On 20 July 2026, the Central Bank of Ireland (Central Bank) launched Consultation Paper 171 (the Consultation).

The Consultation proposes various refinements to the Central Bank’s domestic actuarial regime (DAR) and its ‘Guidance for (Re)Insurance Undertakings on the Head of Actuarial Function Role and Peer Review’ (Guidance). The Central Bank intends to impose the updated DAR as a condition of authorisation for (re)insurers under the European Union (Insurance and Reinsurance) Regulations 2015, the Irish regulations implementing Solvency II (2015 Regulations).

 The Central Bank attributes the proposed refinements to developments, including enhanced Fitness and Probity (F&P) guidance for Heads of Actuarial Function (HoAFs) and the Central Bank’s integrated supervisory approach.

We discuss these amendments in this article, noting that some changes in the revised drafts of the DAR and Guidance are not explicitly described in the Consultation paper itself.

1. Proposed Changes to the DAR

Head of Actuarial Function Role

The requirement for (re)insurers to appoint a HoAF remains unchanged. However, the Central Bank’s proposes:

• removing DAR-specific requirements relating to the HoAF’s employment status and experience due to overlap with the F&P regime (however, the Central Bank will continue to expect the HoAF to be an employee in large and complex (re)insurers);
• permitting reinsurers to appoint separate HoAFs for life and non-life businesses (formalising an existing practice);
• removing the requirement for the HoAF to provide an opinion on the Own Risk and Solvency Assessment (ORSA), while continuing to expect actuarial input into the ORSA process;
• removing the requirement that the HoAF be a member of a recognised actuarial association; and
• requiring the HoAF to report directly to the Board or relevant subcommittee on actuarial matters.

Reserving Policy

The Central Bank proposes that the Reserving Policy should align with the wording of Article 267.2 of the Solvency II Delegated Regulation. The updated wording requires the Reserving Policy to include:

“… a description of the relevant roles and responsibilities, models, sources of information and controls involved within the process.”

 Exemptions

 The Central Bank proposes automatic exemptions from most DAR requirements for:

• non-life insurers that do not write certain classes of business; and
• life insurers with small with-profits funds.

To avail of an exemption, a (re)insurer must notify the Central Bank and confirm that it meets the relevant criteria. The criteria are articulated in greater detail than before. Exemptions will be permitted to apply on an ongoing basis rather than requiring annual renewal.

To support simplification and proportionality, the Central Bank proposes allowing (re)insurers that do not meet the exemption criteria to apply for specific DAR exemptions based on their nature, scale and complexity, although its basis for considering such applications is not made clear.

The Central Bank also details:

• the process for its ongoing monitoring of compliance with the criteria;
• the requirement for a (re)insurer to notify the Central Bank if it no longer complies with the criteria; and
• its power to withdraw an exemption from a (re)insurer in exceptional circumstances, where it has serious concerns about their risk profile.

 Peer Review

The Central Bank proposes the following changes for Peer Reviews:

• Peer Review reports to be submitted routinely to the Central Bank, while certain existing requirements will be moved from the DAR to Guidance, and the previous impact-based scope distinctions will be removed.
• Subsequent Peer Reviews conducted by the same Reviewing Actuary (RA) may have their scope limited on a targeted basis, subject to Board approval (examples of specific scope considerations are addressed in the Guidance), with the number of consecutive reviews an RA may perform remaining limited to three.
• Once the limit of three has been reached, (re)insurers may not recommission a previous RA or another actuary from the same firm until at least three peer reviews have been performed by an alternative provider(s).
• Reference to permission for lower-impact (re)insurers to use an RA from within their own group has been removed.

AOTPs and ARTPs

The Central Bank recommends only minor changes to the actuarial opinion on technical provisions (AOTP).

The Central Bank proposes extending the existing requirement for the HoAF to provide an opinion on compliance of the Technical Provisions (TPs) with Solvency II requirements by explicitly referencing EIOPA guidelines.

To remove ambiguity about whether Regulation 84(8) of the 2015 Regulations is a permission or a requirement, the Central Bank proposes updated drafting. The updated wording clarifies the circumstances in which the TPs must be prepared on a combined basis by replacing the term “permitted” with “required” in Section 2.2 2.b of the DAR.

The Central Bank also proposes a new requirement to include post-balance-sheet events in the AOTP, where applicable.

While the requirement for actuarial reports on technical provisions (ARTP) will remain, the Central Bank proposes moving detailed objectives into the Guidance and allowing greater flexibility in how HoAFs communicate TPs to the Board. (Re)insurers will be required to submit ARTPs to the Central Bank as a matter of course, not just on request.

Life-specific elements

The following changes to the role of the HoAF in life insurers are proposed:

• The responsibility for HoAFs in direct life insurers to monitor compliance with disclosure of information requirements will be removed.
• The requirement for a life insurance ARTP to include the HoAF’s interpretation of “Policyholders’ Reasonable Expectations” (PRE) and its consideration in setting TPs will be removed from the DAR. The term “PRE” does not appear in the revised DAR; instead, there is wording aligned more closely with General Principle 2.1 of the Consumer Protection Code 2012 (the 2012 Code):
  Consultation version of the DAR section 3.1:
  “1. The ARTPs shall include:
  The HoAF’s opinion of how the requirement for the undertaking to act honestly, fairly and professionally in the best interests of its customers, has been considered in establishing the TPs.”.
  The use of wording aligned to General Principle 2.1 of the 2012 Code is somewhat noteworthy, given that the 2012 Code has since been replaced. It is not immediately clear if this reflects an intentional policy choice.
• Exemptions from certain With-Profits business requirements will be automated for eligible life insurers.

Non-Life specific elements

The Central Bank proposes only minor changes to the wording, requiring Reserving Committees for High Impact non-life insurers, confirming that the requirement to maintain a Reserving Committee remains appropriate.

2. Revised Guidance

The Central Bank’s states that its expectations of the HoAF remain broadly the same, however, changes to the Guidance are proposed to:

• reflect the removal of the ORSA opinion requirement;
• clarify expectations regarding AOTPs and ARTPs;
• clarify expectations for Peer Reviews and Peer Review Reports; and
• remove expectations that HoAFs comment on the motivation for reinsurance arrangements or recommend alternative structures in the Opinion on Reinsurance Arrangements.

The Central Bank also proposes changes to the Opinion on the Adequacy of the Reinsurance Arrangements, including:

• introducing an explicit requirement for the HoAF to address the impact on the (re)insurer’s risk margin when considering the material implications of the reinsurance strategy on TPs; and
• expanding stress-testing expectations to include collateral value risk and its interaction with reinsurer default risk where material.

Consultation Next Steps

The Consultation is open for submissions until 20 October 2026. The Central Bank will then review all submissions and publish a Feedback Statement. The Central Bank has also sought input on how the Peer Review regime can be “future-proofed”, inviting respondents to consider whether any aspects of the framework may need to be adapted in light of technological developments and evolving approaches to conducting Peer Reviews.

Should you wish to discuss this topic, please contact Eoin Caulfield, Ian Murray, Niall Campbell or any member of the Insurance Department.

Contributed by: Adam Malone & Martha Ní Dhochartaigh