SBS Resolution No. 3424-2025: Approves the Regulation on Actuarial Aspects for Benefit Funds

Los Laureles Nº 214 - Lima 27 - Peru Tel. : (511)6309000 Lima, September 23, 2025 SBS RESOLUTION No. 03424-2025 The Superintendent of Banking, Insurance and Private Pension Fund Administrators, CONSIDERING:
That, in accordance with the provisions of Article 345 of the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance, approved by Law No. 26702 and amending regulations, the Superintendency of Banking, Insurance and Private Pension Fund Administrators, hereinafter the Superintendency, exercises within the scope of its powers, the control and supervision of the companies forming part of the financial system and insurance system and of other natural and legal persons incorporated by said law or by special laws, exclusively in the aspects that correspond to it; That, by Law No. 26516 and its amending regulation, the Benefit Funds and Derramas created by Legislative Decree No. 21021, Supreme Decrees No. 01 and 78 of 1965 and Supreme Decree No. 030 of 1966, as well as any other Fund that receives resources from its affiliates, partners or associates, for the purpose of allocating them to the provision of benefits consisting of the granting of unemployment, retirement, or similar or additional pensions, whatever their denomination or form of constitution, were incorporated into the control and supervision of the Superintendency; it being further provided that said control and supervision shall be carried out in accordance with the rules provided in its Organic Law, and any others it may issue for this purpose; That, by Supreme Decree No. 160-95-EF, the Regulation for the Control and Supervision of Derramas, Benefit Funds – Law No. 26516 was approved, specifying in its Article 2 that the Superintendency controls and supervises the entities created by Legislative Decree No. 21021, Supreme Decree No. 01 of 1965, Supreme Decree No. 78 of 1965 and Supreme Decree No. 30 of 1966, expressly indicated in Law No. 26516; establishing that the control and supervision exercised by the Superintendency shall be carried out only on those aspects specific to unemployment and retirement pension funds; its main function being to safeguard the economic and financial soundness of retirement, unemployment, similar or additional pension plans, which allows the payment of the benefits they grant, in accordance with the legal provisions and statutory norms governing each fund; That, Article 6 of the aforementioned Regulation indicates the powers of the Superintendency for the development of its supervision and control tasks, among which is to issue complementary norms and regulations related to the calculation of periodic actuarial valuations that allow evaluating the situation of pension funds regarding their contributions, as well as related to the actuarial models that each fund must apply to determine technical reserves; That, by Legislative Decree No. 1133, provisions were issued for the definitive ordering of the pension regime for military and police personnel; That, Article 21 of the Regulation of Legislative Decree No. 1133, approved by Supreme Decree No. 101-2021-EF, establishes that the Military
Police Pension Fund must carry out adequate management of the technical risks of this pension regime; and that for this purpose the Superintendency may issue norms for the adequate management of technical risks; That, by SBS Resolution No. 962-95, the register called “Register of Derramas and Benefit Funds - Law No. 26516” was created in the Superintendency of Banking, Insurance and Private Pension Fund Administrators; That, by Circular No. DCB-13-2014-SBS, criteria were established for the presentation of financial information by the Military Police Pension Fund and the Derramas; That, by SBS Resolution No. 272-2017 and its amending regulations, the Regulation on Corporate Governance and Comprehensive Risk Management was approved, respectively; That, among other aspects, Article 3 of the Regulation on Corporate Governance and Comprehensive Risk Management indicates that Benefit Funds must define general principles and guidelines for the adoption and implementation of corporate governance practices that serve as a guide for the actions of their governing bodies; likewise, the aforementioned article indicates that their corporate structure and organization must be consistent with the nature of their operations and services; That, among other aspects, Article 22 of the Regulation on Corporate Governance and Comprehensive Risk Management indicates that Comprehensive Risk Management is a process applied to the entire entity and in the definition of its strategy, designed to identify potential events that may affect it, manage them according to its risk appetite and provide reasonable assurance in achieving its objectives. Likewise, it is indicated that Comprehensive Risk Management includes the entire entity, its business lines, processes and organizational units, across all its relevant risks and that it is the responsibility of each entity to design and apply comprehensive risk management, appropriate to its nature, size and