Single ORSA

Approval of the production of a single ORSA supervisory report for a group and its subsidiaries

Overview of the measure

As part of their risk management system, insurance undertakings and groups must carry out at least annually an internal evaluation of their risks and solvency, within the framework of a process known as ORSA (Own Risk and Solvency Assessment). Using this framework, undertakings assess their overall solvency requirement in light of their specific risk profile, approved limits on risk tolerance and commercial strategy, check how far their risk profile diverges from the assumptions in the standard formula and ensure ongoing compliance with their solvency requirements in the short or longer term.

 

Complete documentation dedicated to the ORSA can be found on the ACPR website.

 

For groups, subject to prior authorisation by the ACPR (or, for undertakings that are members of foreign groups, by the European supervisory authority responsible for supervising the group), more than one own risk assessment can be carried out jointly, at group level and within certain group members, and a single document can be drawn up reporting on these various assessments.

 

If a group chooses this presentation option, it submits the single document simultaneously to all relevant supervisory authorities. Supervisory authorities can require groups to have the parts of the single document that correspond to undertakings under their supervision translated into their language.

 

In any event, for each individual undertakings, the supervisory authority in question must have at its disposal in the single document the same level of information as if the undertakings had drawn up an individual ORSA report, and that information must have been signed off by the board of directors or supervisory board of the undertakings in question.

Regulatory references

The provisions governing the authorisation to draw up a single ORSA report for a group and certain of its members are laid down in Articles L.356-19, R.356-46 and R.356-47 of the French “Code des assurances”, applicable to undertakings covered by each of the three codes, which transposes Article 246 of Directive 2009/138/EC, known as “Solvency II”.

 

These provisions are clarified in EIOPA’s guidelines on own risk and solvency assessment and in the ACPR notice on the same topic available (in French) on ACPR's website.

 

The ACPR Instruction n° 2015-I-28 on authorisation procedure for the assessment of the own risk and solvency assessment carried out jointly at group level and within certain group members specify the requirements for this application.

Content of the application

The list of all the documents to be included in the application is available in the instruction mentioned above. To summarize, the application must include the following:

 

  • a list of undertakings for which own risk assessments are conducted jointly, and the reasons for this choice
  • a description of how governance requirements are covered for each of these undertakings and, in particular, how their administrative, management and supervisory bodies are involved in the process of assessing and approving these conclusions
  • a description of how the single ORSA report is organized, to enable the relevant supervisory authorities to identify information relating to the individual assessments of undertakings supervised by them
  • if necessary, a specific indication on any required translations that have been commissioned, with particular attention to timescales and content
Procedure

For groups whose “group supervisor” is the ACPR, applications should be sent by post to the following address, as well as by e-mail to the supervisory team responsible for the group:

 

Secrétariat général de l’Autorité de contrôle prudentiel et de résolution
Brigade de contrôle des organismes d’assurance n°XX
61, rue Taitbout
75436 Paris Cedex 09

 

After consulting the members of the Supervisory College and taking into account their opinions and any reservations, the ACPR must reach an authorisation decision within a maximum of five months from receipt of the completed application.

Updated on: 07/07/2017 14:14