EIOPA's IRRD guidelines and technical standards of 2026: the 15 instruments and what to prepare before 30 January 2027

Directive (EU) 2025/1 left most of the detail to EIOPA: nineteen technical standards and guidelines that say what a pre-emptive recovery plan contains, who has to write one, which templates go to the resolution authority and how a failing insurer is valued. By 8 July 2026 EIOPA had delivered fifteen of them. This post lists every instrument published in 2026 with its date, type and status, then goes one level down into the three that change the reporting workload most: the RTS on the content of pre-emptive recovery plans, the RTS on selection criteria and market share together with the guidelines on simplified obligations, and the ITS on resolution reporting. It ends with where Commission adoption stands against the 30 January 2027 application date and a checklist for the two quarters left. The data side of all of this is what IRRD Tool is built for. If you need the directive itself first, start with IRRD explained.

Where the mandates come from

The full text is in our regulation library as Directive (EU) 2025/1. Article 5(12) asks EIOPA for draft regulatory technical standards on the selection criteria of Article 5(2), on the market share methods and on the content of the pre-emptive recovery plan, to be submitted to the Commission by 29 July 2026. Article 5(11) asks for guidelines on the range of stress scenarios, written with the ESRB, and on the indicators, by 29 January 2027. Article 4(2) asks for guidelines on the criteria for simplified obligations by 29 July 2027.

On the resolution side, Articles 9(8) and 10(6) ask for RTS on the contents of resolution plans and group resolution plans, Article 12(3) for implementing technical standards on the forms and templates undertakings send to resolution authorities, and Article 70(7) for RTS on resolution colleges, all by 29 July 2026. Guidelines on critical functions (Article 9(9)) and on resolvability (Article 13(5)) are due by 29 January 2027, guidelines on removing impediments (Article 15(8)) by 29 July 2027. The valuation mandates in Articles 24(6), 25(4), 40(4), 52(5) and 56(4) all run to 29 July 2027, so EIOPA is a year ahead of the directive on most of them.

Every instrument EIOPA published in 2026

The table follows EIOPA’s three press releases. “Submitted” means the final report with the draft text has gone to the Commission and the Commission has not yet adopted it.

Fifteen delivered, four in consultation, nineteen in total.

The RTS on the content of pre-emptive recovery plans

This is the instrument most reporting teams will live with. Article 5(6) of the directive lists the elements; the draft RTS (EIOPA-BoS-25-711, consulted between 29 April and 31 July 2025, eleven responses) turns each into an article of a future Commission delegated regulation.

Article 1 saves work: where information has already been submitted to the supervisor, the supervisor may accept a cross reference instead of a copy. EIOPA added this after consultation, along with dropping the requirement to name the individuals who update the plan. Article 2 is the summary. Article 3 is the description of the undertaking or group: business model and main jurisdictions, core business lines mapped to legal entities, the legal and financial structure with intra-group exposures and reinsurance, and material connections outside the group. For groups, only entities meeting one of six conditions (substantial profit or funding, key commercial activities, centralised functions, substantial risk, cannot be disposed of safely, significant for a Member State) get the detailed treatment.

Article 4 is the framework of indicators: the quantitative and qualitative triggers, forward looking where possible, set at the level of the ultimate parent and of each subsidiary, with a rationale for each threshold and enough lead time for the management body to evaluate, decide and act. Article 5 is governance: who prepares each section, the approval date, the update cycle of at least every two years, the events that force an earlier update, and the escalation procedure when a trigger is hit.

Article 6 is the largest. The plan needs a range of remedial actions under severe stress: recapitalisation, liquidity, risk reduction or SCR relief including divestments, and voluntary restructuring of liabilities. For each action the plan states the impact on solvency, liquidity and capital composition, the impact on policyholders and counterparties, the valuation assumptions, a viability analysis with impediments and their solutions, an expected timeframe, and whether two actions could run in the same period. Article 6(5) asks how the management information systems will make the data for these actions available under stress. Article 7 is the communication strategy and Article 8 the Article 138(2) recovery plan from any SCR breach in the last ten years.

The quantitative inputs are all Solvency II outputs. The risk reduction actions in particular need the SCR by module; how the SCR standard formula is calculated walks through those modules.

Who has to write one: the market share RTS and the simplified obligations guidelines

The second February RTS (EIOPA-BoS-25-712) tells supervisors how to pick undertakings. Articles 1 to 7 take the seven criteria of Article 5(2) in turn. Size is gross technical provisions for life and gross written premiums for non-life. Business model looks at profitability, concentration in lines of business and products, investment strategy and distribution. Risk profile uses the SCR, the quality and coverage of own funds, module exposures against the market, risk appetite and liquidity risk, read from the ORSA and the liquidity risk management plan. Cross-border activity is the share of premiums written under freedom of establishment or freedom of services. Article 8 says the criteria are applied in combination, using Solvency II supervisory reporting.

Articles 9 to 11 are the calculation. The life market is the sum of gross technical provisions, including unit-linked business, of all undertakings authorised in the Member State; the non-life market is the sum of gross written premiums. Small and non-complex undertakings sit in the denominator. Cross-border business counts in the home Member State. A composite is assessed once and its life and non-life parts count toward each 60 percent target separately. A subsidiary covered by a group plan drawn up elsewhere does not need an individual plan.

The guidelines on simplified obligations, published on 8 July 2026 and applying from 30 January 2027, work on the other side of the line. Article 4(1) of the directive allows reduced content, a lower update frequency and a later first plan where a failure would not have a significant negative effect on markets, other undertakings, policyholders or the wider economy. The guidelines list the elements an authority checks under each criterion and say simplified obligations are less likely for undertakings with significant cross-border activity under Article 152aa of Solvency II or a high impact rating under the supervisory review process guidelines. If one criterion alone shows a significant effect, full obligations apply without further assessment. The guidelines also allow authorities to reuse the market share assessment as input, so one data set serves both decisions.

