Regulatory Investment Insights – Investor Reporting (October 2026)

We are excited to launch our Regulatory Investment Insights newsletter series, focused on the most relevant developments in the investment industry.

Solvency II Update & Tripartite Template Version 8.0 (TPT 8.0)

(relevant for: EEA insurance investor)

Amended requirements apply from 30 January 2027

Relaxed requirements for long-term equities (LTE) eligibility (22% equity risk charge instead of currently ca. 30-49%)
- Relevant for listed and unlisted equities and funds (incl. ELTIFs and unlevered closed-ended AIFs).
- So far positive feedback from French and Belgian insurers, but unlikely to be applied in Germany, Austria or other EU member states.
- Our view: Little impact for asset managers since many major LPs are unlikely to use the amended LTE category in future.

Reduced spread risk factors for securitisations
- Significant reductions in spread risk charges for senior, non-STS, investment-grade (IG) securitisations.
- Smaller reductions for senior, non-STS, non-investment-grade securitisations and junior non-STS securitisations.
- Our view: Little impact for asset managers since insurers don’t tend to invest a lot into senior, non-STS, investment-grade (IG) securitisations.

Change of risk calculations for defaulted / forborne loans
- Defaulted / forborne loans to be treated in the counterparty default risk module instead of the spread risk module.
- Our view: Identifying and reporting defaulted / forborne loans essential for the correct SCR calculation.

Increased interest rate risk for loans and bonds
- Adjusted methodology likely to increase interest rate risk for volatility for insurance investors.
- Our view: Little impact for asset managers expected given that many insurers have been preparing for this update for a long time.

Sustainability risk plans and climate change scenario analysis
- Mandatory requirements for insurers, but the regulatory technical standard (RTS) not final yet.
- Our view: Depending on the final RTS, existing (e.g. via EET or BAI ESG) or additional ESG reporting might be required for Solvency II investors.

SOF & BAI Webinar on Solvency 2 Update and TPT 8.0

on 4 November 11:00 CEST (Agenda)

New version 8.0 is released and can be used from January 2027

(valuation dates Q3-Q4 26!)

From April 2027 TPT 8.0 is mandatory

New fields support the revised Solvency II regime (incl. long-term equity or legislative program eligibility).
Existing definitions, codifications and validation rules are changing for some fields.
Some datapoints classified N/A and not expected to be provided.
Issuer identification now possible with other external IDs such as VAT number in addition to LEI.

Non-EEA Insurance Regulations

(e.g. Switzerland, Asia)

Different non-EEA insurance regulations such as Swiss Solvency Test (SST), Hong Kong Risk-Based Capital regime (HKRBC), Korea Insurance Capital Standard (K-ICS) or Japanese Insurance Solvency Regulation (J-ICS / ESR) often similar to Solvency 2 requirements and require a look-through.

No reporting market standards such as TPT 8.0 for EEA insurers, therefore, fragmented investor-specific reporting required.
Due to comparable look-through requirements TPT can often be used as a data source for non-EEA regulations.

CSRD / ESRS / EU Taxonomy / BAI ESG

Template 3.0

ESRS 2.0 significantly simplified compared to ESRS 1.0 (70% less datapoints) and applicable for the FY 2026 optionally and from FY 2027 mandatory; however, GHG reporting incl. PCAF scores unchanged under ESRS 2.0.
EU Taxonomy: Amended Art. 8 Taxonomy DA Templates mandatory for FY 2026 for the first time for many insurers.

BAI ESG Template 3.0 updated to reflect Taxonomy changes and released: Download Here
BAI & SOF & ALH Group & Barmenia Gothaer AM webinar on BAI ESG Template 3.0: Recording | Slides

SFDR 2.0 / European ESG Template 1.1.3

(EET 1.1.3)

SFDR 2.0: Level 1 in negotiation between EU Council, Parliament and Commission. Earliest entry into force: 2029.
Key points under discussion: removal or amendment of the PAI statement, introduction of sustainability labels instead of Art. 8/9 disclosure requirements as well as minimum PAIs on the product level, exemption for AIF marketed to professional investors, removal of “sustainable investment” definition.

SOF PAI EET Study for Private Markets 2025 released and demonstrates that ca. 2/3 private markets GPs keep providing EETs and PAIs despite ESG simplifications. Further insights: 2025 SOF EET/PAI Research.

Our view: Asset managers will have to continue reporting PAIs via EETs to regulated EEA investors regardless of SFDR 2.0 developments. PAIs became an important business input for investors that is used for internal processes and far beyond pure disclosure requirements.

ILPA Fund Performance and Fee Reporting

(relevant for: EEA and non-EEA insurers, pension fund, fund of fund investor,

(third party) AIFM)

ILPA Reporting Template v2.0
- ILPA Reporting Template v2.0 replaced the 2016 template (v1.1) from Q1 2026
- More standardised and rigid structure: line items may no longer be repurposed, reordered or supplemented, and all fields must remain intact even where unused
- Recommended for funds launched from 1 January 2026 and funds still in their investment period during Q1 2026
- Older funds may continue using the 2016 template
ILPA Performance Template
- First standardised ILPA Performance Template introduced in two versions: Granular Methodology and Gross Up Methodology
- Standardises performance reporting including IRR, TVPI and MOIC
- Applicable to funds launched from 1 January 2026, with the first reporting expected in Q1 2027

We're pleased to announce the launch of the new RiskConcile Group website.

To find out more about our services, visit riskconcilegroup.com or email info@riskconcilegroup.com