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Accounting for Insurance Contracts

  1. Introduction
  2. Definitions of Terms
  3. Insurance Contracts
      1. Insurance Risk
  4. Recognition and Measurement Guidance
      1. Adequacy of Insurance Liabilities
      2. Impairment Testing of Reinsurance Assets
      3. Selection of Accounting Principles
      4. Unbundling
      5. Recognition
      6. Discretionary Participation Features in Insurance Contracts
      7. Embedded Derivatives
  5. Disclosure
    1. Applying IFRS 9 with IFRS 4
      1. Temporary Exemption from IFRS 9
      2. Disclosures about the temporary exemption from IFRS 9
      3. The Overlay Approach
      4. Disclosures About the Overlay Approach
      5. Interaction with Other Requirements
    2. Transitional Provisions
      1. Temporary Exemption from IFRS 9
      2. The Overlay Approach
  6. Future Developments
    1. IFRS 17 Insurance Contracts
  7. US GAAP Comparison

Introduction

IFRS 4, Insurance Contracts, mainly addresses the identification of insurance contracts by an entity that issues these contracts—which is not limited to insurance companies—and limited other recognition and measurement issues. It applies to insurance contracts issued, reinsurance contracts held and financial instruments issued with a discretionary participation feature. The matter of the actual accounting for insurance contracts is not addressed in IFRS 4.

IFRS 17, Insurance Contracts, was issued May 2017 to create a comprehensive standard to deal with the identification, recognition, measurement, presentation and disclosure of insurance contracts. IFRS 17 is effective for annual reporting periods beginning on or after 1 January 2021. Earlier adoption is permitted provided that the entity also applies IFRS 9, Financial Instruments, and IFRS 15, Revenue from Contracts with Customers, on or before the date of initial application of IFRS 17.

Definitions of Terms

Cedant. The policyholder under a reinsurance contract.

Deposit component. A contractual component that is not accounted for as a derivative under IFRS 9 and would be within the scope of IFRS 9 if it were a separate instrument.

Direct insurance contract. An insurance contract that is not a reinsurance contract.

Discretionary participation feature. A contractual right to receive, as a supplement to guaranteed benefits, additional benefits:

  1. That are likely to be a significant portion of the total contractual benefits;
  2. Whose amount or timing is contractually at the discretion of the issuer; and
  3. That are contractually based on:
    1. The performance of a specified pool of contracts or a specified type of contract;
    2. Realised and/or unrealised investment returns on a specific pool of assets held by the issuer; or
    3. The profit or loss of the company, fund or other entity that issues the contract.

Fair value. The amount for which an asset could be exchanged, or a liability settled, between knowledgeable, willing parties in an arm's-length transaction.

Financial guarantee contract. A contract that requires the issuer to make specified payments to reimburse the holder for a loss it incurs because a specified debtor fails to make payment when due in accordance with the original or modified terms of a debt instrument.

Financial risk. The risk of a possible future change in one or more of a specified interest rate, financial instrument price, commodity price, foreign exchange rate, index of prices or rates, credit rating or credit index or other variable, provided in the case of a non-financial variable that the variable is not specific to a party to the contract.

Guaranteed benefits. Payments or other benefits to which a particular policyholder or investor has an unconditional right that is not subject to the contractual discretion of the issuer.

Guaranteed element. An obligation to pay guaranteed benefits, included in a contract that contains a discretionary participation feature.

Insurance asset. An insurer's net contractual rights under an insurance contract.

Insurance contract. A contract under which one party (the insurer) accepts significant insurance risk from another party (the policyholder) by agreeing to compensate the policyholder if a specified uncertain future event (the insured event) adversely affects the policyholder.

Insurance liability. An insurer's net contractual obligations under an insurance contract.

Insurance risk. Risk, other than financial risk, transferred from the holder of a contract to the issuer.

Insured event. An uncertain future event that is covered by an insurance contract and creates insurance risk.

Insurer. The party that has an obligation under an insurance contract to compensate a policyholder if an insured event occurs.

Liability adequacy test. An assessment of whether the carrying amount of an insurance liability needs to be increased (or the carrying amount of related deferred acquisition costs or related intangible assets decreased), based on a review of future cash flows.

Policyholder. A party that has a right to compensation under an insurance contract if an insured event occurs.

Reinsurance assets. A cedant's net contractual rights under a reinsurance contract.

Reinsurance contract. An insurance contract issued by one insurer (the reinsurer) to compensate another insurer (the cedant) for losses on one or more contracts issued by the cedant.