the complexity of its operations and services; That, it is necessary for Benefit Funds, including the Military Police Pension Fund, to design and apply technical risk management appropriate to the nature, size and complexity of the operations they carry out and/or the pension regimes they administer, considering the macroeconomic and capital market environment, within the framework of current laws and regulations on the matter, as well as their statutes and/or internal regulations; That, it is necessary to modify the Norms for the Registration of Directors, Managers and Principal Officials – REDIR, approved by Circular No. G-213-2021 and its amending regulations, in order to adapt said norms to the provisions linked to actuarial aspects for benefit funds; That, in order to gather public opinion regarding the proposed norm, the draft resolution on the matter was published by SBS Resolution No. 548-2025 in the official gazette El Peruano and on the digital headquarters of the Superintendency, under the provisions of the
Thirty-Second Final and Complementary Provision of the General Law and Supreme Decree No. 009-2024-JUS; With the approval of the Assistant Superintendencies of Private Pension Fund Administrators, Insurance and Regulation and Legal Affairs; and, In use of the powers conferred by numerals 7 and 9 of Article 349 of the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance approved by Law No. 26702 and its amendments; as well as by Law No. 26516; RESOLVES:
Article First.- To approve the Regulation on Actuarial Aspects for Benefit Funds, in accordance with the following text:
“REGULATION ON ACTUARIAL ASPECTS FOR BENEFIT FUNDS
Article 1.- Scope
1.1. This Regulation applies to Benefit Funds whose supervision is under the charge of the Superintendency, including the Military Police Pension Fund created by Legislative Decree No. 21021.
1.2. The provisions of this Regulation are complementary to the provisions of the Corporate Governance and Comprehensive Risk Management Regulation, approved by SBS Resolution No. 272-2017 and its amending regulations, and Supreme Decree No. 101-2021-EF and its amendments.
Article 2.- Definitions
For the purposes of this Regulation, the following definitions shall be considered:

1. Affiliates or associates: natural persons whose registration is current in the Benefit Fund and/or in the pension regimes it administers, in accordance with current laws and regulations on the matter, statutes and/or internal regulations, and who are the direct holders of the benefits.
2. Technical operational areas: those areas within the organization of the Benefit Fund, which are responsible for the continuous and routine execution of policies, procedures and methodologies related to the constitution of technical reserves. In their areas of action, these areas contribute to the management of technical risks.
3. Beneficiaries: natural persons who enjoy a benefit in the form of a pension or others, related to retirement, withdrawal, unemployment, invalidity or incapacity, death, survivorship (widowhood, orphanhood, ascendants), among other risks, in accordance with current laws and regulations on the matter, and the statutes or internal regulations of the Benefit Funds.
4. Methodological document for the calculation of technical reserves: document in which the methodology (models, parameters, assumptions and other relevant considerations) that the Benefit Fund applies for the calculation of technical reserves is described. This document may receive other denominations such as, for example, technical note, which is mentioned in Article 20 of the regulatory and complementary norms approved with Supreme Decree No. 101-2021-EF.
5. General Law: General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and Insurance, Law No. 26702 and amending regulations.
6. Corporate Governance and Comprehensive Risk Management Regulation: Regulation approved by SBS Resolution No. 272-2017 and amending regulations.
7. Technical reserves: are the estimates of obligations for insurable risk coverages assumed by the Benefit Fund and/or by the pension regimes administered by it, towards affiliates or associates and their beneficiaries, related to withdrawal or retirement, death, invalidity, among other risks, in accordance with current laws and regulations on the matter, as well as its statutes and/or regulations.
8. Technical risk: the possibility of losses or adverse modification of the value of obligations contracted by the Benefit Fund and/or by the pension regimes administered by it, in accordance with current laws and regulations on the matter, and internal statutes and/or regulations.
9. Superintendency: Superintendency of Banking, Insurance and Private Pension Fund Administrators.
   Article 3.- Technical risk management
   3.1 The Benefit Fund must design and apply technical risk management appropriate to the nature, size and complexity of the operations it carries out and/or the pension regimes it administers, and considering the macroeconomic and capital market environment, within the framework of current laws and regulations on the matter, and internal statutes and/or regulations.
