Delivering IFRS 17 - Scale Challenge and Opportunity - Innovation Business Vision
Delivering IFRS 17 - Scale Challenge and Opportunity - Innovation Business Vision
Delivering IFRS 17 - Scale Challenge and Opportunity - Innovation Business Vision
CONTENTS
Executive summary .......................................................................................................................................................... 4
Introduction ...................................................................................................................................................................... 6
1. Planning for IFRS 17 .................................................................................................................................................... 7
Seven basic questions ................................................................................................................................................. 8
1.
2.
3.
4.
5.
6.
7.
EXECUTIVE SUMMARY
IFRS 17 will be the biggest challenge the insurance
industry has faced in a generation. The finance operating
model of every insurer working within an IFRS jurisdiction
will have to be re-engineered. IFRS 17 will be effective 1
January 2021, with insurers required to produce
comparative accounts for 2020.
IFRS 17 will bring unprecedented challenges
to insurers in how they maintain confidence
of investors, how they deliver the required
change, how they manage their businesses
and how they sustain an affordable back
office.
From our IFRS 17 delivery work for
insurance clients, we see key areas that will
be impacted. We have identified these in the
adjacent diagram, (figure 1) where the boxes
coloured orange indicate the areas of the
process that will change as a result of IFRS
17.
Depending on insurers approach and
motivation, it may be possible to work
towards minimizing the impact of the huge
increase in operational work and cost.
Essential steps such as alignment of internal
accounting policies, construction of better
operating models or increasing levels of
automation may need to be taken to reduce
risk and limit impact.
To ensure successful delivery and
implementation, incremental resources will
be required to deliver the change in a
structured and coordinated manner.
A summary of the next steps for every insurer is illustrated on page 33. For more
information see: www.innovation.co.uk
INTRODUCTION
A change is coming that will transform how investors view insurance companies and will
revolutionise how insurers manage themselves.
IFRS 4 TO IFRS 17
Over the last twenty years, measurement of profit and
loss has been transformed across the globe by the
implementation of International Financial Reporting
Standards (IFRS). These standards have enabled
businesses to operate across borders and speak the
same financial language, thus becoming more
comparable for investors. The major standard for
insurance contracts is IFRS 4, initially released in 2004
and revised in 2005.
Figure 2. How asking seven basic questions aids planning and delivery of change.
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Most insurers will require external support from a range of consultancies in delivering change. Some of the major firms
have customisable-off-the-shelf solutions available, some offer subject-matter expertise and others offer resource backfill. The challenge for insurers with suppliers is to secure resources before they become too scarce or too expensive.
For example, there are about 65,000 actuaries in the world, but a common view is that IFRS 17 will require equivalent
to 100,000. This type of shortage will drive prices up. It also indicates the need for smarter processes with higher
degrees of automation.
In summary, all stakeholder groups will be subject to unwanted changes and pressures. For customers and investors,
the impact can be minimised by careful management of the transition between IFRS 4 and IFRS 17 by putting good
planning and communication at the centre of the effort. Workers will face a different kind of pressure because people
are usually resistant to externally imposed change. Senior managers in the business will find their roles and
responsibilities changing and their levels of authority and culpability also shifting. Moreover, there will be an increased
resource requirement, not just to deliver the change, but in perpetuity.
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STRATEGIC OPTIONS
Strategic options
Even a minimum change will require large effort and expenditure. The new
complexities of IFRS 17 will not have been managed down. This option will also
lead to a higher operational cost than a more optimised approach.
Similar to the work above with the addition of work to specifically support
investor relationships.
A team could be generated and dedicated to managing investor expectations.
This would enable good investor management through this period. However, it is
likely to be a duplication of work that will have to be undertaken anyway,
doubling the costs in certain areas of work, plus exposing the business to
governance and audit risks. As such, it may be financially beneficial to pursue
the next option.
The level of necessary back-office change required of insurers will be massive. It
is unlikely that insurers will be forced to apply such large and structural changes
in their back-office operations for a long time. This being the case it would be
prudent for insurers to deal with structural and peripheral issues that have built
up in their operating models as their businesses have evolved.
