Solvency II Reporting Requirements: What Insurers File, and When

"Solvency II reporting" is not one deliverable. It is a set of obligations that share the same closing figures but run on different clocks, reach different audiences, and are governed by different texts. A quarterly submission of quantitative templates has almost nothing in common — in production terms — with an annual public report that any policyholder can read.

Teams that treat the whole thing as a single deadline discover the difference late, usually during final review, when a capital figure quoted in a narrative report turns out not to match the template that carries it.

This article sets out what the regime actually requires: the quantitative templates, the two narrative reports, who receives each, at what frequency, and what the 2027 review changes.

Three obligations under one label

Pillar 3 of Solvency II covers disclosure and market discipline. It produces three distinct submissions:

• Quantitative Reporting Templates (QRTs) — standardised, machine-readable data tables filed with the supervisor, a subset of which is published.

• The SFCR (Solvency and Financial Condition Report) — an annual, public report. It is published by the undertaking and readable by anyone with an interest, policyholders included.

• The RSR (Regular Supervisory Report) — a report for the supervisor only (the ACPR in France, the relevant national competent authority elsewhere). It is more detailed than the public report, and is filed on a one-to-three-year cycle depending on the undertaking, with updates whenever a significant change occurs.

The narrative reports cover the same broad domains, inherited from the directive: business and performance, system of governance, risk profile, valuation for solvency purposes, and capital management. The RSR goes further on what an undertaking has no reason to disclose publicly — assumption detail, projections, elements of internal policy.

The quantitative side: QRTs

A QRT is a standardised table that renders one dimension of an undertaking's prudential position: economic balance sheet, technical provisions, own funds, capital requirements, investment detail, claims experience.

The nomenclature follows a thematic logic, `S.xx.yy`. The full set runs to several dozen templates; a few are emblematic and stable enough to name:

• S.02.01 — prudential balance sheet: assets and liabilities at Solvency II values.

• S.05.01 — premiums, claims and expenses by line of business.

• S.06.02 — investment list, line by line (ISIN, valuation, classification).

Content and templates are set by implementing technical standards. Implementing Regulation (EU) 2023/894 defines the templates for the submission of supervisory information, applicable from the 31/12/2023 submissions onward. The applicable ITS vintage and XBRL taxonomy should always be checked against the financial year concerned — they move.

The templates serve two distinct uses. Filed in full, they are confidential supervisory reporting and accompany the RSR. A subset is annexed to the SFCR and becomes public.

Frequency and deadlines

Not every template is filed on the same cadence, and this is what shapes the production burden.

Quarterly reporting covers a reduced set, oriented towards close monitoring — balance sheet, investments, own funds, MCR. Annual reporting covers the full set.

• Quarterly templates — around 5 weeks after quarter end for solo undertakings, around 11 weeks at group level.

• Annual templates and SFCR — around 14 weeks after year end for solo undertakings, longer at group level.

These are the usual orders of magnitude, not a citation. Deadlines have moved across vintages and continue to move with the review — they must be verified against the standards applicable to the financial year being reported.

Solo and group are two parallel sets

A group does not file a larger version of the solo return. It files its own set, built on consolidation: scope of entities, contributions to the group SCR, intra-group transactions, risk concentrations — each with its own deadline, generally later than the solo one.

In practice an insurance group runs two reporting chains in parallel, and the group chain cannot start until the solo figures it consumes are stable. The extra weeks granted at group level are not slack; they are the consolidation itself.

What the 2027 review changes

Directive (EU) 2025/2, which revises Solvency II, must be transposed by member states by 29 January 2027, for application from 30 January 2027.

For Pillar 3, the structural change is to the public report: the SFCR is split into two parts. One is addressed to policyholders and beneficiaries and is to be written so that it can be understood without prudential expertise. The other is addressed to market professionals and retains the current level of technical detail.

The practical consequence for the teams producing it is twofold. Existing technical content has to be distributed across two documents whose readers have different expectations — and the split is editorial, not mechanical. A section cannot simply be copied into the policyholder-facing part; it has to be rewritten for a reader who does not know what a risk margin is.

Where the requirement actually bites

The list of obligations is public and stable. What makes Solvency II reporting difficult is not knowing what to file — it is keeping several deliverables that describe the same closing consistent with each other.

Narrative and quantitative drift apart when they live in separate chains. An own-funds figure quoted in the public report must be the figure carried by the corresponding template. A methodology change mentioned in the supervisory report must be visible in the technical provisions filed. When one chain lives in a reporting tool and the other in a word processor, the gap surfaces at final review — the worst possible moment, because both are already deadline-bound.

Narrative text ages silently. A description of method or governance carried over from one financial year to the next without review becomes wrong the moment practice changes, and nothing signals it. Quantitative templates fail loudly when they are wrong; narrative reports do not.

Cadences collide. The annual campaign and the first quarterly submission of the new year overlap for most undertakings. A chain that is only sized for the annual peak spends the first quarter recovering from it.

The approach that holds is to treat the narrative report as an output of the data chain rather than a document written alongside it: figures quoted in the text sourced from the same place as the templates, and the reconciliation between the two run as a control rather than as a proofread.

That is a question of chain design, which we cover separately in automating Solvency II reporting and, on the calculation side, in SCR calculation software. For the framework as a whole, see our complete guide to Solvency II; for what changes in 2027, see the Solvency II review.

Frequently asked questions

Is the SFCR public? Yes. The SFCR is an annual public report, published by the undertaking and accessible to anyone, policyholders included. The RSR is not — it goes to the supervisor alone.

How often is the RSR filed? On a one-to-three-year cycle depending on the undertaking, with updates required whenever a significant change occurs. It is the one Pillar 3 deliverable that is not strictly annual for everyone.

Which templates are published? A subset of the QRTs is annexed to the SFCR and becomes public. The full set is confidential supervisory reporting.

Do groups get more time? Yes, group deadlines fall later than solo ones — but the additional weeks are consumed by consolidation, which cannot begin before the underlying solo figures are stable.

What should we check before relying on a deadline? The ITS vintage and XBRL taxonomy applicable to the financial year being reported. Template codes, deadlines and taxonomy versions change from one vintage to the next, and the 2027 review moves several of them.

Finengy Advisory supports insurers and banks on regulatory production and its industrialisation. Talk to us about your reporting chain.

This content is informative and does not constitute regulatory advice. Template codes, deadlines and taxonomy versions cited are the usual orders of magnitude and must be re-checked against the standards applicable to the financial year concerned.