Publication duties

Solvency II SFCR publication page

EU insurers and reinsurers must publish a solvency and financial condition report each year. Article 301 of Delegated Regulation (EU) 2015/35 puts it on the firm's own website, if it has one. It must stay there for five years. The current deadline is 14 weeks after financial year end. This becomes 18 weeks from 30 January 2027.

A reference note from Dan Malone, who builds software products.

The rule

“The solvency and financial condition report shall consist of two parts, clearly identified and disclosed jointly. The first part shall consist of information specifically targeted at policy holders and beneficiaries”

Directive (EU) 2025/2, amending Article 51 of Directive 2009/138/EC (Solvency II)Checked 2026-09-01

The facts

What the duty actually says

Typed fields for Solvency II SFCR publication page
Field	Value
Who must publish	Every EU insurance and reinsurance undertaking must make an annual solvency and financial condition report publicly available. Source
Current solo deadline	14 weeks after the undertaking's financial year end, under Article 300(1) of Delegated Regulation (EU) 2015/35. Source
Current group deadline	20 weeks after the group financial year end. Article 362 of Delegated Regulation (EU) 2015/35 extends the Article 300 deadlines by 6 weeks. Source
Where it must go	On the undertaking's own website, where the undertaking owns and maintains one. A trade association website is the fallback (Article 301(1) and (2)). Source
How long it stays up	The report must remain available on that website for at least 5 years after the disclosure date (Article 301(3)). Source
Copies on request	With no website, send an electronic copy within 10 working days, for 5 years. Anyone can request a printed copy within 2 years; send it within 20 working days (Article 301(4) and (5)). Source
Board approval first	The board of directors must approve the report. Publication happens only after that approval (Regulation 57(2), S.I. No. 485 of 2015). Source
Fixed structure	The report follows the structure in Annex XX of Delegated Regulation (EU) 2015/35. It opens with a summary that policy holders can understand (Articles 290 and 292). Source
Copy to the supervisor	Each published report, and each updated version, goes to the supervisory authority in electronic form (Articles 300(2) and 301(6)). Source
Updates after a major development	An MCR or SCR breach becomes a major development. This happens when the Bank gets no realistic finance scheme or recovery plan in time. The undertaking must then disclose immediately. An unresolved MCR breach must be disclosed again after 3 months (Regulation 56). Source
Change from 30 January 2027	The report splits into two parts, disclosed jointly. The solo deadline moves to 18 weeks and the group deadline to 24 weeks. Source
Audit from 30 January 2027	A statutory auditor must audit the balance sheet in the report. Small and non-complex undertakings and captives are exempt (new Article 51a). Source

The artefact

What the published page has to contain

A clear, concise summary that policy holders and beneficiaries can understand
A description of the business and its performance over the reporting period
A description of the system of governance and an assessment of its adequacy
Risk exposure, concentration, mitigation and sensitivity, set out for each risk category
Valuation bases and methods, shown separately for assets, technical provisions and other liabilities
Own funds structure, amount and quality, with an analysis of changes since the last report
The Solvency Capital Requirement and Minimum Capital Requirement amounts, with any capital add-on shown separately
A statement of any MCR breach, or significant SCR breach, during the period, with origin, effect and remedies
A statement naming any information withheld under a supervisory waiver, and the reasons
The quantitative reporting templates required by the public disclosure implementing standards
The section order set out in Annex XX of Delegated Regulation (EU) 2015/35
From 30 January 2027: both parts, clearly identified and disclosed jointly

What goes wrong

How this is usually got wrong

/01
The report goes live after the 14-week date, so the public disclosure is late on a fixed statutory clock.
/02
The PDF sits behind a login, an investor-relations gate or a cookie wall, so the public cannot read it.
/03
A site redesign deletes older years and breaks the 5-year availability rule in Article 301(3).
/04
The website version and the version sent to the supervisor differ after a late correction.
/05
A major development happens and no updated report is published, so the live page is stale and wrong.
/06
The page gives no route to request an electronic or printed copy, so the Article 301(4) and (5) duties fail.
/07
The file is a scanned image, so screen readers and site search cannot read it.
/08
Only the newest report is linked; earlier years return 404 while still inside the 5-year window.
/09
Group and solo reports use different year-end dates and sit on one page without labels. Readers then compare the wrong numbers.
/10
From 2027: the two parts are published as separate files on separate dates, not disclosed jointly.

Who supplies this

Where the source material lives

Workiva
Reporting platform used to draft and control the SFCR narrative and the quantitative templates. It keeps version history and an audit trail.
https://www.workiva.com/en-au/solutions/solvency-ii-software
Wolters Kluwer CCH Tagetik
Solvency II reporting suite covering QRT calculation, SFCR and RSR production, and supervisory submission files.
https://www.wolterskluwer.com/en/solutions/cch-tagetik/solvency-ii
ARKK
Regulatory reporting and digital tagging service that prepares Solvency II submission and disclosure files for insurers.
https://www.arkk.com/solvency-ii
Milliman
Actuarial consultancy that works on SFCR content, technical provisions and readiness for the 2027 Solvency II changes.
https://www.milliman.com

Every note in publication duties

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Sources

Last checked 2026-09-01 · Published 2026-09-01

This page is reference material, not legal advice. Your advisor owns what applies to you.

