Publication de la lettre circulaire 23/2 du Commissariat aux assurances relative au rapport actuariel annuel des entreprises luxembourgeoises d’assurances autres que sur la vie

On 7 February 2023, the Commissariat aux Assurances (CAA) published Circular letter 23/2 relating to the annual actuarial report of Luxembourg insurance companies other than life insurance.
The actuarial report in non-life insurance is requested since the reporting relating to the financial year 2005. It has become an essential tool for the Commissariat aux assurances in monitoring non-life insurance companies. Since the entry into force of circular letter 12/4 containing the current provisions on this subject, the Solvency 2 Directive entered into force and it was considered appropriate to amend certain provisions of the aforementioned circular letter in order to adapt them to the current legislative framework. Therefore, Circular letter 21/19 has thus revisited the reporting for the 2021 financial year. The present Circular letter 23/2 clarifies certain aspects regarding the modifications of CL 21/19, which have been misunderstood or raised many questions.
Furthermore, the following new features are hereby introduced:
– Four additional questions concerning the status and duties of the actuary were added;
– RAC D 0050 tables must now be produced for all branches defined according to appendix I of the Law of 7 December 2015 for which a number of claims declared is greater than 500;
– The RAC D 0060 table now includes all the branches defined according to appendix I of the Law of 7 December 2015 and the column „provision for claims assessed in a manner actuarial“ has been withdrawn;
– Clarifications have been added on the expected explanations concerning restatements described in section 2.5;
– Clarifications have been added concerning the assumptions to be applied in the calculation of the market stress test;
– Clarifications have been added concerning the stress tests „degradation of claims“, especially for companies that are not affected by „cyber“ scenarios and „man-made“;
– The statistics requested in part 6 „pricing“ are now to be provided in part 1 within the RAC D 0120 tables
As in the past, the report has two distinct parts:
– Part 1 is an Excel file which includes a qualitative questionnaire (RAC.D.0020) with questions mainly of the “yes / no” type and quantitative annexes in the form of paintings.
– Part 2 is a paper document signed by the actuary and containing explanations complementary.
The date of submission of the actuarial report is communicated each year by the CAA in the form of a information note, together with the dates of submission of the other periodic statements to the CAA.
The figures to be delivered on computer media must be inserted in the file plus amply described in the IT user manual for reporting. Any comments relating to the methods used and the results obtained are, on the other hand, to be included in the section narrative of the actuarial report.
The actuarial report must be signed by an actuary or any other person expert in the matters covered by this circular letter, having professional experience in actuarial matters for at least three years.
The entire actuarial report, as supplemented where applicable by additional information provided at the request of the CAA, must be submitted as soon as possible for discussion to the board of directors of the insurance company.
This circular letter replaces the provisions of circular letter 12/4 of the CAA relating to the annual actuarial report of Luxembourg insurance companies other than life and applies for the first time to the financial statements for the 2021 financial year.