On 25 March 2020, the Dutch Central Bank (De Nederlandsche Bank, DNB) published a news item on postponing the reporting periods for insurers due to the COVID-19 outbreak. DNB follows the recommendations published on 20 March 2020 by the European Insurance and Occupational Pensions Authority (EIOPA) on supervisory flexibility regarding the deadline of supervisory reporting and public disclosure.
DNB welcomes and follows these recommendations, as the COVID-19 outbreak has significant impact on the Dutch economy. DNB published the letters it has sent to Dutch Solvency II Basic insurers and Dutch Solvency II insurers.
For Solvency II Basic insurers, DNB allows for an eight week delay in the submission of annual reports. The first quarterly reports have to be submitted no later than a week after the original deadline. DNB does encourage insurers to submit the reports as soon as they reasonably can. For insurers with a dispensation, DNB states that these insurers should get in touch with DNB as soon as they no longer meet the conditions of the dispensation. DNB also requests the internal management reports for the first quarter from insurers with a dispensation.
Solvency II insurers should follow the deadlines set out in the recommendations by EIOPA. DNB encourages insurers to submit the full report on the first delivery, with an optional two week delay for the annual reports and a one week extension for the quarterly reports. DNB does not make use of the option stated in the EIOPA recommendations to request additional information from insurers with a dispensation for the quarterly reports. DNB notes that insurers with a dispensation should contact DNB as soon as they no longer meet the conditions for the dispensation and that DNB will request the internal management reports for the first quarter.
DNB allows for an eight week delay for the Solvency II annual report National States. The Solvency II quarterly report National States impact alternative extrapolation method can be submitted one week after the original deadline. The annual report, the actuarial function report and the audit report have to be submitted within the original deadline, 30 June 2020.
Finally, for both Solvency II Basic insurers and Solvency II insurers, DNB extends the period for the digital signature from the auditor with 8 weeks. This means that reports can be submitted and published without a fully complete audit, but DNB notes that it prefers that the audit be completed as soon as reasonably possible.