The challenge
Small mandates, the same few experts
The amended Solvency II regime is not a rewrite, but it touches a lot: liquidity and sustainability risk plans, a two-part SFCR, a new reporting taxonomy. The Insurance Recovery and Resolution Directive adds recovery plans that have to be produced once and then kept current. Each item looks feasible on its own.
Together, they land on a small group of actuarial, finance, risk and reporting people who are also closing the year and running the business. That is where plans quietly break. The same experts end up booked several times in the same quarter, and nobody notices until a deliverable slips.
Meanwhile, IFRS 17 left many finance teams running on workarounds, and the change backlog keeps growing. Policy administration and claims programs pull on the same architects, product experts and testers. The useful question is no longer “are we compliant?” but “what are we not doing because of this?” If nobody can answer in the meeting, it is being decided by default.