国際財務報告基準（International Financial Reporting Standard、IFRS）第17号の適用日が近づいており、多くの企業が各社のIFRS第17号プロジェクトを押し進めています。一方、まだ取り組み始めたばかりの企業もあるでしょう。本稿では、IFRS第17号の新たな損益計算書（P&L）およびバランスシートが、どのような様式になりそうか、また迅速な導入に向けて注目すべき主なポイントについてお伝えします。IFRS第17号は、まったく新しいコンセプト、結果を報告する新たな方法、そして多くのモデリングの課題をもたらします。これらについて、以下で詳しく論じます。
1. What will the new balance sheet and P&L look like?
IFRS 17 Statement of Financial Position (balance sheet)
Under IFRS 17 the liabilities for your insurance business comprise the Best Estimate of Liabilities (BEL), Risk Adjustment (RA) and the Contractual Service Margin (CSM). For companies reporting under Solvency II, the IFRS 17 BEL will most likely be similar to the Solvency II BEL, although with possible differences in assumptions (discussed in section 6 below). The RA is a concept similar to the Solvency II Risk Margin, though the calculation technique used may be different (this is discussed further in section 7 below). The CSM, however, is a completely new concept, which would not have been seen or used before. There may also be differences in asset valuations arising from the implementation of IFRS 9, and the impact of asset and liability valuation differences could result in a new level of IFRS equity.
Figure 1: IFRS 17 balance sheet
CSM key points
The CSM represents the profits not yet earned for each group of contracts (contracts are grouped by portfolio, profitability and cohort—see section 5 below for more details).
It is calculated at contract inception as the difference between the fulfilment cash flows and present value of premium, so that on day 1 the profit is zero. The future profits are then spread over the future lifetime of the contracts as the CSM is released through the P&L (the value of the CSM before it is released to P&L can change due to for example new contracts being added to the group, interest accretion and absorption of changes in fulfilment cash flows relating to future service).
The amount of CSM released to the P&L each period is determined based on the coverage units in the period. The coverage units are determined for each contract by considering the quantity of the benefits provided under a contract and its expected coverage period.
The CSM cannot be negative for gross of reinsurance business, meaning an insurer will have to recognise losses immediately in its P&L. In addition, a loss component will need to be established and tracked—the tracking of this will bring additional challenges.
The models or systems used to calculate the CSM can be complex, and therefore require rigorous testing and validation.
IFRS 17 Statement of Financial Performance (P&L and OCI)
The Statement of Financial Performance will include the new presentation of P&L and Other Comprehensive Income (OCI). Companies can make an accounting choice on whether to disaggregate the impact of market movements and include them in OCI instead of the P&L—this may reduce volatility in reported profit or loss and allows insurers to manage the volatility across P&L and OCI.
The new P&L will have a completely different format—there is nothing comparable in other reporting regimes (e.g., Solvency II). It will require input from multiple stakeholders (actuarial as well as finance teams), will require consistency between all sources (e.g., actual versus expected cash flows) and will need to ensure any approximations and adjustments used in the balance sheet also work for the P&L.
Figure 2 illustrates how changes in the value of the insurance contract liabilities flow to the CSM, P&L and OCI.
Figure 2: Changes in liabilities
An Analysis of Change (AoC) is used to determine these flows to the CSM, P&L and OCI. So for IFRS 17, the AoC is more than just a way of validating the balance sheet, it defines the reported profit in a reporting period. Therefore a robust and efficient process is required to produce the AoC.
The importance of the AoC means that the BEL model needs to produce meaningful cash flows over one year (or even shorter for interim reporting). This can expose model limitations that are appropriate in terms of discounted value (especially at low yields) but are not reliable in terms of cash flow timing. For example, assumptions regarding the payment of outstanding claims may be appropriate for calculating the BEL cash flows but may not be accurate enough to achieve meaningful actual versus expected comparisons.