Some of these issues could be resolved at low or zero cost in the course of
delivering IFRS 17, however, issues would first need to be acknowledged,
documented and understood. It could be useful for insurers to benchmark each
other. Benchmarking may appear to be an unattractive option, but as insurers
dont compete on their back offices and IFRS imposes greater transparency,
some insurers may find such activities advantageous.
Required cost of investment is unlikely to palatable to company boards unless
the investment cost is measured in comparison to operational benefit of
delivering the change in business cases.
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4. Use IFRS 17 as an
opportunity to deliver
something fundamentally new
and different.
(Do maximum option)
Insurers may wish to take the opportunity to fundamentally re-engineer how they
manage their businesses. From the perspectives of business processes and
accounting standards this will be achievable in the pragmatic option above.
Nevertheless, even more could be done. Accountants and actuaries could target
full automation of their close processes. They could decide to replace longstanding models and have new management information systems delivered.
All of these are worthy pursuits, especially if the result is a slicker, quicker,
leaner and lower cost back-office that is able to rapidly respond to management
and investor demands. However, every additional initiative potentially increases
the complexity and risk in delivery.
In our view is it useful to begin the strategic design process by being idealistic,
then paring back delivery planning to align with budgets, risk, timing and
capability.
Early identification of the best ideas and improvements will enable the business
to make considered and timely decisions. Some proposals will be deemed too
risky, whilst others can be prioritised and properly managed (these end up
contributing to the pragmatic option).
One area we do propose caution on is in systems. Data entry, storage,
transformation, processing and reporting is highly complex in most insurers.
Insurers usually face a huge challenge in maintaining their legacy systems
(usually policy systems). Changing major systems during this period should be
treated very carefully. If an insurer is keen on changing major systems during the
IFRS development period, we would urge them to put contingency plans and
funding in place to maintain legacy systems in an IFRS 17 compatible manner
until the new systems are fully signed off. We do suggest though, that if systems
change is on any partys agenda, that they place particular focus on ensuring
good data standards, to enable good systems design.
There will be a large number of subordinate options to each of these strategic options. We discuss sixteen relevant
options in section 2, on pages 23 to 25.
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2. DELIVERING IFRS 17
MAJOR CONSIDERATIONS
Each insurer is going to rework its valuation and accounting processes. The insurers
approach to product development will change. New processes and models will be
required for closing the books and undertaking valuation. Current configuration of
organisations and systems will not suit an IFRS 17 environment, so these will have to
change too. For example, actuarial teams often reside separated from their accounting
colleagues, but IFRS 17 will place actuaries much closer, if not at the centre of
accounting processes. This will mean a much higher integration of teams, leading to
organisational changes. In addition, systems supporting the people and the processes
will also need to be reengineered.
These points lead to further questions about how much
and how far a business is prepared to go to undertake
changes. Most insurers do not prioritise investment in
their back-office operations, however there is a case to
use IFRS 17 as an opportunity to undertake corporate
house-keeping by aligning its accounting policies
across all its entities. Especially as, a post-IFRS 17
accounting and actuarial environment will be much
more operationally complex, therefore costlier, than the
current regime.
If the insurer chooses to pursue the minimum amount
of change to be compliant, they are likely to pay a
heavy operational overhead for maintaining the
minimum required standards. It will also face increased
operational complexity because of the increase in
volume and complexity of calculations.
If the insurer chooses to take the opportunity to
optimise its processes it will compete for scarce
resources with other insurers. For example, there are
currently about 65,000 practising actuaries in the
world, a common consensus is that the number of
required actuaries by 2022 could be 100,000.
Insurers also face a choice about how much support
they seek from outside organisations. Most large
accounting firms and consultancy firms offer expertise
in the accounting and actuarial approaches to the
standard. Others, such as Innovation are experts in
delivery. At least one major accounting firm has even
invested in training a large number of new actuaries in
anticipation of delivering the changes for clients.
Deciding what level of external intervention will be
required is a key decision in setting the insurers
delivery strategy. It may be tempting to do the work inhouse, but suppliers have been developing processes,
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DELIVERY OPTIONS
After the strategic direction is settled (previously in section 1.6 How?) there will be
delivery options. This section discusses twenty common options available to insurers.
