Solvency UK reporting has just been overhauled, and the clock is already running. The Prudential Regulation Authority has published Policy Statement 18/26 on Solvency UK post-implementation reporting, disclosure and Own Funds permissions changes, with the PRA intending to implement the final policy and rule instrument for reporting reference dates on or after Thursday 31 December 2026. This is not a capital reform: it is a dense set of operational deadlines for compliance and actuarial teams, landing well before the next chapter of the wider Solvency capital debate.
Branch reporting loses two of its three years
Third-country branches get the single biggest cut in the package. The PRA is reducing the requirement for branches to report projected FSCS liabilities data from three years of data to one year, stripping out a forecasting window that firms had complained was disproportionate to its supervisory value. The requirement traces back to CP22/25, which originally proposed that third-country branch undertakings report projected FSCS liabilities within the non-life income, expenditure and business model analysis template IR, and the trimmed version keeps the data point without the multi-year forecasting burden.
The change sits alongside a subsidiarisation threshold that currently stands at £600 million of FSCS-protected liabilities and triggers closer branch supervisory scrutiny, and follows PS13/26, published in May 2026, which set out the PRA’s final policy on insurance third-country branches. It also follows a track record the regulator would rather not repeat: the PRA fined HDI Global SE over FSCS data errors that ran across three years of submissions, and easing the projection window is as much about data quality as it is about paperwork.
MALIR trades Excel rows for XBRL tags
Matching adjustment reporting gets the more technical makeover. The PRA proposed moving the Matching Adjustment Asset and Liability Information Return (MALIR) templates from Excel to eXtensible Business Reporting Language (XBRL) format and including them in the Bank of England Insurance Taxonomy, a shift first set out in the Solvency UK reporting and disclosure consultation paper. Annuity writers running matching adjustment portfolios will need to rebuild MALIR submission pipelines around structured XBRL tagging rather than spreadsheet templates, mirroring the format already used across the rest of the Solvency UK regulatory returns.
Frequency is easing at the same time as format. Two respondents welcomed the proposal to reduce the frequency of cashflows reported in the MALIR templates from monthly to annual, noting the significant reduction in file sizes and validation work required. The PRA is banking on the lead time being sufficient: it considers there is sufficient time for firms to prepare for the first XBRL MALIR submissions in 2027, giving actuarial and reporting teams roughly a year to re-plumb data feeds before the new format goes live.
A single date resets the annuity progression clock
The most consequential date in the package sits inside a single annuity template. The PRA is changing the reference date for the non-life annuity provision progression in template IR.16.01 from 31 December 2024 to 31 December 2026, to align with the implementation date of this policy. For non-life annuity writers, that means the progression history being compared against restarts from the new reporting reference date rather than carrying forward two more years of pre-overhaul data.
The reset is not confined to annuities. Firms will be allowed to opt in to reporting NACE 2.1 codes from the 31 December 2026 reporting reference date, ahead of the formal implementation date of 1 January 2027, giving firms that are ready an early option rather than a mandatory switch. Taken together, the annuity reset and the NACE opt-in confirm the same operational anchor point across the package: reporting reference dates on or after Thursday 31 December 2026.
Why MALIR’s move to XBRL lands before the capital debate does
PS18/26 is a feedback statement as much as a rulebook change. The PRA’s Regulatory Digest for July 2026 confirms that PS18/26 provides the PRA’s feedback on responses to CP22/25, published via the Regulatory Digest for July 2026. The PRA received six responses to CP22/25 and three responses to Proposal 1 of CP4/26 — a modest but engaged industry sample for what amounts to a plumbing exercise rather than a capital fight. CP22/25, the Solvency UK reporting and disclosure post-implementation amendments consultation, was published on 4 December 2025, and the consultation closed on Wednesday 4 March 2026.
A smaller but notable Own Funds change rode alongside the reporting fixes. Under CP4/26 Proposal 1, the PRA is removing the permission requirement for classifying equity-accounted subordinated liabilities into own funds tiers — a narrow administrative simplification, not a change to how much capital insurers must hold. That distinction matters: while PS18/26 tightens the operational calendar, it leaves the UK’s divergence from EU Solvency II on capital untouched, and it arrives on a materially faster clock than EIOPA’s parallel January 2027 timeline for its own Solvency II supervisory guidelines.
