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Background information

The digital report on the use of limitations and exemptions from Solvency II reporting is an annual publication by EIOPA, which provides an overview of the number of National Competent Authorities (NCAs) that grant limitations and/or exemptions from Solvency II reporting requirements to solo undertakings and groups in the European Economic Area (EEA).

As described in Article 35, paragraphs 6 and 7 of the Solvency II Directive, solo undertakings may be subject to limitations or exemptions to report certain information as follows:

  • Limitation: Submit quarterly reporting information of reduced scope, where this information is reported at least annually. All templates, with the exception of the minimum capital requirement (MCR) template, can be subject to a limitation (Article35 (6)).
  • Exemption: Be exempted from both quarterly and annual reporting in case of reporting templates on an item-by-item basis under certain conditions (Article 35(7)).

The limitation to regular supervisory reporting can only be granted to undertakings that do not represent more than 20% of a Member State’s life, non-life and reinsurance market share, respectively.

Groups, as specified in Article 254(2), paragraphs 2 and 3, can benefit from limitations and/or exemptions from reporting only if all insurance or reinsurance undertakings within the group would benefit from the corresponding limitation and/or exemption.

Finally, Article 35 requires supervisory authorities to give priority to the smallest undertakings when determining the eligibility of the undertakings for those limitations.

Limitations and/or exemptions at solo level

Annual reporting

Figure 1


In 2024, the same four NCAs granted limitations and/or exemptions from annual reporting to 119 solo undertakings, marking a very slight increase from 118 in 2023. This represents 5.13% of the total number of solo undertakings, up from 5.04% in the previous year.

NCAs slightly adjusted their numbers of limitations and/or exemptions: France exempted 2 additional solo undertakings, whilst Germany reduced its exemptions by one compared to 2023. Meanwhile, Norway maintained its practice of exempting more than half of its solo undertakings from annual reporting and Liechtenstein exempted the same 7 solo undertakings as in 2023.


Figure 1 - Number of solo undertakings with at least one limitation/exemption

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Annual reporting solo

Table 1


In the EEA, only 5.13% of the total number of solo undertakings, representing 1.47% of the market share for non-life business (measured by gross written premium (GWP)) and 0.73% for life business (measured by technical provision (TP)) are benefiting from limitations and/or exemptions from annual reporting.


Table 1 - Overview of limitations/exemptions - by key measures

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Annual reporting solo

Table 2


The open derivatives template remains the most frequently exempted template overall. In terms of number, however, a very slight decrease is noted from 103 to 100 limitations and/or exemptions from 2023 to 2024, which can be explained by France and Germany reducing their limitations and/or exemptions by two and one respectively (i.e., from 8 to 6 and from 61 to 60).

The templates exempted vary from one undertaking to another, indicating a risk-based approach is being taken. However, this variability makes it challenging to draw straightforward conclusions from the data, as certain templates (e.g., those related to structured products or securities lending and repo) may not be applicable to specific undertakings. As a result, the absence of limitations and/or exemptions for these templates does not necessarily imply a lack of need, but rather that they are not relevant to the undertaking in question.


Table 2 - Overview of limitations/exemptions - by template

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Annual reporting solo

Figure 2


This figure visualises the data in Table 2, showing the year-over-year changes in the number of exempted solo undertakings by country and template. The change for a specific template can be selected from the drop-down menu on the right.

The graphic shows that, with the exception of the securities lending and repo template, which remained unchanged across all countries, the variations in exempted solo undertakings between 2023 and 2024 are relatively minor.


Figure 2 - Change in number of exempted undertakings between 2023 and 2024 by template and country

Note: Only countries that had at least one limitation and/or exemption granted during the reference period considered are shown.
Source: EIOPA Annual reporting solo

Quarterly reporting

Figure 3


In 2025 Q1, nine NCAs granted limitations and/or exemptions to quarterly reporting to 638 solo undertakings, a slight increase from 636 solo undertakings in the same period last year. The proportion of exempted solo undertakings to the total number of solo undertakings also rose very slightly, from 26.98% in 2024 Q1 to 27.35% in 2025 Q1, indicating a very modest increase in the use of proportionality measures for quarterly reporting.

A closer look at the NCAs where proportionality measures are most prevalent reveals the following:

  • France and Luxembourg remained the most frequent users of this measure, with their NCAs granting limitations and/or exemptions to 281 solo undertakings in 2025 Q1 (284 in 2024 Q1) and 189 in 2025 Q1 (188 in 2024 Q1) respectively. This represents a significant proportion of their markets in terms of number of undertakings, with 63.15% of undertakings in France and 71.05% in Luxembourg being covered.
  • Italy no longer used this measure in 2025 Q1.