There will be a great deal more options and sub-options available to each insurer, but
their relevance will depend on the people, processes and systems the insurer currently
has, and those it intends to have by 2022. The earlier these are explored, the more likely
implementation of IFRS 17 will happen in a planned and controlled manner.
The workflow is illustrated on the next page (figure 6)
and discussed in detail thereafter. For this paper the
options discussed are:
Delivery options 6 & 7 - Decide whether to buy offthe-shelf systems to fast-track delivery (Table 6)
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1. Develop in-house
and backfill
operational work
This approach could be dubbed The artisanal approach, where actuaries and accountants
make their own tools that they will subsequently use to deliver the operational work.
inconsequently when the process and the systems are operational, the users will understand
the challenges and be able to work continuous improvement activities.
The insurers employees will need to learn IFRS 17 before they can effectively design and
deliver the required changes. This means that the rate of development is likely to be slower
than in other organisations who use external support. In addition, developing the required
process, models and systems without external support risks missing optimum solutions
derived by external parties. In backfilling the operational work, insurers are more likely to be
able to retain key employees during the development of IFRS 17, but the cost of backfill could
be high. Backfill costs could be reduced by utilising agency / contract staff on short or fixed
term contracts.
2. Develop in-house
and dont backfill
operational work
As previous, except the following: In not backfilling operations, many actuaries and
accountants will have much increased workload. This will make working for the insurer less
attractive at a time when other insurers are likely to be offering premium job-offers to
prospective accountants and actuaries, especially those with IFRS 17 experience. This will
be especially bad for organisations who are lean.
3. Outsource
development work
and maintain use of
staff for operational
work
This is the type of approach used by organisations in manufacturing industries where there is
a high degree of separation between those who develop and those who manufacture the
goods. Insurers tend to be more artisanal, where accountants and actuaries often make their
own tools (based on frameworks from outside suppliers) and use them to deliver the
operational work.
This route does have many merits; It minimises the disruption to current operations; utilises
experts whose approach and insight would not otherwise be applied; benefits the client by
only paying for mature expertise (whereas internal people will be learning as they go along),
but leaves staff with minimal understanding of IFRS 17 and its mechanisms. Possibly also
leaves the insurer dependent on outsourced organisations who will have different priorities
and motives to the insurer.
4. Develop in
partnership with
suppliers and
backfill operational
work
A good number of suppliers to insurers have been developing technical and business
process solutions to IFRS 17. If chosen and managed carefully they could offer a good
service and minimise disruption in current operations
5. Develop in
partnership with
suppliers and do not
backfill operational
work
As the previous option except: Where work becomes unexpectedly high or difficult, there will
be two types of problem that can emerge. The first when operational work becomes
prioritised over the development work, meaning that the rate of development slows down,
and the project is delayed. The second is that an unscrupulous supplier sees complexity of
delays as an opportunity to exploit shortages at a high cost to the customer.
The risk that if not properly managed, the suppliers deliver what is best for the supplier, not
the customer. Use of several suppliers specialist in certain activities may treat this risk.
Backfilling operational work can be undertaken by agency or independent staff on short or
fixed term contracts. This would be significantly lower cost than compared to consultancy
staff.
Table 5. Delivery options 1 to 5 - Decide workload balance & volume of outsourced development
6. Buy off-the-shelf
models
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A number of suppliers have developed Prophet or MoSes IFRS 17 valuation models. These
can be adopted by insurers and plugged in to the operational process, short cutting the
development time for key and complex areas of the process. The risk that the insurer
There is at least one full accounting system on the market that has the required components
for the insurer to be IFRS 17 compatible, it is provided by SAP. There may be other systems
too. Changing accounting systems is a long-term and challenging process. All manner of
factors need to be decided, including data standards, version control and service
management. Backward-compatibility with legacy systems will be a key challenge.
8. Outsource
operational work
temporarily
9. Outsource
operational work
permanently
Elements of the process permanently ceded to an outside supplier would simplify the amount
of internal management required within an insurer Outsourcing will always be a double edged
sword, day-to-day costs become relatively fixed, but changes in service become costly.
Service standards tend to be low and responsiveness reduced. Despite the downsides it
does make management of the core business simpler and more predictable.