Reinsurer. The party that has an obligation under a reinsurance contract to compensate a cedant if an insured event occurs.

Unbundle. Account for the components of a contract as if they were separate contracts.

Insurance Contracts

An insurance contract is defined in IFRS 4 as a contract under which one party (the insurer) accepts significant insurance risk from another party (the policyholder) by agreeing to compensate the policyholder if a specified uncertain future event (the insured event) adversely affects the policyholder.

A contract creates sufficient insurance risk to qualify as an insurance contract only if there is a reasonable possibility that an event affecting the policyholder or other beneficiary will cause a significant change in the present value of the insurer's net cash flows arising from that contract. In considering whether there is a reasonable possibility of such significant change, it is necessary to consider the probability of the event and the magnitude of its effect. Also, a contract that qualifies as an insurance contract at inception or later remains an insurance contract until all rights and obligations are extinguished or expire. If a contract did not qualify as an insurance contract at inception, it should be subsequently reclassified as an insurance contract if, and only if, a significant change in the present value of the insurer's net cash flows becomes a reasonable possibility.

A range of other arrangements, which share certain characteristics with insurance contracts, would be excluded from any imposed insurance contracts accounting standard, since they are dealt with under other standards. These include financial guarantees (including credit insurance) measured at fair value; product warranties issued directly by a manufacturer, dealer or retailer; employers' assets and liabilities under employee benefit plans (including equity compensation plans); retirement benefit obligations reported by defined benefit retirement plans; contingent consideration payable or receivable in a business combination; and contractual rights or contractual obligations that are contingent on the future use of, or right to use, a non-financial item (for example, certain licence fees, royalties, lease payments and similar items).

IFRS 4 applies to all insurance contracts, including reinsurance. Thus, the standard does not relate only to insurance companies, but all entities engaging in insurance contracts.

IFRS 4 does not apply to product warranties issued directly by a manufacturer, dealer or retailer; employers' assets and liabilities under employee benefit plans and retirement benefit obligations reported by defined benefit retirement plans; contractual rights or obligations that are contingent on the future use of or right to use a non-financial item, as well as lessee's residual value guarantees on finance leases; financial guarantees entered into or retained on transferring financial assets or financial liabilities within the scope of IFRS 9; contingent consideration payable or receivable in a business combination; or direct insurance contracts that an entity holds as a policyholder.

Insurance Risk

IFRS 4 replaces what had been an indirect definition of an insurance contract under IAS 32 with a positive definition based on the transfer of significant insurance risk from the policyholder to the insurer. This definition covers most motor, travel, life, annuity, medical, property, reinsurance and professional indemnity contracts. Some catastrophe bonds and weather derivatives would also qualify, as long as payments are linked to a specific climatic or other insured future event that would adversely affect the policyholder. On the other hand, policies that transfer no significant insurance risk—such as some savings and pensions plans—will be deemed financial instruments, addressed by IFRS 9, regardless of their legal form. IFRS 9 also applies to contracts that principally transfer financial risk, such as credit derivatives and some forms of financial reinsurance.

There may be some difficulty in classifying the more complex products (including certain hybrids). To facilitate this process, the IASB has explained that insurance risk will be deemed significant only if an insured event could cause an insurer to pay significant additional benefits in any scenario, apart from a scenario that lacks commercial substance. As a practical matter, reporting entities should compare the cash flows from (1) the occurrence of the insured event against (2) all other events. If the cash flows under the former are significantly larger than under the latter, significant insurance risk is present.

For example, when the insurance benefits payable upon death are significantly larger than the benefits payable upon surrender or maturity, there is significant insurance risk. The significance of the additional benefits is to be measured irrespective of the probability of the insured event, if the scenario has commercial substance. Reporting entities have to develop internal quantitative guidance to ensure the definition is applied consistently throughout the entity. To qualify as significant, the insurance risk also needs to reflect a pre-existing risk for the policyholder, rather than having arisen from the terms of the contract.

This requirement would specifically exclude from the cash flow comparison features such as waivers of early redemption penalties within investment plans or mortgages in the event of death. Since it is the contract itself that brought the charges into place, the waiver does not represent an additional benefit received for the transfer of a pre-existing insurance risk.

The application of this IFRS 4 definition may result in the redesignation of a significant fraction of existing insurance contracts as investment contracts. In other situations, the impact could be the opposite. For example, a requirement to pay benefits earlier if an insured event occurs could make a contract insurance; this means that many pure endowment contracts are likely to meet the definition of insurance. All told, insuring entities will need to set clear, consistent and justifiable contract classification criteria and rigorously apply these.

