<!-- Guidance: Article 297 as amended. Give objectives, own funds by tier, the SCR by risk module, the MCR and any non-compliance. Common pitfall: an own funds total that does not reconcile to the excess of assets over liabilities. -->

### 7.1 Own funds

Explain the objectives and time horizon for managing own funds and the
material changes by tier over the year.

| Line | EUR m |
|---|---|
| Excess of assets over liabilities *(Example)* | 317.7 |
| Less foreseeable dividends *(Example)* | (35.0) |
| Add subordinated liabilities *(Example)* | 30.0 |
| Basic own funds *(Example)* | 312.7 |

| Tier | Eligible for SCR (EUR m) | Eligible for MCR (EUR m) |
|---|---|---|
| Tier 1 unrestricted *(Example)* | 268.3 | 268.3 |
| Tier 2, subordinated debt *(Example)* | 30.0 | 9.1 |
| Tier 3, net deferred tax assets *(Example)* | 14.4 | Not eligible |
| Total *(Example)* | 312.7 | 277.4 |

*Example:* For the MCR, Tier 2 is limited to 20% of the MCR
(0.20 x 45.6 = 9.1) and Tier 3 is not eligible, under the tiering
limits in Article 82 of Delegated Regulation (EU) 2015/35; check the
amended text.

### 7.2 Solvency Capital Requirement

| Module (standard formula) | EUR m |
|---|---|
| Market risk *(Example)* | 98.6 |
| Counterparty default risk *(Example)* | 14.2 |
| Non-life underwriting risk *(Example)* | 121.3 |
| Health underwriting risk *(Example)* | 8.9 |
| Sum of modules *(Example)* | 243.0 |
| Diversification *(Example)* | (62.5) |
| Basic SCR *(Example)* | 180.5 |
| Operational risk *(Example)* | 11.8 |
| Loss-absorbing capacity of deferred taxes *(Example)* | (9.9) |
| SCR *(Example)* | 182.4 |

State whether undertaking-specific parameters, simplifications or an
internal model are used. The MCR of EUR 45.6m equals 25% of the SCR,
the floor of the corridor in Article 129(3) of the Directive.

### 7.3 Non-compliance

If the MCR or SCR was breached during the period or at disclosure,
state the period, cause, consequences, remedial measures and their
effect. *Example:* No breach occurred.

## 8. Part 2, F: Sustainability-related information

<!-- Guidance: Article 297a of the amended Delegated Regulation. Common pitfall: describing climate ambitions without the quantifiable targets in the plans required by Article 44 of the Directive. -->

Disclose the elements of the sustainability risk plans required by
Article 44 of the Directive as amended, including quantifiable targets;
whether the undertaking publishes transition plans under Directive
2013/34/EU and where; whether it has material exposure to climate
change-related risks after the materiality assessment in Article 45a(1)
and what actions it has taken. If the SFCR is used to meet disclosure
duties under Regulation (EU) 2019/2088 or Regulation (EU) 2020/852,
include that information here.

| Item | Content |
|---|---|
| Sustainability risk plan targets *(Example)* | Reduce weighted average carbon intensity of the corporate bond portfolio by 30% by 2030 against 2025 |
| Transition plan link *(Example)* | [URL] |
| Material climate exposure *(Example)* | Yes, physical risk on property lines; scenario results in section 5 |

## 9. Public quantitative templates

<!-- Guidance: Attach the public templates required by the implementing technical standards in force for the year. Common pitfall: a balance sheet template that differs from section 6.1 after late adjustments. -->

Attach the public templates for the reporting year as an annex, in
the form required by the implementing technical standards applicable to
that year (Commission Implementing Regulation (EU) 2023/895 under the
pre-2027 rules, or its successor). Reconcile each template to the
narrative.

| Template | Content | Agrees to |
|---|---|---|
| Balance sheet | Solvency II balance sheet | Section 6.1 |
| Premiums, claims and expenses by line of business | Underwriting data | Section 3.2 |
| Technical provisions | Best estimate and risk margin | Section 6.2 |
| Own funds | Tiers and eligibility | Section 7.1 |
| SCR | Modules | Section 7.2 |
| MCR | Linear formula and corridor | Section 7.2 |

## 10. Non-disclosure, updates and means of disclosure

<!-- Guidance: Articles 53 and 54 of the Directive and Articles 299 to 302 of the Delegated Regulation. Common pitfall: omitting information without supervisory permission. -->

