Instruction No. 2026-I-02 on the ACPR Authorization Procedure for Simultaneous Group and Subsidiary ORSA, RSR, and SFCR Reporting

AUTORITÉ DE CONTRÔLE PRUDENTIEL ET DE RÉSOLUTION ----- Instruction No. 2026-I-02 regarding the authorization procedure by the Prudential Control and Resolution Authority to proceed simultaneously at the group level and at the level of any group subsidiary to the internal assessment of risks and solvability ("Single ORSA"), the single report to the supervisor ("Single RSR") and the single report on solvency and financial situation ("Single SFCR") replacing Instructions No. 2015-I-27 and No. 2015-I-28 of December 17, 2015 modified by Instruction No. 2024-I-11 of October 21, 2024

The Prudential Control and Resolution Authority, Having regard to Delegated Regulation (EU) 2015/35 of the Commission of October 10, 2014 supplementing Directive 2009/138/EC of the European Parliament and of the Council on the access to and exercise of the activities of insurance and reinsurance (known as "Solvency II"); Having regard to Delegated Regulation (EU) 2026/269 of the Commission of October 29, 2025 amending Delegated Regulation (EU) 2015/35 as regards technical provisions, measures relating to long-term guarantees, own funds, equity risk, spread risk on securitization positions, other capital requirements under the standard formula, disclosure and publication of information, proportionality and group solvency; Having regard to the Insurance Code, in particular Articles L. 356-2, L. 356-19, L. 356-21-1, L. 356-25, L. 357-1, R. 350-1, R. 355-1, R. 356-46, R. 356-47, R.356-511, R. 356-59 and R. 356-60; Having regard to the Monetary and Financial Code, in particular Article L. 612-24; Having regard to the Mutual Code; Having regard to the Social Security Code; Having regard to EIOPA Guidelines 14/259 on the internal assessment of risks and solvency (ORSA); Having regard to the opinion of the Prudential Affairs Advisory Commission (CCAP) dated June 26, 2026, DECIDES

Article 1:
Participating companies and parents mentioned respectively in the second and third paragraphs of Article L. 356-2 of the Insurance Code, which wish, in accordance with the fifth paragraph of Article L. 356-19 of the same code, to proceed simultaneously at the group level and at the level of any group subsidiary to the internal assessment mentioned in the second paragraph of Article L. 354-2 of the same code (internal assessment of risks and solvency, hereinafter "ORSA"), and to draw up a single document encompassing all these assessments (hereinafter "Single ORSA Report"), must submit a written application to the Prudential Control and Resolution Authority acting as group supervisor, which rules within the time limits provided for in Article R. 356-46 of the same code. A file must accompany this written application.

Article 2:
Participating companies and parents mentioned respectively in the second and third paragraphs of Article L. 356-2 of the Insurance Code, which wish, in accordance with Article L. 356-25 of the same code, to publish a single report on solvency and financial situation ("Single SFCR") containing information at the group level and of any group subsidiary, must submit a written application, at least five months before the end of the financial year to which the Single SFCR relates, to the Prudential Control and Resolution Authority acting as group supervisor, which rules within the time limits provided for in Article R. 356-60 of the same code. A file must accompany this written application. The report referred to in Article XXX of the Insurance Code [Article 51 bis §6 of the S2 Directive] is produced for each subsidiary and the group and is presented to the supervisory authority of the company by the group.

Article 3:
Participating companies and parents mentioned respectively in the second and third paragraphs of Article L. 356-2 of the Insurance Code, which wish, in accordance with Article L. 356-21-1 of the same code, to submit a single regular report to the supervisor ("Single RSR") containing information at the group level and of any group subsidiary, must submit a written application, at least five months before the end of the financial year to which the Single RSR relates, to the Prudential Control and Resolution Authority acting as group supervisor, which rules within the time limits provided for in Article R.356-51-1 of the same code. A file must accompany this written application.

