In some accounting models, a regulator may specify discount rates or other assumptions
about market risk variables that are used in measuring insurance liabilities and the
regulator may not amend those assumptions to reflect current market conditions at all
times. In such cases, compliance with the requirements might be achieved by disclosing:
(a) the effect on profit or loss or equity of a reasonably possible change in the
assumption set by the regulator; and
(b) the fact that the assumption set by the regulator would not necessarily change at
the same time, by the same amount, or in the same direction, as changes in market
prices, or market rates, would imply. [IFRS 4.IG65E].
An insurer might be able to take action to reduce the effect of changes in market
conditions. For example, it may have discretion to change surrender values or maturity
4414 Chapter 51
benefits, or to vary the amount or timing of policyholder benefits arising from
discretionary participation features. There is no requirement for entities to consider the
potential effect of future management actions that may offset the effect of the disclosed
changes in any relevant risk variable. However, disclosure is required of the methods
and assumptions used to prepare any sensitivity analysis. To comply with this
requirement, disclosure of the extent of available management actions and their effect
on the sensitivity analysis might be required. [IFRS 4.IG65F].
Because some insurers manage sensitivity to market conditions using alternative
methods as discussed above, different sensitivity approaches may be used for different
classes of insurance contracts. [IFRS 4.IG65G].
Many life insurance contract liabilities are backed by matching assets. In these
circumstances giving isolated disclosures about the variability of, say, interest rates on
the valuation of the liabilities without linking this to the impact on the assets could be
misleading to users of the financial statements. In these circumstances it may be useful
to provide information as to the linkage of market risk sensitivities.
11.2.7
Exposures to market risk from embedded derivatives
As noted at 11.2 above, disclosure is required if there are exposures to market risk arising
from embedded derivatives contained in a host insurance contract if the insurer is not
required to, and does not, measure the embedded derivatives at fair value. [IFRS 4.39(e)].
Fair value measurement is not required for derivatives embedded in an insurance
contract if the embedded derivative is itself an insurance contract (see 4 above).
Examples of these include guaranteed annuity options and guaranteed minimum death
benefits as illustrated below. [IFRS 4.IG66].
Example 51.43: Contract containing a guaranteed annuity option
An insurer issues a contract under which the policyholder pays a fixed monthly premium for thirty years. At
maturity, the policyholder can elect to take either (a) a lump sum equal to the accumulated investment value
or (b) a lifetime annuity at a rate guaranteed at inception (i.e. when the contract started). This is an example
of a contract containing a guaranteed annuity option.
For policyholders electing to receive the annuity, the insurer could suffer a significant loss if interest rates
decline substantially or if the policyholder lives much longer than the average. The insurer is exposed to both
market risk and significant insurance risk (mortality risk) and the transfer of insurance risk occurs at inception
of the contract because the insurer fixed the price for mortality risk at that date. Therefore, the contract is an
insurance contract from inception. Moreover, the embedded guaranteed annuity option itself meets the
definition of an insurance contract, and so separation is not required. [IFRS 4.IG67].
Example 51.44: Contract containing minimum guaranteed death benefits
An insurer issues a contract under which the policyholder pays a monthly premium for 30 years. Most of the
premiums are invested in a mutual fund. The rest is used to buy life cover and to cover expenses. On maturity or
surrender, the insurer pays the value of the mutual fund units at that date. On death before final maturity, the insurer
pays the greater of (a) the current unit value and (b) a fixed amount. This is an example of a contract containing
minimum guaranteed death benefits. It is an insurance contract because the insurer is exposed to significant
insurance risk as the fixed amount payable on death before maturity could be greater than the unit value.
It could be viewed as a hybrid contract comprising (a) a mutual fund investment and (b) an embedded life
insurance contract that pays a death benefit equal to the fixed amount less the current unit value (but zero if
the current unit value is more than the fixed amount). [IFRS 4.IG68].
Insurance contracts (IFRS 4) 4415
Both of the examples of embedded derivatives above meet the definition of an
insurance contract where the insurance risk is deemed significant. However, in each
case, market risk or interest rate risk may be much more significant than the mortality
risk. So, if interest rates or equity markets fall substantially, these guarantees would have
significant value. Given the long-term nature of the guarantees and the size of the
exposures, an insurer might face extremely large losses in certain scenarios. Therefore,
particular emphasis on disclosures about such exposures might be required. [IFRS 4.IG69].
To be informative, disclosures about such exposures may include:
• the sensitivity analysis discussed at 11.2.6.C above;
• information about the levels where these exposures start to have a material effect
on the insurer’s cash flows; and
• the fair value of the embedded derivative, although this is not a required disclosure.