Table 7. Delivery options 8 & 9 - Decide whether to outsource operational work either temporarily or permanently
10. Local
development of the
standard
Allow each entity to develop their own ledgers and models in response to IFRS 17. This will
allow each entity to closely work towards perfecting local regulatory requirements. The
corollary of this is that an insurers entire accounting and actuarial process would become
fragmented with proliferation of duplication. It would be difficult to manage from a group
perspective. Audit would become expensive. Operational duplication would be rife. Once
operational it would be much more difficult for actuarial teams to be able to validate headoffice numbers where local anomalies occur.
11. Central
development of the
standard
Design, plan, manage and deliver IFRS 17 from a centralised location.The previous option
demonstrates the inadequacies of a localised approach. A centralised approach gives the
insurer the opportunity to resolve all these issues. However, a centralised approach can
throw up its own problems entities will be subject to different details in the standards,
meaning that there will be local nuances. To attempt to control and tie all of these distinctions
down at a central point would most likely be counterproductive when expertise is locally
based.
This option is a hybrid of options 13 and 14. It recognises that there are merits in central
working and local working. Strategy, planning and design is easier when members of a team
are co-located. This will suit most insurers because they have corporate accounting or
actuarial solutions. Nevertheless, some activities such as detailed adjustment of models may
be best handled locally. This option recognises these compromises. There exact split will
depend on how complex and fragmented the insurers organisation, processes and systems
are.
Table 8. Delivery options 10 to 12 - Decide where the elements of the work will take place
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13. Produce
comparative
accounts
concurrently
Comparative accounts are usually more easily done at the time the original accounts are
created because retrospective accounting and disclosure creation can be troublesome. In
addition, it can be difficult to devise useful commentaries when time has passed.
In producing the accounts retrospectively, the insurer has the opportunity to delay completion
of its business process design and modelling. The disadvantage of this option is that because
the work is done retrospectively it would be difficult to understand or correct surprising
outcomes.
Table 9. Delivery options 13 & 14 - Decide timing of calculation actions for comparative and opening balance sheet work
Early adoption of the standard is allowable. It is advantageous to any insurer because it will
give it a much greater amount of time to understand and explain the changes in the balance
sheet to its investors. It may also be advantageous to a business that it discovers that its
position is actually improved by IFRS 17, or that investors view of the business is actually
improved.
Comparative accounts would be required; so very early work would be required to enable to
business to re-engineer its processes to be able to accomplish early adoption. It is likely that
such a delivery would require off-the-shelf solutions and a great deal of external support.
16. Adopt late
Some insurers have been lobbying hard to delay the standard further. It is likely that they
have assessed their businesss capability and believe it will not be possible to be compliant in
time. Even a small delay might help some businesses if it were possible because they could
benefit from suppliers learning experiences at other insurers.
In some cases, it would be possible for some or all entities within an insurer delaying. The
route to enabling a delay lies in each companys accounting reference period. For most
businesses it is January to December, making the first scheduled annual report for IFRS 17
in December 2021. If an insurer moves its accounting reference period prior to 2021, then it
may be able to delay 1 month, for every month it shifts with a maximum delay of 11 months.
All manner of legal issues would have to be resolved, some national regulators would not
allow it, an insurer would probably lose credibility in doing it and it would be very costly.
Table 10. Delivery options 15 & 16 - Decide whether to adopt early, on time or late
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Figure 7. The proposed nine IFRS 17 workstreams shown in proportion to the overall workload
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PROGRAMME SCHEDULE
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All institutions will be committing to do this work at about the same time. There is already
a shortage of actuaries in the world and also a shortage of project managers with
insurance experience. IFRS 17 will exacerbate this situation. Innovations experience of
the Solvency II peak where programme managers cost 50% more because of high
demand.
2 Alignment with
local reporting
standards
There will be differences in each country both in terms of product/policy and local
regulators detailed requirements
3 Level of
information flow
from Actuarial to
Finance will
massively increase
4 Analysis of
profitability profiles
and modelling of
potential outcomes
Early analysis of the profitability profiles will help understand what the information gaps
are
5 Conflicts with
Solvency II and
other risk-based
capital reporting
requirements
It may be possible to lever benefits from SII, but there are significant differences such as
contractual service margin, presentation and disclosure requirements and transition
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If the new reporting regime causes a big shift and recalibration in risk / liability / P&L, then
this could have a major impact on the businesss market perception. Companies who do
not communicate well may find the market against them.