Figure 3 - Number of solo undertakings with at least one limitation/exemption

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Quarterly reporting solo

Table 3


More than 27% of solo undertakings in the EEA continued to be granted authorisation to submit quarterly reporting information of reduced scope (i.e., limitation) or were exempted from quarterly reporting in case of reporting templates on an item-by-item basis (i.e., exemption). While this represents more than a quarter of the total number of undertakings, these entities account for only 4.73% of the market share for non-life business (measured by GWP) and 1.92% for life business (measured by TP).

A closer look at the changes in 2025 Q1 reveals the following:

  • Luxembourg stands out once again with the highest proportion of solo undertakings being granted a limitation and/or exemption from reporting (71.05%). This translates to a market share of 8.63% for non-life business and 0.14% for life business.
  • Malta and Norway granted limitations and/or exemptions to more than 50% of their solo undertakings, with Malta’s exemption rate increasing to 51.47% (from 32% in 2024 Q1) and Norway’s exemption rate rising to 55.93% in 2025 Q1 (from 55% in 2024 Q1).


Table 3 - Overview of limitations/exemptions - by key measures

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Quarterly reporting solo

Table 4


When looking at the type of templates in quarterly reporting for solo undertakings in 2025 Q1, it is evident that approaches across NCAs differ in terms of the specific templates that are exempted. Specifically:

  • Investment reporting templates (i.e., templates on collective investment undertakings, list of assets and open derivatives) continue to be the most frequently exempted templates in 2025 Q1.
  • Solo undertakings from Luxembourg, Malta, Portugal and Sweden that are granted a limitation and/or exemption from quarterly reporting are once more exempted from reporting all templates.
  • Liechtenstein and Norway continue to consistently not exempt the balance sheet.
  • Germany continues to exempt nearly all quarterly templates except the own funds template.


Table 4 - Overview of limitations/exemptions - by template

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Quarterly reporting solo

Figure 4


This figure provides a graphical representation of the data in Table 4, illustrating the change in the number of exempted solo undertakings between 2024 Q1 and 2025 Q1 by country and template. The change for a specific template can be selected from the drop-down menu on the right.


Figure 4 - Change in number of exempted undertakings between 2024 Q1 and 2025 Q1 by template and country

Note: Only countries that had at least one limitation and/or exemption granted during the reference period considered are shown.
Source: EIOPA Quarterly reporting solo

Limitations and/or exemptions at group level

Annual reporting


In 2024, the same two NCAs as in 2023 granted limitations and/or exemptions to annual reporting to 9 groups, up from 8 in 2023. This increase was driven by Germany granting one additional exemption.


Figure 5 - Number of groups with at least one limitation/exemption

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Annual reporting group

Quarterly reporting


In 2025 Q1, the number of limitations and/or exemptions to quarterly reporting granted rose to 21, compared to 19 in the corresponding quarter of 2024. This growth is explained by Malta, where the number of exempted groups grew by 3, from 8 to 11. In contrast, France exempted one group less than in 2024 Q1, while Germany maintained its quarterly reporting exemptions, with no changes to the exempted groups.


Figure 6 - Number of groups with at least one limitation/exemption

Note: Only countries that had at least one limitation and/or exemption granted during the reference period are shown.
Source: EIOPA Quarterly reporting group

Proportionality principle in reporting

In order to illustrate the implementation of proportionality in supervisory reporting, EIOPA has updated the example presented in previous reports. This updated example reaffirms the previous conclusions that proportionality requirements embedded in technical standards achieve their intended objectives.

However, it is noteworthy that the number of reported templates still does not fully account for the complexity of the business and the effort required to complete them. For instance, smaller undertakings with limited lines of business or solely domestic business often face a significantly lower level of complexity in certain templates compared to undertakings with broader business structures.

Annual reporting


On an annual basis, the largest 10% of undertakings continued to submit around 38 templates in 2024. In contrast, the smallest 10% submitted around 28 templates, a very minor reduction from 29 reported in 2023.


Figure 7 - Average number of templates provided by undertaking

Source: EIOPA Annual reporting solo

Quarterly reporting


On a quarterly basis, the reporting requirements for solo undertakings remained unchanged in 2025 Q1. Specifically, the largest 10% of solo undertakings continued to submit around 9 templates, while the smallest 10% submitted around 6 templates, with no change from 2024 Q1.


Figure 8 - Average number of templates provided by undertaking

Source: EIOPA Quarterly reporting solo

 

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