[IFRS 4.IG70].
An extract of Aviva’s disclosures in respect of financial guarantees and options is
shown below.
Extract 51.34: Aviva plc (2016)
Notes to the consolidated financial statements [extract]
42 –
Financial guarantees and options [extract]
(c) Overseas life business [extract]
(ii) Spain and Italy
Guaranteed investment returns and guaranteed surrender values
The Group has also written contracts containing guaranteed investment returns and guaranteed surrender values in both
Spain and Italy. Traditional profit-sharing products receive an appropriate share of the investment return, assessed on a book value basis, subject to a guaranteed minimum annual return of up to 6% in Spain and up to 4% in Italy on existing
business, while on new business the maximum guaranteed rate is lower. Liabilities are generally taken as the face value
of the contract plus, if required, an explicit provision for guarantees calculated in accordance with local regulations. At 31 December 2016, total liabilities for the Spanish business were £1 billion (2015: £1 billion) with a further reserve of
£15 million (2015: £14 million) for guarantees. Total liabilities for the Italian business were £18 billion (2015:
£14 billion), with a further provision of £47 million (2015: £41 million) for guarantees. Liabilities are most sensitive to changes in the level of interest rates. It is estimated that provisions for guarantees would need to increase by £14 million (2015: £12 million) in Spain and decrease by £5 million (2015: £1 million decrease) in Italy
if interest rates fell by 1%
from end 2016 values. Under this sensitivity test, the guarantee provision in Spain is calculated conservatively, assuming a long-term market interest rate of 0.39% and no lapses or premium discontinuances. In the local valuation there is no
allowance for stochastic modelling of guarantees and options.
11.2.8
Other disclosure matters
11.2.8.A
IAS 1 capital disclosures
Most insurance entities are exposed to externally imposed capital requirements and
therefore the IAS 1 disclosures in respect of these requirements are likely to be applicable.
Where an entity is subject to externally imposed capital requirements, disclosures are
required of the nature of these requirements and how these requirements are
incorporated into the management of capital. Disclosure of whether these requirements
4416 Chapter 51
have been complied with in the reporting period is also required and, where they have
not been complied with, the consequences of such non-compliance. [IAS 1.135].
Many insurance entities operate in several jurisdictions. When an aggregate disclosure
of capital requirements, and how capital is managed, would not provide useful
information or distorts a financial statement user’s understanding of an entity’s capital
resources, separate information should be disclosed for each capital requirement to
which an entity is subject. [IAS 1.136].
Although there is no explicit requirement to disclose the amounts of the regulatory
capital requirements, some insurers do so to assist users of the financial statements.
Ping An is an example of an entity that discloses its externally imposed regulatory
capital requirements.
Extract 51.35: Ping An Insurance (Group) Company of China, Ltd (2016)
Notes to consolidated financial statements [extract]
for the year ended 31 December 2016
45. RISK AND CAPITAL MANAGEMENT [extract]
(7) CAPITAL MANAGEMENT [extract]
The Group’s capital requirements are primarily dependent on the scale and the type of business that it undertakes, as
well as the industry and geographic location in which it operates. The primary objectives of the Group’s capital
management are to ensure that the Group complies with externally imposed capital requirements and to maintain
healthy capital ratios in order to support its business and to maximize shareholders’ value.
The Group manages its capital requirements by assessing shortfalls, if any, between the reported and the required
capital levels on a regular basis. Adjustments to current capital levels are made in light of changes in economic
conditions and risk characteristics of the Group’s activities. In order to maintain or adjust the capital structure, the
Group may adjust the amount of dividends paid, return capital to ordinary shareholders or issue capital securities.
The Group has formally implemented China Risk Oriented Solvency System since 1 January 2016 by reference to the
‘Notice on the Formal Implementation of China Risk Oriented Solvency System by CIRC’. The Group adjusted the
objective, policy and process of capital management. As at 31 December 2016, the Group was compliant with the
relevant regulatory capital requirements.
The table below summarizes the minimum regulatory capital for the Group and its major insurance subsidiaries and
the regulatory capital held against each of them.
