The insurance industry is working relentlessly to implement the IFRS 17. Almost three years after the new reporting standard was initially published, there is still a long way to go. This is not so surprising as IFRS 17 obliges the industry to fundamentally redesign its external and internal reporting. Creating a parallel reporting system (Solvency II) or adding an extra step in the existing process (a Risk Transfer Test), as was done in the past, is not an option this time.
Those involved in IFRS 17 implementation would acknowledge that the challenge they face is far beyond that of any `normal’ project – and not just because this is what the consultants keep saying.
Even if you are an experienced insurance practitioner, you will be forced into making difficult choices when advancing on the IFRS 17 highway. A highway, which is still under heavy construction.
Here are some observations on what to watch out for on the IFRS 17 highway and the questions you might need to ask yourself on the still incomplete road.
The level of knowledge and, in particular, how to interpret it professionally varies greatly between top management, project management, actuaries, accountants, systems and process specialists, internal performance management and investor relations. The time and the amount of repetition required for transmitting or acquiring this right level of knowledge is often underestimated. Self-study can be sufficient for some, but the majority will need facilitated sessions. Without investing enough time to decipher the IFRS 17 “rules” for all concerned, you may be at risk of taking wrong decisions at different levels of your organisation, due to misunderstandings or misinterpretations.
The more you advance, the more unmarked roads you seem to encounter. Should you take the right or left fork, or continue straight ahead? Sometimes the choices may relate to the nitty-gritty of the detailed design. At other times the fundamental direction, such as classification of your products, is in play. The number of decisions to be taken may seem overwhelming, as well as the extent of the resulting internal communication required.
Identifying the right person(s) to put at the wheel for many IFRS 17-related decisions is not straightforward. In particular, when implications for multiple areas, such as underwriting guidelines, accounting and reserving methodology and KPIs need to be considered at the same time. Different stages of the project demand different types of expertise or different personalities.
Maintaining a healthy balance between understanding all the relevant impacts and moving the project forward is essential. In each project, there will be a `pusher` and a `puller’, both with good reasons for advancing quickly rather than taking more time. You may have to choose between waiting until the road has been fully constructed or carrying on, relying on the temporary road-marking. Until the highway is fully built, the full financial and operational implications of IFRS 17 will not be entirely known. While making your system or methodology choices you can either continue spending time evaluating each issue profoundly, or draw a line for now. Studying the subject in-depth typically slows down the project, though it may make for a better choice of direction. But even decisions that are currently as informed as possible are no guarantee against a later recall.
There is no satellite navigation for this journey, so you have to start with your old systems and process maps (or establish them) and draw the new ones as you go. Insurance companies have grown up with a large and multi-dimensional patchwork of front systems, sub-ledgers and financial and regulatory reporting systems, which have probably never been fully mapped together. You need to understand both the old and the new world to get on the right route. Seemingly small points on your system and processes map, never connected before, may now need to join up. The details matter.
The project will be a long drive and no one wants to fall asleep at the wheel. People with the most knowledge and experience are most in demand and the need for their knowledge and time is snowballing. But you need to ensure they can delegate (preferably to suitably qualified colleagues) and get some rest. Driving without resting invites disaster.
Spending a reasonable amount of time on documenting which turn you chose and why is part of the journey. IFRS 17 implementation will take a long time. Some will still be working on projects in many years to come. Keeping a journal will help to ensure that you don’t lose your way or repeat past mistakes.
The destination the insurance industry will reach once the IFRS 17 has been implemented seems predefined, but getting there will take different amounts of time and effort for each of the players. And the time taken will also depend on how you address the challenges discussed above. So keep questioning yourself and others, watch out, and have a safe drive!