Article 4:
The application file mentioned in Article 1 must contain the following information:

• the coverage scope of the Single ORSA Report (list of insurance and reinsurance subsidiary companies covered);
• the reasons for the choice of this scope and a justification that each subsidiary receives sufficient treatment in the Single ORSA Report, with regard to its size, structure and the complexity of its risks and with regard to those of the group as a whole;
• a description of how the governance requirements relating to the ORSA are covered for each of the subsidiaries and in particular how the administrative, management or supervisory bodies of the insurance and reinsurance subsidiaries (in particular the boards of directors or supervisory boards for French entities) are involved in the assessment process, as well as in the approval of the Single ORSA Report by the board of directors and supervisory board of the companies mentioned in Article 1;
• a description of the envisaged content and structure elements of the Single ORSA Report, both for the sections relating to individual assessments which must be identifiable, and for that relating to the group;
• a presentation of the translation arrangements provided for in accordance with Article R. 356-47 of the Insurance Code.

Article 5:
The application file mentioned in Article 2 must contain the following information:

• the coverage scope of the Single SFCR (list of insurance and reinsurance subsidiary companies covered);
• a description of the process for drawing up the Single SFCR, and in particular the involvement of the administrative, management or supervisory bodies of the insurance and reinsurance subsidiaries (in particular the boards of directors or supervisory boards for French entities), in the drawing up of the Single SFCR, as well as in its approval by the board of directors or supervisory board of the companies mentioned in Article 2;
• a description of the envisaged content and structure elements of the Single SFCR, both for the information relating to each of the subsidiaries, which must be individually identifiable in accordance with Article R. 356-59 of the Insurance Code, and for that relating to the group;
• a presentation of the translation arrangements provided for in accordance with Article 366 of Delegated Regulation (EU) 2015/35 of the Commission of October 10, 2014.

Article 6:
The application file mentioned in Article 3 must contain the following information:

• the coverage scope of the Single RSR (list of insurance and reinsurance subsidiary companies covered);
• a justification that each insurance or reinsurance subsidiary receives sufficient treatment in the Single RSR, with regard to the size, structure and complexity of the risks of the subsidiary and the group as a whole;
• a description of the process for drawing up the Single RSR, and in particular the involvement of the administrative, management or supervisory bodies of the insurance and reinsurance subsidiaries (in particular the boards of directors or supervisory boards for French entities), in the drawing up of the Single RSR, as well as in its approval by the board of directors or supervisory board of the companies mentioned in Article 3;
• a description of the envisaged content and structure elements of the Single RSR, both for the information relating to each of the subsidiaries, which must be individually identifiable in accordance with Article L.356-21-1 of the Insurance Code, and for that relating to the group;
• a presentation of the translation arrangements provided for in accordance with Article 374 of Delegated Regulation (EU) 2015/35 of the Commission of October 10, 2014.

Article 7:
I. - The obtaining of the proportionality measure concerning the reduction of ORSA frequency in accordance with Article R. 354-3-4 of the Insurance Code [Article 45 §5 of the S2 Directive] for a group benefiting from a single report in application of Article 1 of this instruction is conditional upon the obtaining of this proportionality measure by each of the insurance and reinsurance entities included in the scope of the single report.
II. - The obtaining of the proportionality measure concerning the reduction of the frequency of submission of the RSR in accordance with Article R. 355-5-2 of the Insurance Code [Article 35 §5 bis of the S2 Directive] for a group benefiting from a single report in application of Article 3 of this instruction is conditional upon the obtaining of this proportionality measure by each of the insurance and reinsurance entities included in the scope of the single report.
III. – In the case of insurance subsidiaries covered by the Single SFCR in application of Article 2 of this instruction benefiting from the status of small and non-complex enterprise in accordance with Article L. 357-1 of the Insurance Code, the Single SFCR includes for the subsidiaries concerned the simplified information provided for in Article R. 355-8-4 of the Insurance Code [Article 51 of the S2 Directive] and complete information every three years.

Article 8:
The applications and files mentioned in Articles 1, 2 and 3 must be addressed to the Prudential Control and Resolution Authority acting as group supervisor by electronic means by depositing them at the following address: https://acpr-portail.banque-france.fr.

Article 9:
This instruction replaces Instruction No. 2015-I-27 of December 17, 2015 (modified by Instruction No. 2024-I-11 of October 21, 2024) as well as Instruction No. 2015-I-28 of December 17, 2015 (modified by Instruction No. 2024-I-11 of October 21, 2024).
References to Instruction No. 2015-I-27 of December 17, 2015 and to Instruction No. 2015-I-28 of December 17, 2015 shall be understood as being made to this instruction.

Article 10:
This instruction enters into force on January 30, 2027.
Paris, July 10, 2026
For the Insurance Sectoral Sub-College
The President,
Jean-Paul FAUGÈRE