Instruction No. 2026-I-14 on the liquidity risk management plan required by Directive 2009/138/EC on insurance and reinsurance activities

PRUDENTIAL CONTROL AND RESOLUTION AUTHORITY

Instruction No. 2026-I-14 concerning the liquidity risk management plan required by Directive 2009/138/EC of the European Parliament and of the Council of 25 November 2009 on the taking-up and pursuit of the business of insurance and reinsurance (known as "Solvency II") The Prudential Control and Resolution Authority (ACPR), Having regard to Delegated Regulation (EU) XXX ("Macroprudential DR"); Having regard to Commission Delegated Regulation (EU) 2026/269 of 29 October 2025 amending Delegated Regulation (EU) 2015/35 as regards technical provisions, measures relating to long-term guarantees, own funds, equity risk, spread risk on securitisation positions, other capital requirements under the standard formula, communication and publication of information, proportionality and group solvency; Having regard to Commission Delegated Regulation (EU) 2015/35 of 10 October 2014 supplementing Directive 2009/138/EC of the European Parliament and of the Council on the taking-up and pursuit of the business of insurance and reinsurance (known as "Solvency II"); Having regard to the Insurance Code, in particular its articles L. 310-3-1, L. 322-1-2,
L. 322-1-3, L. 356-1, L. 356-2, L. 356-4;
Having regard to the Monetary and Financial Code, in particular its articles L. 517-4, L. 612-14,
L. 612-24 and R. 612-21;
Having regard to the Mutual Insurance Code, in particular its articles L. 111-4-2 and L. 211-10; Having regard to the Social Security Code, in particular its articles L. 931-2-2 and L. 931-6; Having regard to the opinion of the Consultative Committee on Prudential Affairs (CCAP) dated 26 June 2026, DECIDES
Article 1:
I. – The following entities are subject to this instruction:
a) insurance and reinsurance undertakings falling under the so-called "Solvency II" regime mentioned in articles L. 310-3-1 of the Insurance Code (including captive insurance and reinsurance undertakings mentioned in 1° and 3° of
article L. 350-2 of the same code), L. 211-10 of the Mutual Insurance Code and L. 931-6 of the
Social Security Code, with the exception of those that have obtained the status of small and non-complex undertaking in accordance with article L. 357-1 of the Insurance Code; b) groups mentioned in 5° of article L. 356-1 of the Insurance Code, with the exception of those that have obtained the status of small and non-complex group in accordance with article L. 356-27 of the Insurance Code, and subject to group supervision in application of the second and third paragraphs of article L. 356-2 of the same code, such as:

