IIF Feedback on Insurance Capital Standards: Key Recommendations

On February 5, 2026, the Institute of International Finance (IIF) provided insightful feedback to the International Association of Insurance Supervisors (IAIS) concerning consultations on Insurance Capital Standards (ICS). These consultations focused on supervisory reporting, public disclosure, and evaluation methodology within the Common Framework (ComFrame). The IIF urged the IAIS to require that each Internationally Active Insurance Group report a singular solvency ratio, aligning with each jurisdiction's regulatory compliance requirements. They also recommended the formal recognition of existing frameworks, such as Solvency II and the Swiss Solvency Test, as valid local solutions.

The IIF proposed removing the requirement for parallel calculations via a standardized method and recommended that reporting and disclosure templates, like those in Annexes A and G, should serve only as examples rather than mandatory formats. This change would allow local regulatory supervisors to customize reporting structures to better meet their specific needs. In terms of public disclosure, the IIF stressed that requirements should focus on consumer-relevant data and align with existing supervisory report obligations to protect proprietary information. Furthermore, the IIF called for a formal public consultation by the IAIS on the ICS implementation assessment methodology, suggesting that jurisdictional frameworks be evaluated based on achieving comparable supervisory outcomes rather than strict adherence to technical ICS criteria.