Scarce resources with become even more scarce. Consequently, prices will rise as quality
people become ever more in demand.
3 IFRS 17 TOM
design isnt
satisfactory
4 Much duplication
of work in each
country
Even though IFRS 17 is a standard, the detailed outputs in each country will be slightly
different. This results in high costs and workload
5 Resistance to
change
Not all stakeholders buy into the change of P&L reporting from current to forecast. It is
likely that there will be a period of resistance to the concept of the changes by some
stakeholders.
6 Major M&A
disrupts
development
M&A activities are disruptive to business and back-office management. It can take a
decade to align organisations, processes and systems. Adopting a pre-existing business
during the IFRS 17 development period will make delivery costly and challenging
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As with all new regulatory regimes, IFRS 17 will give every insurer the opportunity to
lever how it implements the standard to increase market advantage
2 Alignment of
accounting policies
in different entities
Many insurers have grown by acquisition. When organisations are merged into the
new parent, they often retain legacy methods and processes. This makes the act of
closing books more complex than it would be if all policies, methods and standards
were aligned
3 Implementation in
multiple countries
Undertake a pilot in lead countries and roll-out progressively, learning lessons and
making improvements on the way
It may be possible to lever some benefits from SII work but there are also significant
differences such as contractual service margin, presentation and disclosure
requirements and transition
The technical challenges will need to be defined, some are universal, and many are
unique to each company. Getting an early view will allow key decisions to be made in
an orderly and timely way
6 Improve the
business processes
Taking those opportunities could be factored into the programme and achieved at the
same time
7 Organisational
opportunities
The new way of working will give rise to a number of opportunities to change or
renew how people operate in the affected areas.
8 Systems
opportunities
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NEXT STEP
1 Start to understand
the investor
implications of the
change.
There is a risk that investors will respond negatively to the impact IFRS 17 has on
your business. Model the changes in todays balance sheet and perform a gap
analysis as to how investors might respond
2 Communicate the
need for change
Creating awareness of the need for change is the first step to enabling the change to
be delivered. Communicate the strategic need for change and invite comment and
views from the affected user population.
3 Understand what
needs to change
Early gap analysis will allow the business to begin to understand the scale of
potential changes and kick-off the planning cycle. Make decisions about what
opportunities you wish to take to align your accounting policies, reduce complexity
and optimise your organisation.
Strategic decisions take a long time for experts to work through. Identifying key
decisions early will allow the process of debate and investigation to commence.
IFRS 17 will be one of a number of programmes undertaken over the next 4 years.
Many will have interdependencies and some may negate or duplicate each other.
Assess IFRS against all other strategic initiatives and assess constraints,
dependencies, assumptions, clashes, pinch-points and duplications.
6 Identify delivery
options
There are always many different ways of delivering a set of outcomes. Create a list
of all the delivery options use our template to speed the process up and add extra
options unique to your business. Prioritise what is more is more important low
investment cost or low operational cost
7 Set up a team to do
kick off the work
This work has to be done. It would be better done before it becomes urgent and
resource availability becomes an issue. Decide whether there is the capability and
capacity to do the work wholly in house or whether some or all of it is contracted out.
Plan the implementation of change in detail. Build a basic framework for the end-toend process of change. The information provided in this paper should enable you to
do this.
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INNOVATORS
We are powered by our people; we call them
Innovators. Innovators are people who share our
values and have the experience and ability to serve
Innovations customers well. Because Innovation is
solely concerned with delivering change, we have high
standards for people in these subjects. Our people are
rounded, they have a wide range of management and
delivery skills they get their hands dirty and they
have done it successfully over a number of years.
Our staff are a mixture of employees and independent
consultants. The independent consultants are usually
very senior, with decades of experience and enjoy the
challenge of working in different business
environments. Many of our independent consultants
have worked with us for over a decade. This business
model allows Innovation to be lower cost and have a
flexible approach to our customers. Three key features
that differentiate Innovation from bigger and more
general consultancies are:
Aviva
Prudential GHO
Prudential UK
Friends Life
PruHealth
Just Retirement
Sedgwick
Swiss Re
Manulife
Mercer
Zurich Insurance
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