In addition, any out-of-model adjustments need to explicitly consider the supporting cash flows and careful consideration is required when reflecting adjustments in the AoC (and ultimately the current year’s profit).
2. Key decisions needed for implementation
The key decisions and considerations needed prior to implementation are:
- What business is classified as “insurance business” and in scope of IFRS 17
- What measurement approach to use
- What data is needed
- What assumptions are needed
- What method to use for calculating the Risk Adjustment
- What transition approach to use
We discuss each of these in turn in the following sections.
3. What business is in scope?
IFRS 17 applies to insurance and reinsurance contracts issued, reinsurance contracts held and investment contracts with discretionary participation features.
An insurance contract is defined in IFRS 17 as “A contract under which one party (the issuer) accepts significant insurance risk from another party (the policyholder) by agreeing to compensate the policyholder if a specified uncertain future event (the insured event) adversely affects the policyholder.” Companies will need to consider all of their business and determine which contracts, if any, fall into this definition, and therefore are in scope for IFRS 17.
An insurance contract might contain components that would be within the scope of another standard if they were separate contracts. These components need to be identified.
- IFRS 9 should be applied to determine whether there is an embedded derivative to be separated and, if there is, how to account for that derivative.
- An investment component should be separated only if it is distinct. (Distinct investment components are not highly interrelated with the insurance component. Components are highly interrelated if it is not possible to measure one without considering the other, or if the policyholder is unable to benefit from one component unless the other is also present.) IFRS 17 applies to any non-distinct investment components.
- Any promises to transfer distinct goods and services should be separated and IFRS 15 should apply to them.
4. What measurement approach to use
There are three measurement approaches which can be used for valuing your insurance liabilities. The choice of approach depends on the type of insurance contracts being considered:
- The General Model is the default model for all insurance contracts. This is also known as the Building Block Approach—the liabilities are made up of the three building blocks: BEL, RA and CSM. For example, this approach should be used for long-term and whole life insurance protection business.
- The Variable Fee Approach is a modification of the General Model for direct participating contracts. An insurance contract is considered to be a direct participating contract when: the contractual terms specify that the policyholder participates in a share of a clearly identified pool of underlying items; the entity expects to pay the policyholder an amount equal to a substantial share of the fair value returns on the underlying items; and the entity expects a substantial proportion of any change in the amounts to be paid to the policyholder to vary with the change in the fair value of the underlying items. For example, this approach should generally be used for unit-linked insurance and with-profits contracts.
- The Premium Allocation Approach is a simplified approach for short-duration contracts with little variability (generally for coverage periods up to one year). For example, this approach should generally be used for general insurance contracts, short-term life contracts and certain group contracts.
5. What groups are needed for data?
Under IFRS 17, the CSM and hence profits are calculated at an aggregated ”group” level (unit of account). Contracts are required to be grouped in the following way:
- By portfolio: Contracts subject to similar risks should be managed together.
- By profitability:
- They should be split into onerous (non-profitable) and non-onerous (profitable) contracts.
- The group of non-onerous contracts will be split further into profitable with no significant risk of becoming onerous, and other profitable contracts.
- By issue year: Contracts issued more than one year apart cannot be grouped together.
This grouping will need to be tracked and maintained, which could require significant data and/or model developments. This level of granularity can also make it more difficult to analyse results.
6. What new assumptions are needed for the BEL?
A similar approach to the Solvency II BEL may be used to calculate the best estimate cash flows for IFRS 17, where the assumptions used are current best estimate. However, there may be some differences in the definition of the assumptions:
- For example, the IFRS 17 best estimate cash flows should only include expenses directly attributable to fulfilment of the portfolio of contracts. Expenses not attributable to the portfolio are treated separately and are outside the insurance result. Under Solvency II, expense assumptions are based on all expenses incurred in servicing the insurance obligations.
- Another example where there may be differences is contract boundaries, as the definition of contract boundaries for IFRS 17 is slightly different from the definition for Solvency II.