The ITS on resolution reporting

The April ITS (EIOPA-BoS-26-040) implements Article 12(3). It applies only to undertakings and ultimate parents selected for resolution planning under Articles 9 or 10, the 40 percent set, and only once the resolution authority has told you.

Article 1 points to the templates in Annex I and the instructions in Annex II, published separately as EIOPA-BoS-26-042 and 26-043. The codes run from IR 01.01 to IR 09.02. Solo undertakings skip IR 04.01, IR 07.04 and IR 07.05. Groups report IR 03.01 and IR 03.02, liabilities broken down by the Article 35 categories that matter for the write-down and conversion tool, on a consolidated and on an entity basis, IR 04.01 for financial interconnections between group entities, IR 07 for critical functions and core business lines per entity and per Member State, IR 08 for relevant services including reinsurance, and IR 09 for financial market infrastructures whose disruption would stop a critical function.

Article 3 is the calendar. Reporting is at least every two years, within 18 weeks of the financial year end for solo undertakings and 24 weeks for groups. For a first reference date at a financial year end between 30 January 2027 and 31 December 2027 the deadlines stretch to 20 and 26 weeks. Article 5 fixes the format on Implementing Regulation (EU) 2023/894, the Solvency II reporting regulation: monetary values in units without decimals, percentages as per unit with four decimals. Article 7 obliges the resolution authority to check with the supervisor before asking for anything already in Solvency II reporting. The IR templates therefore sit next to the Solvency II QRT set and are meant to be built from the same source data. EIOPA kept the regular submissions on a going concern basis; gone concern figures for the write-down tool are requested ad hoc.

Scenarios and indicators

The scenario guidelines require a range that covers a system-wide event, an idiosyncratic event and a combination of the two, each marked as slow-moving or fast-moving. ORSA scenarios can be the starting point but may need to be broader or more severe. Each scenario must quantify the effect on solvency, liquidity and profitability, and the events must be severe enough that capital requirements would be breached without remedial action. Guideline 4 lists the idiosyncratic candidates: underwriting losses or under-reserving, concentrated asset price falls, liquidity outflows such as margin calls and lapse spikes, counterparty failure, operational loss including cyber attack, and legal risk.

The indicator guidelines follow Article 5(8) with seven categories: capital, liquidity, asset quality, profitability, market conditions, macroeconomic conditions and operational events. An undertaking may drop categories that do not fit its business, but the set must include an SCR breach, and group plans need indicators for the group SCR and for every subsidiary in scope. Calibration should give warning before the supervisory measures of Article 136a of Solvency II, the early warning article added by Directive (EU) 2025/2. The suggested profitability set reads like a reserving dashboard: loss ratio, combined ratio, changes in key reserving assumptions, expense ratio and premium growth by line.

Commission adoption and the gap to 30 January 2027

Two clocks run here. The guidelines are EIOPA’s own instruments under Article 16 of Regulation (EU) No 1094/2010. National authorities confirm within two months of the translated versions whether they comply, and the July 2026 texts apply from 30 January 2027 regardless. Draft RTS and ITS are different: the final reports say the Commission will decide on adoption under Articles 10 and 15 of the EIOPA Regulation. An RTS becomes a Commission delegated regulation, which the Parliament and the Council can object to during a scrutiny period before publication; an ITS becomes an implementing regulation without that period. Each enters into force on the twentieth day after publication in the Official Journal.

At the time of writing EIOPA’s IRRD page lists the February and April drafts as submitted, not adopted. The directive’s own deadline for those submissions was 29 July 2026 and Member States apply their national law from 30 January 2027, so there was never much slack. In practice the national transposition law and the supervisor’s selection letter will set your first deadline while the exact wording of the RTS may still be moving. The drafts are the best available statement of what will be required, and the guidelines are already fixed.

Checklist for Q4 2026 and Q1 2027

October to December 2026. Ask your supervisor whether you are in the pre-emptive recovery planning set and the resolution authority whether you are in the resolution planning set; if you have not heard, estimate your position from the market share RTS with published market figures. Ask about simplified obligations at the same time. Map the eight RTS articles to documents you already hold: ORSA, capital management policy, liquidity risk management plan, group structure, any Article 138 recovery plan since 2016. Build the indicator table from figures you already report, set thresholds and record who is told when one is hit. Draft one scenario per category, reusing the ORSA reverse stress test where it meets the severity condition. If you hold financial contracts under third-country law, read the stay powers RTS with legal. Respond to the valuation consultation by 20 October 2026 if resolution valuation matters to you.

January to March 2027. Quantify each remedial action under the three scenarios and check compatibility between actions. If you are in the resolution set, agree the first IR reference date with the authority and map source fields to IR 01 to IR 09 in the 2023/894 formats. Put the plan through the management body before submission and diarise the two-year update and the nine-month supervisory review. Watch the Official Journal for the delegated regulations and diff the adopted text against the February drafts.

Where this lands in the software

IRRD Tool covers the data path rather than the narrative. It pulls the figures the RTS and the guidelines ask for from several sources at once, whether a database, Excel files or CSV extracts, and feeds them into multiple templates, so the indicator table, the remedial action quantification and the IR resolution reporting templates come from one set of defined transformations instead of three hand-built extracts. Those transformations are defined once and reused quarter after quarter, which is what an indicator framework monitored between the two-year plan updates needs. Because the same integration already populates the Solvency II reporting templates, the SCR, own funds, technical provisions and liquidity figures in the plan reconcile to the quarterly submission. The scenarios, thresholds and remedial actions stay with the risk and actuarial team.