Recognition and Measurement Guidance

Adequacy of Insurance Liabilities

IFRS 4 imposes a liability adequacy test, which requires that at each reporting date the “insurer” must assess whether its recognised insurance liabilities are adequate, using then-current estimates of future cash flows under the outstanding insurance contracts. If as a result of that assessment it is determined that the carrying amount of insurance liabilities (less related deferred acquisition costs and related intangible assets, if appropriate—see discussion below) is insufficient given the estimated future cash flows, the full amount of such deficiency must be reported currently in earnings.

The standard defines minimum requirements for the adequacy test that is to be applied to the liability account. These minimum requirements are that:

  1. The test considers the current estimates of all contractual cash flows, and of such related cash flows as claims handling costs, as well as cash flows that will result from embedded options and guarantees.
  2. If the test shows that the liability is inadequate, the entire deficiency is recognised in profit or loss.

In situations where the insuring entity's accounting policies do not require a liability adequacy test, or provides for a test that does not meet the minimum requirements noted above, then the entity is required under IFRS 4 to:

  1. Determine the carrying amount of the relevant insurance liabilities, less the carrying amount of:
    1. Any related deferred acquisition costs; and
    2. Any related intangible assets, such as those acquired in a business combination or portfolio transfer. However, related reinsurance assets are not considered because an insurer accounts for them separately.
  2. Determine whether the carrying amount of the relevant net insurance liabilities is less than the carrying amount that would be required if the relevant insurance liabilities were within the scope of IAS 37. If it is less, the insurer shall recognise the entire difference in profit or loss and decrease the carrying amount of the related deferred acquisition costs or related intangible assets or increase the carrying amount of the relevant insurance liabilities.

The IAS 37-based amount is the required minimum liability to be presented. Therefore, if the current carrying amount is less, the insuring entity must recognise the entire shortfall in current period earnings. The corresponding credit to this loss recognition will either decrease the carrying amount of the related deferred acquisition costs or related intangible assets or increase the carrying amount of the relevant insurance liabilities, or both, dependent upon the facts and circumstances.

In applying the foregoing procedures, any related reinsurance assets are not considered, because an insuring entity accounts for these separately, as noted later in this discussion.

If an insuring entity's liability adequacy test meets the minimum requirements set forth above, this test is applied at the level of aggregation specified above. On the other hand, if the liability adequacy test does not meet the stipulated minimum requirements, the comparison must instead be made at the level of a portfolio of contracts that are subject to broadly similar risks and which are managed together as a single portfolio.

For purposes of comparing the recorded liability to the amount required under IAS 37, it is acceptable to reflect future investment margins only if the carrying amount of the liability also reflects those same margins. Future investment margins are defined under IFRS 4 as being employed if the discount rate used reflects the estimated return on the insuring entity's assets, or if the returns on those assets are projected at an estimated rate of return, and discounted at a different rate, with the result included in the measurement of the liability. There is a rebuttable presumption that future investment margins should not be used, however, although exceptions (see below) can exist.

Impairment Testing of Reinsurance Assets

When an insuring entity obtains reinsurance (making it the cedant), an asset is created in its financial statements. As with other assets, the reporting entity must consider whether an impairment has occurred as of the reporting date. Under IFRS 4, a reinsurance asset is impaired only when there is objective evidence that the cedant may not receive all amounts due to it under the terms of the contract, as a consequence of an event that occurred after initial recognition of the reinsurance asset, and furthermore the impact of that event is reliably measurable in terms of the amounts that the cedant will receive from the reinsurer.

When the reinsurance asset is found to be impaired, the carrying amount is adjusted downward and a loss is recognised in current period earnings for the full amount.

Selection of Accounting Principles

IFRS requires certain accounting practices to be adopted with regard to insurance contracts, but also allows other, existing procedures to remain in place under defined conditions. An insuring entity may, under provisions of IFRS 4, change accounting policies for insurance contracts only if such change makes the financial statements more relevant to the economic decision-making needs of users and no less reliable, or more reliable and no less relevant to those needs. Relevance and reliability are to be assessed by applying the criteria set forth in IAS 8.

To justify changing its accounting policies for insurance contracts, an insuring entity must demonstrate that the change brings its financial statements nearer to satisfying the criteria of IAS 8, but the change does not necessarily have to achieve full compliance with those criteria. The standard addresses changes in accounting policies in the context of current interest rates; continuation of existing reporting practices; prudence; future investment margins; and “shadow accounting.” These are discussed in the following paragraphs.