- Discount rates may also be different. Unlike Solvency II, there is no prescribed method for calculating the discount rate in IFRS 17. The discount rate should be set so that it is consistent with observable market prices of financial instruments comparable with the cash flows of the insurance liabilities. Companies will need to determine an appropriate discount rate to use—a “top-down” approach (starting with return on reference assets) or a “bottom-up” approach (starting with risk-free rates) may be used.
7. Methods for calculating Risk Adjustment
The RA for nonfinancial risk reflects the compensation an entity requires for bearing the uncertainty about the amount and timing of the cash flows that arises from nonfinancial risk as the entity fulfils insurance contracts. IFRS 17 does not specify a method or confidence level for calculating the RA. Each company must decide which risks are in scope and the confidence level, which should be based on the company’s own view of risk.
Some possible methods that can be used to calculate the RA include the value-at-risk, conditional tail expectation and cost of capital methods. The value-at-risk method will be familiar to companies that already adhere to a shock-based capital framework such as Solvency II. This is an approach similar to the Solvency Capital Requirement (SCR) calculations. However, in the Solvency II standard formula, the SCR is calibrated at a 99.5% confidence level over a one-year time horizon. Therefore, companies may need to recalibrate these shocks for a lower confidence level and multiyear time horizon under IFRS 17. Alternatively, companies may decide to use a cost of capital method to leverage the Solvency II Risk Margin calculations.
Confidence level equivalents will need to be disclosed if an alternative technique is used, which may be a challenge as it is rare for companies to determine the distribution of outcomes. This may need the use of updated actuarial models to achieve.
The choice of RA method will have an effect on how future profits will flow to the P&L—a lower or higher RA will lead to a higher or lower CSM. These impacts should be considered when choosing the method and confidence level to calculate RA.
The RA is released in the P&L each period as the risk exposure runs off.
8. What transition approach to use
Companies implementing IFRS 17 are required to disclose the impact on the balance sheet of transitioning to IFRS 17 in their first set of financial statements. The impact is calculated at the ”Transition Date,” which is “the beginning of the annual reporting period immediately preceding the date of initial application.” This is to enable the company to provide at least one year’s comparative information in its first set of accounts. Therefore, for a company applying IFRS 17 from 1 January 2023, the Transition Date is 1 January 2022.
The Full Retrospective Approach (FRA), i.e., an approach assuming that IFRS 17 had always applied, should be used unless it is impracticable to do so. This will require a full history to the date of transition for data and assumptions.
If the FRA is impracticable, companies can choose to either use the Modified Retrospective Approach (MRA) or the Fair Value Approach (FVA). The MRA allows for simplifications to the FRA to address data limitations, but it still has many practical challenges for implementation. For example, information on the actual historical cash flows from initial recognition are required—while using the actual historical cash flows does simplify things the data may not be readily available, particularly at the unit-of-account level (i.e., grouping by portfolio, profitability and annual cohort) The FVA may be simpler to apply than the MRA as it is a prospective calculation. This approach involves determining the CSM at the Transition Date as the difference between the fair value of the insurance contract at that date and the fulfilment cash flows measured at that date. However, the FVA can lead to a lower CSM. The practicalities, along with the resulting CSM, will need to be weighed up as a company decides on which approach to adopt.
Further details on the practical challenges with each of the transition approaches can be found in the following article: IFRS 17: Transition practical issues.
9. Conclusion
IFRS 17 will bring a lot of change—there are new ways of reporting results, completely new concepts and many modelling challenges. A lot of work is required to get ready for implementation and companies are likely to be busy over the coming months getting their models and systems ready for the implementation date of 1 January 2023.
To discuss how Milliman can help with your IFRS 17 project please contact your usual Milliman consultant or Andrew Kay or Gillian Tucker.
More information on Milliman insights, products and services related to IFRS 17 can be found at: https://www.milliman.com/en/insurance/ifrs-17