Solvency and Financial Condition Report Template (Solvency II SFCR)
Two-part SFCR: policyholder summary, business, governance, risk profile, valuation, own funds, SCR and MCR, sustainability, public QRTs, controls
使用方法: Use it when an insurer prepares its annual public SFCR under Solvency II. Fill the regime and timeline section first to confirm whether the two-part structure from 2027 applies. The main pitfall is narrative numbers that do not agree with the public templates and the audited balance sheet.
预览
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.
Document control
| 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
- Regime, scope and timeline
- Part 1: Information for policyholders and beneficiaries
- Part 2, A: Business and performance
- Part 2, B: System of governance
- Part 2, C: Risk profile
- Part 2, D: Valuation for solvency purposes
- Part 2, E: Capital management
- Part 2, F: Sustainability-related information
- Public quantitative templates
- Non-disclosure, updates and means of disclosure
- Production process and controls
- Glossary and references
- Standard and licence note
1. Regime, scope and timeline
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
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
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)).
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
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
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
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
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
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
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
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
| 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
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.
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