Solvency II SFCR publication page

A reference note from Dan Malone, who builds software products.

What the duty actually says

Typed fields for Solvency II SFCR publication page
Field	Value
Who must publish	Every EU insurance and reinsurance undertaking must make an annual solvency and financial condition report publicly available. Source
Current solo deadline	14 weeks after the undertaking's financial year end, under Article 300(1) of Delegated Regulation (EU) 2015/35. Source
Current group deadline	20 weeks after the group financial year end. Article 362 of Delegated Regulation (EU) 2015/35 extends the Article 300 deadlines by 6 weeks. Source
Where it must go	On the undertaking's own website, where the undertaking owns and maintains one. A trade association website is the fallback (Article 301(1) and (2)). Source
How long it stays up	The report must remain available on that website for at least 5 years after the disclosure date (Article 301(3)). Source
Copies on request	With no website, send an electronic copy within 10 working days, for 5 years. Anyone can request a printed copy within 2 years; send it within 20 working days (Article 301(4) and (5)). Source
Board approval first	The board of directors must approve the report. Publication happens only after that approval (Regulation 57(2), S.I. No. 485 of 2015). Source
Fixed structure	The report follows the structure in Annex XX of Delegated Regulation (EU) 2015/35. It opens with a summary that policy holders can understand (Articles 290 and 292). Source
Copy to the supervisor	Each published report, and each updated version, goes to the supervisory authority in electronic form (Articles 300(2) and 301(6)). Source
Updates after a major development	An MCR or SCR breach becomes a major development. This happens when the Bank gets no realistic finance scheme or recovery plan in time. The undertaking must then disclose immediately. An unresolved MCR breach must be disclosed again after 3 months (Regulation 56). Source
Change from 30 January 2027	The report splits into two parts, disclosed jointly. The solo deadline moves to 18 weeks and the group deadline to 24 weeks. Source
Audit from 30 January 2027	A statutory auditor must audit the balance sheet in the report. Small and non-complex undertakings and captives are exempt (new Article 51a). Source

What the published page has to contain

A clear, concise summary that policy holders and beneficiaries can understand

A description of the business and its performance over the reporting period

A description of the system of governance and an assessment of its adequacy

Risk exposure, concentration, mitigation and sensitivity, set out for each risk category

Valuation bases and methods, shown separately for assets, technical provisions and other liabilities

Own funds structure, amount and quality, with an analysis of changes since the last report

The Solvency Capital Requirement and Minimum Capital Requirement amounts, with any capital add-on shown separately

A statement of any MCR breach, or significant SCR breach, during the period, with origin, effect and remedies

A statement naming any information withheld under a supervisory waiver, and the reasons

The quantitative reporting templates required by the public disclosure implementing standards

The section order set out in Annex XX of Delegated Regulation (EU) 2015/35

From 30 January 2027: both parts, clearly identified and disclosed jointly

How this is usually got wrong

/01

The report goes live after the 14-week date, so the public disclosure is late on a fixed statutory clock.

/02

The PDF sits behind a login, an investor-relations gate or a cookie wall, so the public cannot read it.

/03

A site redesign deletes older years and breaks the 5-year availability rule in Article 301(3).

/04

The website version and the version sent to the supervisor differ after a late correction.

/05

A major development happens and no updated report is published, so the live page is stale and wrong.

/06

The page gives no route to request an electronic or printed copy, so the Article 301(4) and (5) duties fail.

/07

The file is a scanned image, so screen readers and site search cannot read it.

/08

Only the newest report is linked; earlier years return 404 while still inside the 5-year window.

/09

Group and solo reports use different year-end dates and sit on one page without labels. Readers then compare the wrong numbers.

/10

From 2027: the two parts are published as separate files on separate dates, not disclosed jointly.

Where the source material lives

Workiva

Reporting platform used to draft and control the SFCR narrative and the quantitative templates. It keeps version history and an audit trail.

https://www.workiva.com/en-au/solutions/solvency-ii-software

Wolters Kluwer CCH Tagetik

Solvency II reporting suite covering QRT calculation, SFCR and RSR production, and supervisory submission files.

https://www.wolterskluwer.com/en/solutions/cch-tagetik/solvency-ii

ARKK

Regulatory reporting and digital tagging service that prepares Solvency II submission and disclosure files for insurers.

https://www.arkk.com/solvency-ii

Milliman

Actuarial consultancy that works on SFCR content, technical provisions and readiness for the 2027 Solvency II changes.

https://www.milliman.com