European Commissioner Michael Barnier ponders delaying the start date of S-II by two months, to Dec. 31, 2012, to synch the start up to most companies’ fiscal years. Sounds trivial, but as InsuranceERM.com explains:
Barnier’s comments come on the back of weeks of speculation that the date would be pushed back to, effectively, 2013 [see IERM, 17 March, Regulation/supervision, “EC looking at 2013 Solvency II start date“]. While such a change would postpone the legislation by just two months, in practice it gives insures an extra 12 months to comply. A meeting to discuss the issue is unofficially expected this week.
The reason a two-month delay equals a 12-month postponement isn’t explained, though in my experience, implementation of accounting/financial changes requires all measures to be presented on a year-to-date basis, compared with 12 months prior. An October 2012 implementation would require YTD results starting 1/1/2012 and as-if comparisons to 2011. A December 31, 2012, reuire YTD starting 1/1/2013 (one year later) with comparisons of 2013 results to 2012. (This is true only for companies whose fiscal years begin 1/1. But that’s just about everybody in insurance.)
Note that decisions need to be wrapped up fairly soon, as the data gathering under current rules would begin eight months from now, 1/1/2011.