Solvency UK vs Solvency II: what changed for reporting after the PRA reforms

Solvency UK is the PRA’s name for the prudential regime that has applied to UK insurers since 31 December 2024. Most of it still looks like Solvency II. The reporting side does not: a third of the templates are gone, the survivors carry new codes, the taxonomy is the Bank of England’s own and the portal is BEEDS. This article is for the team that delivers the return. It covers how the regime got here, what each reform did, which templates were deleted, renamed or added, which taxonomy version applies to which reference date, what a group with entities on both sides of the Channel files, and where these changes sit in BOE Tool, our Bank of England XBRL reporting software. For the EU baseline, the Solvency II QRT list covers the EIOPA package template by template.

How Solvency II became Solvency UK

Solvency II applied in the UK from 1 January 2016. At Brexit the directive, the delegated regulation and the implementing technical standards were copied into UK law as retained EU law, later renamed assimilated law, and the PRA supervised against them with minor edits. The templates still came from Commission Implementing Regulations 2015/2450 and 2015/2452, so a UK QRT was, cell for cell, an EIOPA QRT.

The Financial Services and Markets Act 2023, which received Royal Assent on 29 June 2023, changed the mechanism: section 1 and Schedule 1 revoke the assimilated financial services law so that HM Treasury and the regulators can replace it with domestic rules. HM Treasury used that power for insurance on 31 December 2024, revoking Delegated Regulation (EU) 2015/35, the Solvency 2 Regulations 2015 and the Commission Implementing Regulations, the two reporting ITSs included. PS15/24, published on 15 November 2024, is the PRA’s restatement. It moved the rules, templates and instructions into the PRA Rulebook and PRA policy material from the same date, and its Appendix 8 maps each revoked provision to its new home.

For reporting the rule is simple. Solvency UK applies to every quarterly and annual return with a reference date of 31 December 2024 or later. Earlier reference dates, late resubmissions included, stay on the old Solvency II taxonomy.

The main reform strands

The reforms landed in three waves, each with its own policy statement.

The risk margin went first. The Insurance and Reinsurance Undertakings (Prudential Requirements) (Risk Margin) Regulations 2023, made on 7 December 2023 and in force from 31 December 2023, cut the cost of capital rate from 6 percent to 4 percent and introduced a risk tapering factor of 0.9 for life obligations and 1.0 for non-life, with a floor of 0.25.

The matching adjustment came second. PS10/24, published on 6 June 2024 and in force from 30 June 2024, widened the eligible assets, added a senior manager attestation on the MA claimed and introduced the Matching Adjustment Asset and Liability Information Return, the MALIR, from 31 December 2024 with a deadline of 130 business days after the financial year end.

The third wave is the one a reporting team feels, and it arrived on two consecutive days. PS2/24, published on 28 February 2024, raised the thresholds at which Solvency UK applies to £25 million of annual gross written premium and £50 million of technical provisions, up from the EUR 5 million and EUR 25 million in the directive, and confirmed that the Regular Supervisory Report was no longer required from 31 December 2023. PS3/24, published on 29 February 2024, is the reporting and disclosure reform itself. Both took effect on 31 December 2024, and PS15/24 made the near-final rules final.

What PS3/24 did to the template package

PS3/24 closed a review that began with PS29/21 in December 2021, when the PRA removed the summary asset and own funds variation templates, dropped financial stability reporting for larger firms and widened the quarterly reporting waiver. Phase 2 went further. Counting each template once per firm type and frequency, the policy statement puts the net effect at 107 templates removed, one third of what firms previously had to file.

The deletions and additions are in the table below. Two proposed new templates, S.05.04 on activity by country and S.14.02 on non-life product obligations, were withdrawn after consultation.

The bigger change for a reporting system is the renumbering. The S, SR, NS and NSR prefixes became IR, or IRR for ring-fenced fund reporting; SF, IMO, SPV and MRS did not change. NS.00 was merged into the content of submission template, so there is one IR.01.01 rather than an EIOPA header plus a national one. Two proposals were reversed after consultation: the quarterly technical provisions templates stayed quarterly rather than moving to semi-annual, and the Quarterly Model Change return QMC.01 kept its eleven week deadline instead of the proposed five.

The table lists the changes that touch the routine return, with codes as the PRA prints them. Each IR code links to the PRA’s PS15/24 instructions in our library.

Disclosure moved with it. The public disclosure templates sit in the Bank of England taxonomy under a DIS framework with solo and group entry points, but the PRA’s reporting Q&A is explicit that no disclosure return is submitted through BEEDS. The templates show what the SFCR must contain; publishing it remains the firm’s job.

