Today, 10 March 2026, Commission Delegated Regulation (EU) 2026/269 formally enters into force, marking the latest step in the ongoing reform of the Solvency II Delegated Regulation (EU) 2015/35 framework. The changes form part of the broader Solvency II Review Directive (EU) 2025/2, with most operational provisions applying from 30 January 2027.
For asset managers manufacturing UCITS, AIFs, and mutual funds distributed to European insurers, today’s milestone does not immediately alter reporting obligations. However, it begins the transition period toward a revised prudential framework that may influence how insurers assess fund investments and the data they request from managers.
What the new regulation changes
The delegated regulation introduces targeted amendments across several parts of the Solvency II framework, with the goal of reducing excessive prudence in capital requirements while maintaining policyholder protection. The reforms aim to free up insurer capital and encourage investment into long-term assets that support the European economy.
Key areas affected include:
- Technical provisions and long-term guarantee measures. Updates to the volatility adjustment and risk-margin methodology may affect how insurers value liabilities and measure solvency positions.
- Capital requirements for certain assets. Changes to equity risk calibrations and securitisation spread risk are intended to facilitate long-term equity investment and reduce barriers to securitisation exposure.
- Climate and catastrophe risk considerations. The framework reinforces the need for forward-looking modelling of climate-related risks and updates parameters for natural catastrophe exposures.
- Proportionality and simplified regimes. Smaller insurers may benefit from lighter reporting and governance requirements under the revised supervisory framework.
Although many of these changes operate on the insurer’s balance sheet, they influence how insurers evaluate investment funds held in their portfolios.
Implications for fund manufacturers
For managers whose funds are held by insurance clients, the practical impact will likely emerge gradually during the transition period to 2027. Insurers may begin reassessing the capital efficiency of different asset classes under the updated calibrations, particularly long-term equity and securitised exposures.
This could influence product positioning and portfolio construction discussions with insurance investors. For example, where capital charges shift, insurers may request additional transparency around portfolio composition, duration, or underlying exposures in order to assess the revised treatment under the standard formula or internal models.
In practice, insurers rely heavily on standardized look-through data from investment funds to calculate capital charges under the Solvency II standard formula and internal models. As capital calibrations evolve, insurers may revisit how they map asset exposures, duration profiles, and underlying risk characteristics within their reporting frameworks. This does not immediately change industry templates such as the FinDatEx Tripartite Template, but it may influence the level of detail insurers expect when evaluating fund investments.
Managers distributing into insurance channels should therefore expect ongoing dialogue with their insurance clients as these recalibrations are implemented.
Should we expect changes to the FinDatEx TPT?
At present, FinDatEx has not announced revisions to the Tripartite Template (TPT) linked specifically to this delegated regulation.
Most of the changes introduced by the regulation focus on insurer capital calculations and liability valuation rather than introducing new data requirements from investment funds. As a result, there is no immediate indication that the structure of the TPT will change as a direct consequence of this update.
However, two scenarios could still drive future template adjustments:
- Insurers requesting additional transparency to evaluate new capital treatments or climate-related considerations.
- Supervisory guidance from EIOPA or industry working groups that translate regulatory changes into additional data points for look-through reporting.
If such developments occur, they would typically be implemented through future TPT versions coordinated by FinDatEx rather than through the regulation itself.
Our perspective
For clients relying on us for the FinDatEx TPT or other European country-specific reporting, such as German VAG, Italian COVIP, and Dutch FTK reporting, there are no immediate reporting changes triggered by the regulation entering into force today. The main operational date remains 30 January 2027.
Over the coming months, we will monitor whether insurers begin requesting additional transparency as they prepare for the revised framework, and whether industry templates evolve to reflect new capital or risk considerations. Should any changes affect Solvency II reporting workflows or data requirements, we will communicate them well ahead of the implementation timeline.
If you would like to discuss how the Solvency II review may affect insurance distribution channels or reporting expectations for your funds, our team would be happy to help.
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