Regarding interest rates, IFRS 4 provides that an insuring entity is permitted, although it is not required, to change its accounting policies such that it remeasures designated insurance liabilities to reflect current market interest rates, and recognises changes in those liabilities in current period earnings. It may also adopt accounting policies that require other current estimates and assumptions for the designated liabilities. IFRS 4 permits an insuring entity to change its accounting policies for designated liabilities, without consistently applying those policies to all similar liabilities, as the requirements under IAS 8 would suggest. If the insuring entity designates liabilities for this policy choice, it must continue to apply current market interest rates consistently in all periods to all these liabilities until they are later eliminated.

An unusual feature of IFRS 4 is that it offers affected reporting entities the option to continue with their existing accounting policies. Specifically, an insuring entity is allowed to continue the following practices if in place prior to the effective date of IFRS 4:

  1. Measuring insurance liabilities on an undiscounted basis.
  2. Measuring contractual rights to future investment management fees at an amount that exceeds their fair value as implied by a comparison with current fees charged by other market participants for similar services. It is likely that the fair value at inception of those contractual rights equals the origination costs paid, unless future investment management fees and related costs are out of line with market comparables.
  3. Employing non-uniform accounting policies for the insurance contracts (and related deferred acquisition costs and intangible assets, if any) of subsidiaries, except as permitted by the above-noted interest provision. If those accounting policies are not uniform, the insuring entity may change them if the change does not make the accounting policies more diverse, and also satisfies the other requirements of the standard.

The concept of prudence, as set forth in IFRS 4, is meant to excuse an insuring entity from a need to change its accounting policies for insurance contracts in order to eliminate excessive prudence (i.e., conservatism). However, if the insuring entity already measures its insurance contracts with sufficient prudence, it is not permitted to introduce additional prudence following adoption of IFRS 4.

The matter of future investment margins requires some explanation. Under IFRS 4 it is clearly preferred that the measurement of insurance contracts should not reflect future investment margins, but the standard does not require reporting entities to change accounting policies for insurance contracts to eliminate future investment margins. On the other hand, adopting a policy that would reflect this is presumed to be improper (the standard states that there is a rebuttable presumption that the financial statements would become less relevant and reliable if an accounting policy that reflects future investment margins in the measurement of insurance contracts is adopted, unless those margins affect the contractual payments). The standard offers two examples of accounting policies that reflect those margins. The first is using a discount rate that reflects the estimated return on the insurer's assets, while the second is projecting the returns on those assets at an estimated rate of return, discounting those projected returns at a different rate and including the result in the measurement of the liability.

IFRS 4 states that the insuring entity could possibly overcome this rebuttable presumption if the other components of a change in accounting policies increase the relevance and reliability of its financial statements sufficiently to outweigh the decrease in relevance and reliability caused by the inclusion of future investment margins. As an example, it cites the situation where the existing accounting policies for insurance contracts involve excessively prudent (i.e., conservative) assumptions set at inception, and a statutory discount rate not directly referenced to market conditions, and ignore some embedded options and guarantees. This entity might make its financial statements more relevant and no less reliable by switching to a comprehensive investor-oriented basis of accounting that is widely used and involves current estimates and assumptions; a reasonable (but not excessively prudent) adjustment to reflect risk and uncertainty; measurements that reflect both the intrinsic value and time value of embedded options and guarantees; and a current market discount rate, even if that discount rate reflects the estimated return on the insuring entity's assets.

The actual ability to overcome IFRS 4's rebuttable presumption is fact dependent. Thus, in some measurement approaches, the discount rate is used to determine the present value of a future profit margin, which is then attributed to different periods using a formula. In such approaches, the discount rate affects the measurement of the liability only indirectly, and the use of a less appropriate discount rate has limited or no effect on the measurement of the liability at inception. In yet other approaches, the discount rate determines the measurement of the liability directly, and because the introduction of an asset-based discount rate has a more significant effect, it is highly unlikely that an insurer could overcome the rebuttable presumption noted above.

Finally, there is the matter of shadow accounting. According to IFRS 4, an insurer is permitted, but not required, to change its accounting policies so that a recognised but unrealised gain or loss on an asset affects those measurements in the same way that a realised gain or loss does. This is because, under some accounting models, realised gains or losses on an insurer's assets have a direct effect on the measurement of some or all of (1) its insurance liabilities; (2) related deferred acquisition costs; and (3) related intangible assets. IFRS 4 provides that the related adjustment to the insurance liability (or deferred acquisition costs or intangible assets) may be recognised in equity if, and only if, the unrealised gains or losses are recognised directly in equity.