   3.2 The Board of Directors or equivalent body, general management, the technical risk management function and the technical operational areas contribute to technical risk management within their respective responsibilities.
   Article 4. Responsibility of the Board of Directors or equivalent body
   The Board of Directors or equivalent body has the following responsibilities associated with technical risk management:
10. Approve and periodically review, at least annually, the objectives, guidelines and strategy for technical risk management.
11. Approve and periodically review, at least annually, the policies, procedures and manuals that include aspects related to the analysis of the sufficiency of contributions, technical reserves, data quality and other aspects related to technical risk management.
12. Approve the methodological documents for the calculation of technical reserves.
13. Approve and periodically review the organizational structure and the necessary resources for the fulfillment of the technical risk management function, in such a way as to ensure that said function is carried out effectively and avoiding conflicts of interest.
14. Appoint the official in charge of the technical risk management function, regardless of whether the activities referred to in Article 6 have been partially or totally outsourced. In case this function is outsourced, either partially or totally, appoint the person responsible for the outsourced function, in accordance with paragraph 14.3 of Article 14 of this Regulation.
15. Arrange the necessary measures to periodically monitor exposure to the main technical risks and ensure the implementation of actions or plans derived from this monitoring.
    Article 5. Management Responsibility
    5.1 General management is responsible for implementing technical risk management in accordance with the provisions of the Board of Directors or equivalent body and current regulations.
    5.2 The managements of the technical operational areas must inform the official in charge of the technical risk management function of any relevant event that affects the fulfillment of their respective obligations.
    Article 6. Technical risk management function
    6.1 The official in charge of the technical risk management function must carry out, with a minimum annual frequency, at least the following activities:
16. Perform an independent recalculation of technical reserves based on calculation files and working papers different from those used by the technical operational areas.
17. Evaluate the methodologies, assumptions and parameters applied by the Benefit Fund in the calculation of technical reserves.
18. Evaluate the sufficiency and quality of the data used in the calculation of technical reserves.
19. Analyze the reasonableness of technical reserves by conducting backtesting studies and, if applicable, establish recommendations regarding the sufficiency of technical reserves, as well as the methods and procedures used for their calculation.
20. Based on the principle of proportionality and/or data limitation, evaluate cases where backtesting studies would not be necessary or applicable.
21. Analyze the sufficiency of contributions for the payment of benefits to affiliates or associates.
22. Identify and evaluate the technical risks inherent to the obligations of the Benefit Fund and/or the pension regimes it administers, analyzing their incidence and impact on results and solvency.
23. Calculate and monitor the technical risk indicators that have been previously defined by the Benefit Fund, including the analysis of deviations that occur and their possible causes.
24. Participate in the effective implementation of the technical risk management system.
25. Continuously and timely inform the Board of Directors and General Management about relevant aspects of technical risk management, for timely decision-making.
26. Prepare special reports requested by the Superintendency.
    6.2 The official in charge of the technical risk management function must prepare an annual report, covering up to December 31 of each year, in which all the activities indicated in paragraph 6.1 must be documented, possible deficiencies determined, and corresponding recommendations formulated.
    6.3 The annual report must be brought to the attention of the Board of Directors or equivalent body so that it can determine the appropriate corrective or preventive measures.
    6.4 The annual report of the technical risk management function must be submitted to the Superintendency no later than ninety (90) calendar days after the close of each year, attaching the minutes of the Board of Directors or equivalent body corresponding to the session in which said report was reviewed.
    Article 7. Technical reserves
    7.1 The Benefit Fund must use its own methodology for the calculation of technical reserves, considering the most appropriate actuarial method, according to the profile of the risks covered and the available information.
    7.2 The constitution, calculation and monitoring of technical reserves must be carried out based on actuarial and financial principles and methods.
    7.3 Technical reserves must be calculated prudently, reliably, objectively and transparently, ensuring that the actuarial model and the results obtained can be reviewed by a qualified third-party expert.
    7.4 Technical reserves must be calculated monthly.
    7.5 The hypotheses, assumptions, parameters (mortality and morbidity tables, probabilities of invalidity and withdrawal, technical interest rates, among others), actuarial formulas and other considerations applied in the calculations of technical reserves, must be realistic and adequate, must be supported by the respective methodological documents for the calculation of technical reserves and must be applied consistently over time, without arbitrary changes.