31 December 2016
Ping An
Property &
The Group
Ping An Life
Casualty
Core capital
889,883 501,710 63,439
Regulatory capital held
929,883 533,710 71,439
Minimum regulatory capital
442,729 236,304 26,725
Core solvency margin ratio
201.0%
212.3%
237.4%
Comprehensive solvency margin ratio
210.0%
225.9%
267.3%
As discussed at 7.2.1 above, equalisation and catastrophe provisions are not liabilities
but are a component of equity. Therefore, they are subject to the disclosure
requirements in IAS 1 for equity. IAS 1 requires disclosure of a description of the nature
and purpose of each reserve within equity. [IFRS 4.IG58].
Insurance contracts (IFRS 4) 4417
11.2.8.B
Financial guarantee contracts
A financial guarantee contract reimburses a loss incurred by the holder because a
specified debtor fails to make payment when due. The holder of such a contract is
exposed to credit risk and is required by IFRS 7 to make disclosures about that credit
risk. However, from the perspective of the issuer, the risk assumed by the issuer is
insurance risk rather than credit risk. [IFRS 4.IG64B].
As discussed at 2.2.3.D above, the issuer of a financial guarantee contract should provide
disclosures complying with IFRS 7 if it applies IAS 39 or IFRS 9 in recognising and
measuring the contract. However, if the issuer elects, when permitted, to apply IFRS 4
in recognising and measuring the contract, it provides disclosures complying with
IFRS 4. The main implications are as follows:
(a) IFRS 4 requires disclosure about actual claims compared with previous estimates
(claims development), but does not require disclosure of the fair value of the
contract; and
(b) IFRS 7 requires disclosure of the fair value of the contract, but does not require
disclosure of claims development. [IFRS 4.IG65A].
11.2.8.C
Fair value disclosures
Insurance contracts are not excluded from the scope of IFRS 13 and therefore any
insurance contracts measured at fair value are also subject to the disclosures required
by IFRS 13. However, insurance contracts are excluded from the scope of IFRS 7.
Disclosure of the fair value of investment contracts with a DPF is not required by IFRS 7
if the fair value of that feature cannot be measured reliably. [IFRS 7.29(c)]. However, IFRS 7
does require additional information about fair value in these circumstances including
disclosure that fair value information has not been provided because fair value cannot
be reliably measured, an explanation of why fair value cannot be reliably measured,
information about the market for the instruments, information about whether and how
the entity intends to dispose of the financial instruments and any gain or loss recognised
on derecognition. [IFRS 7.30].
For insurance contracts and investment contract liabilities with and without a DPF which
are measured at fair value, disclosures required by IFRS 13 include the level in the fair
value hierarchy in which the liabilities are categorised. [IFRS 13.93]. Very few insurance or
investment contract liabilities are likely to have quoted prices (unadjusted) in active
markets and are therefore likely to be Level 2 or Level 3 measurements under IFRS 13.
For investment contract liabilities without a DPF measured at amortised cost, disclosure
of the fair value of those contracts is required as well as the assumptions applied in
determining those fair values and the level of the fair value hierarchy in which those fair
value measurements are categorised. [IFRS 13.97].
When unit-linked investment liabilities are matched by associated financial assets some
have argued that there is no
fair value adjustment for credit risk as the liability is simply the
value of the asset. However, there will be at least some risk, however small, of non-payment
with regard to the liability. Therefore, it would be appropriate to provide some form of
qualitative disclosure that credit risk was taken into account in assessing the fair value of the
liability or why it was thought to be immaterial and/or relevant only in extreme situations.
4418 Chapter 51
11.2.8.D
Key performance indicators
IFRS 4 does not require disclosure of key performance indicators. However, such
disclosures might be a useful way for an insurer to explain its financial performance
during the period and to give an insight into the risks arising from insurance contracts.
[IFRS 4.IG71].
References
1
IASB Update, May 2002.
7 Commission Regulation (EU) 2017/1988 of
2 www.cfoforum.eu (accessed on
3
November
2017 amending Regulation (EC)
11 September 2018).
No
1126/2008 adopting certain international
3
IFRIC Update, January 2008, p.3.
accounting standards in accordance with
4
IFRIC Update, November 2005, p.6.
Regulation (EC) No 1606/2002 of the European
5
IFRIC Update, January 2010, p.2.
Parliament and of the Council as regards
6
European Embedded Value Principles, European
International Financial Reporting Standard
4,
Insurance CFO Forum, May 2004, p.3.
Official Journal of the European Union,
9 November 2017.
4419
Chapter 52
Insurance contracts
(IFRS 17)
1 INTRODUCTION .......................................................................................... 4429
2 THE OBJECTIVE, DEFINITIONS AND SCOPE OF IFRS 17 ...........................4431
2.1
The objective of IFRS 17 ................................................................................... 4431
International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards Page 874