By Fitch Ratings | July 27, 2021
EU insurers’ IFRS 17 financial statements will not be as helpful for users as they could be, as they will lack certain profitability information unless they routinely show accounting data for cohorts of contracts grouped by origination year, Fitch Ratings says.
The European Commission’s (EC) Accounting Regulatory Committee recently proposed to exempt products that are intergenerationally mutualised or cash-flow-matched from annual cohort reporting requirements under IFRS 17, the international standard for insurance accounting. We believe reporting by annual cohorts gives insightful information on historical pricing and subsequent profit emergence, helping users of financial statements to analyse and project profitability.
Insurers using the exemption will have to disclose it as a significant accounting policy and highlight the portfolios to which they have applied it in the notes to their financial statements. However, they will not be required to assess the quantitative impact of applying the exemption.
Under the IFRS 17 annual cohort reporting requirement, insurance contracts must be grouped into portfolios according to their risk profile and start date, with start dates no more than one year apart. They must be further grouped according to their expected profitability. In particular, contracts that are expected at the outset to be loss-making (known as ‘onerous’ contracts) must be grouped separately.
This segregation into cohorts can give helpful visibility on under-pricing, showing when it took place, the extent to which it affects profitability, and whether the insurer improved its pricing for subsequent cohorts. This information will not be disclosed for insurers using the exemption from annual cohort reporting. Consequently, their financial statements will be less transparent, and metrics that they calculate at a portfolio level will not be directly comparable with similar metrics calculated at a cohort level by companies not using the exemption.
Several EU members’ insurance trade associations opposed the annual cohort requirement for intergenerationally mutualised and cash-flow-matched contracts, which represent more than 70% of the life insurance liabilities in the EU. They took the view that, for these products, reporting by annual cohorts would produce information representing neither the contracts’ economic characteristics nor the insurers’ underlying business models. The European Financial Reporting Advisory Group debated this view but did not reach consensus for its IFRS 17 endorsement advice to the EC, submitted in March 2021.
The exemptions from annual cohort reporting requirements could complicate insurers’ preparations for IFRS 17. EU insurers have conducted their IFRS 17 implementation projects so far on the basis of applying the requirements across all of their insurance contracts. Many companies are now likely to reconsider their plans. Those that also operate outside the EU will have to deal with different contract aggregation rules, which could drive up implementation costs and affect timelines.
The EC’s proposal is now subject to scrutiny by the European Parliament and the Council of the EU, with IFRS 17 likely to be formally endorsed by end-2021 and due to take effect for reporting periods on or after 1 January 2023. Annual cohort reporting could remain an area of focus for several years. The International Accounting Standards Board will carry out a post-implementation review of IFRS 17, after which the EC intends to review the exemptions from the annual cohort reporting requirement by end-December 2027.