As early as 2014, the firm worked alongside the FNIM on the preparation and submission of an amendment to raise the Solvency II application thresholds so that small mutual insurers could be excluded from its scope. This technical work was followed by more than a decade of regular advocacy in support of these proposals.
The objective of raising the exclusion thresholds was ultimately reflected in the Solvency II revision adopted in 2024 and published in 2025. National transposition measures are to apply from 30 January 2027; exclusion remains subject to the conditions set out in the legislation.
We also regularly proposed proportionality measures to simplify the standard formula and quantitative reporting templates (QRTs). The changes adopted more than ten years after these initial efforts strengthen proportionality, but remain less far-reaching than our original proposals.
Revision and timetable: Directive (EU) 2025/2. Implementing and proportionality measures: European Commission.