Information may be withheld only where the Directive allows (Article
53) and with supervisory permission; record it here internally and give
it in the regular supervisory report instead. Publish an updated SFCR
after a major development (Article 54, Article 302 of the Delegated
Regulation), labelled as updated and dated. Keep both parts on the
website for at least five years (Article 301); if there is no website,
send an electronic copy within 10 working days of a request.

| Item | Value |
|---|---|
| Information withheld with permission | *Example:* None |
| Website location notified to the supervisor | [URL] |
| Updates issued in the year | *Example:* None |

## 11. Production process and controls

<!-- Guidance: Internal working section, removed before disclosure. Show the timeline from year end to disclosure and the controls. -->

```mermaid
flowchart LR
  A["Year-end close<br/>and IFRS accounts"] --> B["Solvency II balance sheet<br/>and technical provisions"]
  B --> C["SCR, MCR and own funds"]
  C --> D["QRTs and narrative drafted"]
  D --> E["External audit of<br/>balance sheet (Art. 51a)"]
  E --> F["Audit committee review"]
  F --> G["AMSB approval"]
  G --> H["Disclosure on website<br/>and submission to supervisor"]
```

| Control ID | Control | Owner |
|---|---|---|
| CTL-SFCR-001 *(Example)* | Agree every narrative number to QRTs with a tick-mark file | [@solvency-reporting-lead] |
| CTL-SFCR-002 *(Example)* | Page count and readability check of Part 1 | [@communications-lead] |
| CTL-SFCR-003 *(Example)* | Actuarial function review of technical provisions sections | [@actuarial-function-holder] |
| CTL-SFCR-004 *(Example)* | Confirm prescribed SCR and MCR description matches the Official Journal text | [@legal-counsel] |

UK comparison: UK insurers report under Solvency UK; the PRA moved the
retained reporting and disclosure rules into the Reporting Part of the
PRA Rulebook (policy statement PS3/24, February 2024). The UK SFCR does
not follow the EU two-part structure; check the current Rulebook. US
comparison: there is no SFCR; insurers file public statutory annual
statements under NAIC rules and a confidential ORSA summary report.

## 12. Glossary and references

<!-- Guidance: Define terms for Part 2 readers and list the legal sources with dates. -->

### 12.1 Glossary

| Term | Meaning |
|---|---|
| AMSB | Administrative, management or supervisory body |
| SCR | Solvency Capital Requirement, calibrated to a one-year 99.5% value at risk |
| MCR | Minimum Capital Requirement, the lower intervention level |
| Own funds | Capital resources classified into three tiers by quality |
| Technical provisions | Best estimate of insurance obligations plus the risk margin |
| QRT | Quantitative reporting template |
| SNCU | Small and non-complex undertaking |

### 12.2 References

| Reference | Version or date | Use |
|---|---|---|
| Directive 2009/138/EC (Solvency II), Articles 35, 44, 45a, 51 to 56, 256 to 256c | As amended; consolidated text on EUR-Lex | SFCR obligation |
| Directive (EU) 2025/2 amending Directive 2009/138/EC | OJ 2025-01-08; transposition 2027-01-29, application 2027-01-30. https://eur-lex.europa.eu/eli/dir/2025/2/oj/eng | Two-part SFCR, audit |
| Commission Delegated Regulation (EU) 2015/35, Articles 290 to 303, Annex XX | As amended by the Delegated Regulation adopted as C(2025) 7206, applying from 2027-01-30 | Content and structure |
| Commission Implementing Regulation (EU) 2023/895 | Templates for the pre-2027 framework; check successor | Public templates |
| PRA Rulebook, Reporting Part; PS3/24 | February 2024 | UK comparison |
| ORSA Report (`finance/orsa-report`) | This collection | Forward-looking assessment |

## Standard and licence note

Based on Directive 2009/138/EC (Solvency II) as amended by Directive
(EU) 2025/2, and Commission Delegated Regulation (EU) 2015/35 as amended
by the Commission Delegated Regulation adopted on 29 October 2025 as
C(2025) 7206, which applies from 30 January 2027. EU legislation is
cited by article number and summarised in original words; the
prescribed SCR and MCR description must be taken from the Official
Journal. Check the current consolidated texts, implementing technical
standards, EIOPA guidance and your supervisor's instructions before
use. Quillmere Assurance SE, its group and every figure are fictional.
This template is original text and is not legal, actuarial or
financial advice; check the current official text and a qualified
professional. Template licence: MIT.