On 15 July 2026 EIOPA delivered the last of the legal instruments it was mandated to produce under the EU's Solvency II review. The revised framework applies from 30 January 2027. The remaining work is not in Frankfurt or Brussels — it is in firms' models.
Solvency IIRisk marginLiquidityMatching adjustmentORSAPrecision about actors matters here, because the package is easy to misread. The substantive change to the framework was made by the EU legislator and the European Commission: the review Directive, and the amended Delegated Regulation the Commission adopted in October 2025 — Regulation (EU) 2026/269. What EIOPA published on 15 July 2026 is the delivery of its mandate as the producer of the supporting instruments: eight sets of guidelines and draft technical standards, completing every legal instrument it was mandated to produce under the review. The draft technical standards now sit with the European Commission, which decides their adoption — a decision due within three months of the 15 July submission, so around mid-October 2026. The delegated acts themselves are not waiting on anything: they were adopted last October.
One more scoping note, for our UK readers: this is EU law. UK firms operate under Solvency UK, which has taken its own path since the end of 2024. Where this package bites a UK reader directly is through EEA entities in the group — and, less directly, as a preview of the questions supervisors everywhere are learning to ask.
The review introduces, in EIOPA's words, "an exponential and time-dependent element (the so-called lambda factor)" into the risk margin, "to better account for the time dependency of risks and reduce both the amount of the risk margin for long-term liabilities and its sensitivity to interest rate changes." For long-duration books — annuities, long-tail liability — this is a structural change to how the balance sheet breathes: a lower margin, and a margin that amplifies rate moves less. A new regulatory technical standard covers the simplified calculation of the risk margin, and the Guidelines on the valuation of technical provisions have been revised to carry the change. The practical consequence: technical-provision and risk-margin components need re-parameterising, re-documenting and re-validating against the new texts — not on 30 January 2027, but in the ORSA and model-change cycles that begin now.
The genuinely new instrument is the set of Guidelines on supervisory powers to remedy liquidity vulnerabilities: the form, activation and extent of the powers supervisors may exercise where liquidity management is deficient — up to and including, in exceptional circumstances, temporary suspension of policyholders' redemption rights. Liquidity risk in insurance has historically been a second-order chapter of the ORSA. It now has an explicit supervisory intervention ladder attached. Expect liquidity-vulnerability metrics, escalation triggers and management actions to be tested against these Guidelines — and a reverse stress test that ends in redemption-suspension territory will concentrate minds at board level.
Matching-adjustment users may assume full diversification between the MA portfolio and the rest of the business in the SCR calculation, provided the best estimate of the obligations does not form a ring-fenced fund. For annuity writers this is a real SCR movement, and the ring-fenced-fund boundary condition will decide who captures it. Expect structuring attention on exactly that boundary.
Between now and 30 January 2027, every EEA insurer — and every UK group with EEA entities — is running an ORSA that straddles two frameworks. The clean approach is to run the forward-looking assessment revised-framework-aware from this cycle: quantify the lambda-factor effect on the risk margin, re-test the MA diversification benefit under the ring-fenced-fund condition, and stand up liquidity-vulnerability metrics before supervisors ask for them. Model validation owns the re-baselining evidence. This is precisely the class of regulatory-change-to-capital-impact translation Abgalis works on: reading the instrument as adopted, mapping the affected model components, and producing calculations a firm's actuarial function can adopt for its own processes — quantified, documented and gated. The firm makes its own submissions; the evidence trail is what we build.
A firm-specific walk-through of how the revised framework moves the risk margin and SCR for a long-duration book — instrumented for ORSA narrative and model-change evidence.