Insurance timelines update: Q4 2025 to Q2 2027

Key regulatory and reporting deadlines for (re)insurers

We outline key regulatory and reporting deadlines for (re)insurers from Q4 2025 to Q2 2027. This update covers Solvency II reforms, actuarial and supervisory reporting, and emerging ESG and sustainability requirements, including EU Taxonomy and the Corporate Sustainability Reporting Directive (CSRD). It highlights critical dates for directives, technical standards, and guidelines to help insurers stay compliant and plan ahead.

Solvency II reform: Key milestones ahead

The Solvency II framework continues to evolve, with significant changes scheduled between Q4 2025 and Q2 2027. The European Commission adopted amended Delegated Acts on 29 October 2025, which will come into force once published in the Official Journal. Revised Implementing Technical Standards (ITS) are expected to take effect in January 2027 following consultations which are closing on 5 January 2026. Member States must transpose the updated Solvency II Directive into national law by 29 January 2027. These changes will impact valuation, disclosure templates, and risk margin calculations, requiring insurers to review governance and reporting processes well in advance.

Actuarial and reporting deadlines to note

Actuarial and supervisory reporting obligations remain central to compliance. Key timelines include quarterly Quantitative Reporting Templates (QRTs) with a five-week submission window and annual QRTs due 14 weeks after year-end for solo entities (20 weeks for groups). The Actuarial Function Report (AFR) and associated opinions on Technical Provisions and ORSA risks must align with these deadlines. Early engagement and “front-ending” reviews of assumptions and methodologies can help mitigate last-minute challenges.

ESG and sustainability: What’s changing?

Climate and sustainability reporting is entering a critical phase. From 1 January 2026, companies in scope of CSRD must disclose EU Taxonomy-aligned activities. Wave 1 entities—large public interest companies—will report on FY 2025 data in 2026, while Wave 2 and Wave 3 follow in 2028 and 2029 respectively. The Corporate Sustainability Due Diligence Directive (CSDDD) has been postponed to July 2028 for Wave 1 firms. Insurers should also prepare for enhanced ESG disclosures under EFRAG’s revised ESRS standards, with technical advice due by November 2025. These developments require robust data collection and governance frameworks to ensure accurate and timely reporting.

Domestic regime and peer review updates

Peer review cycles under the Domestic Actuarial Regime (DAR) currently occur every two to five years, depending on PRISM rating. However, the Central Bank of Ireland (CBI) is expected to begin a review of the DAR in 2026, following EIOPA’s Solvency II consultations. This review may lead to changes in peer review frequency, HoAF reporting obligations, and other governance requirements. Insurers should prepare for potential updates to actuarial processes and governance frameworks.

Preparing for 2027: Strategic considerations

The convergence of regulatory reforms and sustainability obligations by 2027 demands a strategic approach. Insurers should integrate regulatory timelines into enterprise risk management frameworks and allocate resources for implementation projects. Key priorities include updating reporting systems for revised ITS templates, embedding ESG metrics into financial planning, and ensuring actuarial teams are equipped for evolving DAR requirements. With proposed changes to Financial Stability reporting thresholds—from €12bn to €20bn in Solvency II balance sheet assets—firms should assess potential impacts on their reporting obligations. Early preparation will enable insurers to navigate complexity and maintain compliance without disrupting business operations.

Conclusion

The period from Q4 2025 to Q2 2027 represents a pivotal phase for (re)insurers, marked by regulatory reform, enhanced reporting standards, and sustainability-driven obligations. By acting early, leveraging technology, and engaging with expert advisors, insurers can turn compliance challenges into opportunities for improved governance and stakeholder confidence.

Key actions businesses can take today

1. Map regulatory deadlines

Develop a comprehensive compliance calendar covering key milestones such as Solvency II Directive transposition by January 2027, outsourcing register submissions by February 2026, and sustainability reporting starting in 2026. Early planning ensures timely compliance and reduces operational risk.

2. Strengthen governance and ORSA

Review governance frameworks under Pillar 2. Incorporate upcoming Solvency II changes into ORSA scenarios, including liquidity stress tests and revised technical provisions. Engage boards early and ensure actuarial opinions align with evolving regulatory expectations.

3. Prepare for ESG and CSRD

Begin collecting data for EU Taxonomy and CSRD disclosures now. Establish processes for sustainability KPIs and reporting templates to meet the 2026 implementation date. Proactive preparation enhances transparency and avoids last-minute challenges.

We’re here to help

Our Insurance and Risk Modelling team supports (re)insurers in navigating complex regulatory changes and reporting obligations. From Solvency II reforms and actuarial governance to ESG and sustainability disclosures, we bring deep expertise and provide practical insights to help you stay compliant and plan strategically. Contact our experts today to discuss how we can help you meet upcoming deadlines with confidence.