• insurance group companies and mutual insurance group companies
  mentioned in articles L. 322-1-2 and L. 322-1-3 of the Insurance Code;
• mutual group unions mentioned in article L. 111-4-2 of the Mutual Insurance Code;
• social protection insurance group companies mentioned in article
  L. 931-2-2 of the Social Security Code;
• mixed financial holding companies mentioned in article L. 517-4 of the
  Monetary and Financial Code, included in group supervision within the meaning of article
  L. 356-2 of the Insurance Code;
• insurance and reinsurance undertakings falling under the so-called
  "Solvency II" regime, mentioned in articles L. 310-3-1 of the Insurance Code,
  L. 211-10 of the Mutual Insurance Code and L. 931-6 of the Social Security Code,
  when they are also participating undertakings within the meaning of 3° of article
  L. 356-1 of the Insurance Code;
  hereinafter referred to as "Groups"; c) French sub-groups designated in application of article L. 356-4 of the Insurance Code; hereinafter referred to as "Groups".
  II. – In application of article L.356-20-2 of the Insurance Code, the entities listed in I. a) falling within the scope of the liquidity risk management plan covering the consolidated Group and all its subsidiaries in application of I. of article 4, are exempted from the obligation to establish and maintain a liquidity risk management plan at the individual level.
  Article 2:
  I. – In accordance with article L. 354-4 of the Insurance Code, the entities defined
  in article 1 establish and maintain a liquidity risk management plan with a short-term horizon (as defined in article XX of the Macroprudential Delegated Regulation) with the exception of entities benefiting from a proportionality measure by decision of the ACPR in accordance with article 327 octies of Delegated Regulation (EU) 2026/269 or entities benefiting from the status of small and non-complex undertaking defined in article L. 357-1 of the Insurance Code.
  II. – In accordance with article 9 of the Macroprudential Delegated Regulation supplementing
  Delegated Regulation (EU) 2015/35, the liquidity risk management plan is updated annually and without delay following any significant change in the entity's liquidity risk profile or any major external event having a significant impact on the relevance of the content of the liquidity risk management plan.
  Article 3:
  I. – In application of article R. 354-9 of the Insurance Code and article XX
  of the Macroprudential Delegated Regulation supplementing Delegated Regulation (EU) 2015/35, the entities listed in article 1 whose total assets are greater than EUR 20,000 integrate into their liquidity risk management plan the medium and long-term horizon (as defined in article XXX of the Macroprudential DR).
  II. – In accordance with article R. 354-9 of the Insurance Code and XX of the
  Macroprudential Delegated Regulation supplementing Delegated Regulation (EU) 2015/35, the entities listed in article 1 whose total assets are less than EUR 20,000 integrate into their liquidity risk management plan the medium and long-term horizon, by decision of the ACPR.
  III. – An entity subject to integrating the medium and long-term horizon into its liquidity risk management plan
  in application of I. or II. remains subject until the ACPR decides to no longer subject it.
  Article 4:
  I. – Groups apply the horizons provided for in articles 2 and 3 to all their subsidiaries and the consolidated Group.
  II. – In case of exemption from the Group's liquidity risk management plan in
  application of articles 327 octies and 377 ter of Delegated Regulation (EU) 2026/269 and L.354-4 of the Insurance Code, the proportionality measure also applies to all its subsidiaries.
  III. – The information to be provided in the group liquidity risk management plan for each subsidiary is:
• for subsidiaries not benefiting from the status of small and non-complex undertaking as defined in article L. 357-1 of the Insurance Code, the information
  listed in Annex A;
• for subsidiaries benefiting from the status of small and non-complex undertaking
  as defined in article L. 357-1 of the Insurance Code:
  i documentation of the approach for integrating the subsidiary into the group's projections; ii description of liquidity support mechanisms for the subsidiary; iii formalization, where applicable, of the group's commitment to support the subsidiary.
  Article 5:
  By derogation from II. of article 1, the ACPR may decide to subject to the obligation to establish and maintain a liquidity risk management plan at the individual level organisms listed in I. a) falling within the scope of group supervision by written decision. This decision details the reason leading the ACPR to subject the organism in accordance with the cases provided for by article L. 356-20-2 of the Insurance Code.
  Article 6:
  I. – In application of article L. 612-24 of the Monetary and Financial Code, the ACPR
  requires submission of the liquidity risk management plan within 2 weeks after validation of the document by the entity's board of directors or supervisory board for the annual update and for any update. This submission is made in accordance with instruction n° 2025-I-06 of 26 May 2025.
  II. – The medium and long-term analysis to be carried out by decision of the ACPR
  must be integrated into the liquidity risk management plan the year following the notification of the decision taken in application of II. of article 3.
  III. – Groups subject to ACPR group supervision in application of the
  second and third paragraphs of article L. 356-2 or article L. 356-4 of the Insurance Code present their liquidity risk management plan provided for in article 4.
  IV. – Undertakings whose parent company is not subject to ACPR supervision
  and benefiting from the exemption provided for in II. of article 1 submit their group liquidity risk management plan.
  V. – The liquidity risk management plan must be submitted in an office format, machine-readable.
  Article 7:
  I. – An entity not classified as a small and non-complex undertaking
  that made a request for a proportionality measure in 2027 for an exemption from a liquidity risk management plan in application of article L. 357-10 of the Insurance Code and was refused this exemption by the ACPR must submit its first liquidity risk management plan in 2028.
  II. – An entity subject to the integration of the medium and long-term horizon in
  application of I. of article 3 of this instruction integrates this horizon into its liquidity risk management plan from 2028.
  Article 8:
  This instruction enters into force on January 30, 2027.
  Paris, July 10, 2026
  For the Sectoral Sub-College for Insurance
  The President,
  Jean-Paul FAUGÈRE
  Annex A - Liquidity risk management plan for subsidiaries of a group not benefiting
  from the status of small and non-complex undertaking
  Annex A – Liquidity risk management plan for subsidiaries of a group not benefiting from the status
  of small and non-complex undertaking
  The liquidity risk management plan for subsidiaries of a group follows the plan provided for in article 3 of DR XXX:
  Solo LRMP | LRMP of subsidiaries to be integrated into group LRMP ---|--- Overall assessment | Overall assessment* Assumptions underlying projections | The granularity of assumptions for the group must
  | allow understanding of the underlying data of the |
  | --- |
  | subsidiaries |
  Cash flow projections (in central and stressed scenarios) | Available liquidity balance (need or resource)
  | at the end of projections in central and |
  | --- |
  | stressed scenarios |
  Liquid asset reserves | Liquid asset reserves* Liquidity risk indicators | Liquidity risk indicators* Any other information | Any other information* *These parts are to be carried out in application of the corresponding articles of Delegated Regulation XXX.