    7.6 Mortality, morbidity and invalidity tables, among other probability tables used to estimate technical reserves, must comply with the following requirements:
27. They must be based on national or foreign experience.
28. In case adjustment factors are used for these tables, these must be supported by the Benefit Fund's own statistics, considering generally accepted actuarial practices in the academic field.
29. The tables cannot be older than twenty-five (25) years at the date of calculation of the technical reserves.
30. In case demographic assumptions based on the Benefit Fund's own experience are used, these must be constructed based on sufficient, homogeneous and representative information of the risk, so that the estimation complies with the provisions on data quality.
    7.7 The Benefit Fund must contract the services of at least one actuarial professional, assigned to one of the technical operational areas, to be responsible, at a minimum, for the following functions:
31. Calculate and monitor technical reserves.
32. Review and improve the methodologies for calculating technical reserves, taking into consideration the recommendations formulated by the official in charge of the technical risk management function.
33. Monitor and update the assumptions and parameters applied in the calculations of technical reserves.
34. Prepare and update the methodological documents for the calculation of technical reserves.
    Article 8. Methodological document for the calculation of technical reserves
    8.1 The Benefit Fund must keep the methodological document for the calculation of technical reserves updated. Said document must be approved by the Board of Directors or equivalent body and be available to the Superintendency.
    8.2 The actuarial professional referred to in paragraph 7.7 of Article 7 must propose the modification of the methodological document for the calculation of technical reserves, as a result of technical reserve sufficiency studies (backtesting), if applicable.
    Article 9. Technical reserve sufficiency test
    9.1 The Benefit Fund must implement a “backtesting” type methodology for validating technical reserves, based on the principle of proportionality, which allows comparing the actual results of a particular period with the corresponding projections made in previous periods for the considered period. “Backtesting” studies must be carried out at least annually, with the purpose of evaluating the reasonableness and sufficiency of the technical reserves constituted.
    9.2 When the Superintendency detects that the results obtained from the application of the methodologies or models used by the Benefit Fund for the calculation of technical reserves do not reasonably reflect its obligations or the obligations of the pension regimes it administers, it may request the modification of these methodologies within a determined period or assign a different methodology for the calculation of technical reserves.
    Article 10. Technical risk indicators
    10.1 The Benefit Fund must develop its own indicators to monitor and evaluate the technical risks inherent to its obligations or the obligations of the pension regimes it administers.
    10.2 Technical risk indicators must be calculated periodically, at least semi-annually.
    10.3 The technical risk indicators developed by the Benefit Fund must consider, at least, the following aspects: interest rate applied in the calculation of technical reserves, remuneration growth rate, pension growth rate, and mortality, invalidity and withdrawal risks.
    10.4 The working files and databases used for the calculation of these indicators must be available to the Superintendency.
    Article 11. Data quality
    11.1 The Benefit Fund must have adequate internal processes and procedures to ensure that the data used for the calculation of technical reserves and technical risk indicators are complete, accurate and adequate.
    11.2 Data are considered complete when they meet the following conditions:
35. They include sufficient historical information to reasonably calculate technical reserves and allow for the evaluation of technical risks arising from the obligations of the Benefit Fund or the pension regimes it administers.
36. They are available for these calculations and no relevant data is excluded without justification.
    11.3 Data are considered accurate when they meet the following conditions:
37. They do not contain significant errors that could influence decision-making or the judgment of the users of the calculation result, including the Superintendency.
38. Data from different periods used for the same estimation are consistent.
39. They are recorded in a timely and consistent manner over time.
    11.4 Data are considered adequate when they meet the following conditions:
40. They are consistent with the purposes for which they will be used.
41. The nature of the data ensures that the estimates of technical reserves do not include a significant estimation error that could influence decision-making or the judgment of the users of the calculation result, including the Superintendency.
42. They are consistent with the hypotheses on which the actuarial and statistical techniques applied to them when calculating technical reserves are based.
43. They adequately reflect the risks to which the Benefit Fund or the pension regimes it administers are exposed.
44. They have been collected, processed and applied in a transparent and structured manner.
    11.5 When the Benefit Fund does not have sufficient data of adequate quality to apply an actuarial method f