Unbundling

Specific requirements pertain to unbundling of elements of insurance contracts, and dealing with embedded derivatives, options and guarantees.

Unbundling refers to the accounting for components of a contract as if they were separate contracts. Some insurance contracts consist of an insurance component and a deposit component. IFRS 4 in some cases requires the reporting entity to unbundle those components, and in other fact situations provides the entity with the option of unbundled accounting. Specifically, unbundling is required if both the following conditions are met:

  1. The insuring entity can measure the deposit component (inclusive of any embedded surrender options) separately (i.e. without considering the insurance component); and
  2. The insuring entity's accounting policies do not otherwise require it to recognise all obligations and rights arising from the deposit component.

On the other hand, unbundling is permitted, but not required, if the insuring entity can measure the deposit component separately but its accounting policies require it to recognise all obligations and rights arising from the deposit component, regardless of the basis used to measure those rights and obligations.

Unbundling is actually prohibited if an insuring entity cannot measure the deposit component separately.

If unbundling is applied to a contract, the insuring entity applies IFRS 4 to the insurance component of the contract, while using IFRS 9 to account for the deposit component of that contract.

Recognition

IFRS 4 prohibits the recognition of a liability for any provisions for possible future claims, if those claims arise under insurance contracts that are not in existence at the reporting date. Catastrophe and equalisation provisions are thus prohibited, because they do not reflect loss events that have already occurred and therefore recognition would be inconsistent with IAS 37. Loss recognition testing is required for losses already incurred at each date of the statement of financial position, as described above. An insurance liability (or a part of an insurance liability) is to be removed from the statement of financial position only when it is extinguished (i.e., when the obligation specified in the contract is discharged or cancelled, or expires).

In terms of display, offsetting of reinsurance assets against the related insurance liabilities is prohibited, as is offsetting of income or expense from reinsurance contracts against the expense or income from the related insurance contracts.

Discretionary Participation Features in Insurance Contracts

Insurance contracts sometimes contain a discretionary participation feature, as well as a guaranteed element. (That is, some portion of the return to be accrued to policyholders is at the discretion of the insuring entity.) Under the provisions of IFRS 4, the issuer of such a contract may, but is not required to, recognise the guaranteed element separately from the discretionary participation feature. If the issuer does not recognise them separately, it must classify the entire contract as a liability. If, on the other hand, the issuer classifies them separately, it will classify the guaranteed element as a liability. If the entity recognises the discretionary participation feature separately from the guaranteed element, the discretionary participation feature can be classified either as a liability or as a separate component of equity; the standard does not specify how the decision should be reached. In fact, the issuer may even split that feature into liability and equity components, if a consistent accounting policy is used to determine that split.

When there is a discretionary participation feature which is reported in equity, the reporting entity is permitted to recognise all premiums received as revenue, without separating any portion that relates to the equity component. Changes in the guaranteed element and in the portion of the discretionary participation feature classified as a liability are to be reported in earnings, while changes in the part of the discretionary participation feature classified as equity are to be accounted for as an allocation of earnings, similar to how minority interest is reported.

Embedded Derivatives

If the contract contains an embedded derivative within the scope of IFRS 9, that standard must be applied to that embedded derivative.

Disclosure

Under the provisions of IFRS 4, insuring entities must disclose information that identifies and explains the amounts in its financial statements arising from insurance contracts. This is accomplished by disclosure of accounting policies for insurance contracts and related assets, liabilities, income and expense; of recognised assets, liabilities, income and expense (and, if it presents its statement of cash flows using the direct method, cash flows) arising from insurance contracts. Additionally, if the insuring entity is a cedant, it must also disclose gains and losses recognised in profit or loss on buying reinsurance; and, if the cedant defers and amortises gains and losses arising on buying reinsurance, the amortisation for the period and the amounts remaining unamortised at the beginning and end of the period.

Disclosure is also required of the process used to determine the assumptions that have the greatest effect on the measurement of the recognised amounts described above. When practicable, quantified disclosure of those assumptions is to be presented as well. The effect of changes in assumptions used to measure insurance assets and insurance liabilities is required, reporting separately the effect of each change that has a material effect on the financial statements.