Bank of England Insurance Taxonomy versions

Under Solvency UK a firm files on the Bank of England Insurance Taxonomy, which the Bank has published since 2018 for national specific templates and which became the single taxonomy for everything from version 2.0.0. Four versions matter for open reference dates.

Version 2.0.1, published on 10 October 2024, was the first live Solvency UK taxonomy and applies to reference dates from 31 December 2024. Version 2.0.2, published on 2 October 2025, replaced it with validation fixes and data point model changes and is effective from 1 January 2026 for reference dates on or after 31 December 2025. A 31 December 2025 annual return therefore had to be filed on 2.0.2.

Version 2.1.0, published on 16 December 2025, implements PS15/25 on liquidity reporting. It adds a liquidity framework with four entry points: CFL and CFS for the long and short form cash flow mismatch templates, COL for committed liquidity facilities and LMR for liquidity market risk sensitivities. These apply to reference dates on or after 30 September 2026. The other frameworks are unchanged from 2.0.2 and backwards compatible with it, so a firm outside the liquidity scope does not have to move.

Version 2.2.0, published on 3 September 2026, implements PS18/26, which the PRA published on 29 July 2026. It amends the DIS, IR, IMO and MAL frameworks and applies to reference dates on or after 31 December 2026, which means the year-end 2026 return. The changes are targeted: new columns and rows in IR.05.04, clarified instructions for IR.16.01, new own funds terminology in IR.23.01 to IR.23.04, and the MALIR templates MA.01.01 and MA.02.01 moving from Excel to XBRL. It also opens the transition to NACE 2.1 activity codes in IR.06.02, IR.05.07 and IR.11.01, optional for 31 December 2026 and mandatory from 1 January 2027.

How submission works

Every Solvency UK return goes through BEEDS, the Bank of England Electronic Data Submission portal. The firm’s CEO nominates a principal user, the Bank sets up the firm’s schedule of returns, and the reporting team uploads one XBRL instance per entry point. BEEDS runs the taxonomy validations on upload and accepts only a file that passes. The filing rules it enforces are in the Bank’s XBRL filing manual for the Insurance Taxonomy, version 1.0.1 of 30 May 2024.

Deadlines are counted in business days from the reference date rather than the calendar weeks of the directive. Solo firms and branches have 30 business days for a quarterly return and 70 for an annual one; groups have 55 and 100. The PRA publishes the resulting dates for a December year end, so the 31 December 2025 annual return was due on 13 April 2026 for solo entities and 27 May 2026 for groups.

Two practical points from the PRA’s reporting Q&A. The Bank’s taxonomy and EIOPA’s are not interchangeable, and BEEDS returns a fatal error if an instance references any other taxonomy. And validation errors come back 100 lines at a time, so a file with a few hundred blocking errors takes several rounds unless it was validated locally first. For the mechanics of an XBRL instance from scratch, see what XBRL is in insurance reporting.

Groups with EU and UK entities

A group with a UK insurer and one or more EU insurers reports under two regimes with two taxonomies, and the split runs along the legal entity line.

Where the head of the group is in the EU, the UK subsidiary files its solo return to the PRA on the IR templates and the Bank of England taxonomy, and it does not file an EIOPA solo return. The parent files the group return to its EU group supervisor on the EIOPA taxonomy, and that return consolidates the UK entity with the rest of the group. The same UK balance sheet therefore ends up in IR.02.01 for the PRA and inside the group S.02.01 for EIOPA, with different codes and validations and, since the risk margin reform, a different technical provisions figure.

Where the head of the group is in the UK, the direction reverses: the PRA receives the group return on the IR templates, and each EU subsidiary files solo to its national supervisor on the EIOPA templates and the EIOPA taxonomy version current for that reference date. The group list of assets, IR.06.02, has to carry the EU entities’ assets coded the way the PRA instructions demand, which from 2027 means NACE 2.1, while the EU solo templates follow EIOPA’s own NACE timetable.

In both cases the work is a reconciliation: solo figures produced under one rule set have to be traced into a group return produced under the other every quarter, and a UK code and an EU code with the same number no longer always mean the same cell.

Where this lands in the software

BOE Tool is built on the Bank of England Insurance Taxonomy, so the IR templates and the DIS entry points are its native template set rather than a UK add-on to an EIOPA package. Data comes in from databases, Excel and CSV files through import definitions that are set up once and reused quarter after quarter, year after year, and several sources can feed several templates. The tool runs the Bank’s validation rules before anything reaches BEEDS and resolves the recurring errors automatically, so the portal’s 100 line error batches become the exception. SmartData, embedded in the tool, holds reference data on more than 13 million securities traded on European and British exchanges plus Global Legal Entity Identifier Foundation data, so IR.06.02 and the other asset templates can be completed with LEI codes and ultimate parents. A free, noncommittal account is available for the test and transition period.