Finally, reconciliation of changes in insurance liabilities, reinsurance assets and, if any, related deferred acquisition costs are mandated by IFRS 4.

Regarding the amount, timing and uncertainty of cash flows, the entity is required to disclose information that helps users to understand these matters as they result from insurance contracts. This is accomplished if the insuring entity discloses its objectives in managing risks arising from insurance contracts and its policies for mitigating those risks.

Applying IFRS 9 with IFRS 4

IFRS 4 was amended September 2016 to create a temporary exception for insurers to remain applying IAS 39 rather than IFRS 9 for annual periods beginning before 1 January 2021, if the insurer's activities are predominantly connected with insurance. If the entities activities are not predominantly connected with insurance, an overlay approach may be applied, under which the difference between the IFRS 9 and IAS 39 treatment is recognised in other comprehensive income.

The temporary exemptions from IFRS 9 and the overlay approach are also available to an issuer of a financial instrument that contains a discretionary participation feature.

Temporary Exemption from IFRS 9

An insurer may apply the temporary exemption from IFRS 9 if it has not previously applied any version of IFRS 9 (except for applying the requirement in IFRS 9 that the effect of changes in credit risk of a liability are recognised in other comprehensive income for financial liability designated at fair value through profit or loss) and its activities are predominantly connected with insurance, at its annual reporting date that immediately precedes 1 April 2016, or at a subsequent annual reporting date specified.

After April 1, 2016 an entity applying the temporary exception should reassess whether its activities are predominantly connected with insurance at a subsequent annual reporting date if there was a change in the entity's activities. An entity that previously did not qualify for the temporary exemption from IFRS 9 is permitted to reassess whether its activities are predominantly connected with insurance at subsequent annual reporting dates before 31 December 2018 only if there was a change in the entity's activities during that annual period. The standard provides additional guidance on what constitutes a change in an entity's activities.

If an entity no longer qualifies for the temporary exemption from IFRS 9 as a result of a reassessment, then the entity is permitted to continue to apply the temporary exemption from IFRS 9 only until the end of the annual period that began immediately after that reassessment. An insurer that previously elected to apply the temporary exemption from IFRS 9 may at the beginning of any subsequent annual period irrevocably elect to apply IFRS 9.

An entity applying the temporary exception from IFRS 9 may apply the requirement in IFRS 9 that the effect of changes in credit risk of a liability are recognised in other comprehensive income for financial liability designated at fair value through profit or loss.

An insurer's activities are predominantly connected with insurance if:

  1. The carrying amount of its liabilities arising from contracts within the scope of IFRS 4, which includes any deposit components or embedded derivatives unbundled from insurance contracts, is significant compared to the total carrying amount of all its liabilities; and
  2. The percentage of the total carrying amount of its liabilities connected with insurance relative to the total carrying amount of all its liabilities is:
    1. Greater than 90%; or
    2. Less than or equal to 90% but greater than 80%, and the insurer does not engage in a significant activity unconnected with insurance. The standard provides further guidance on assessing whether an entity engages in significant unconnected activities.

Liabilities connected with insurance comprise:

  1. Liabilities arising from contracts within the scope of IFRS 4;
  2. Non-derivative investment contract liabilities measured at fair value through profit or loss applying IAS 39 (including those designated as at fair value through profit or loss to which the insurer has applied the requirements in IFRS 9 for the presentation of gains and losses); and
  3. Liabilities that arise because the insurer issues, or fulfils obligations arising from, the above contracts. Examples of such liabilities include derivatives used to mitigate risks arising from those contracts and from the assets backing those contracts, relevant tax liabilities such as the deferred tax liabilities for taxable temporary differences on liabilities arising from those contracts and debt instruments issued that are included in the insurer's regulatory capital.

A first-time adopter of IFRS may apply the temporary exemption from IFRS 9 if it meets the criteria for applying the temporary exemption as described above.

Situations may exist where an insurer applies the temporary exceptions from IFRS 9 but its associates or joint ventures do not, or vice versa. For annual periods beginning before 1 January 2021, the entity is permitted to retain the relevant accounting policies applied by the associate or joint venture as follows:

  1. The entity applies IFRS 9 but the associate or joint venture applies the temporary exemption from IFRS 9; or
  2. The entity applies the temporary exemption from IFRS 9 but the associate or joint venture applies IFRS 9.

An entity may apply the requirements separately for each associate or joint venture.

When an entity uses the equity method to account for its investment in an associate or joint venture:

  1. IFRS 9 shall continue to be applied, if it was previously applied in the financial statements used to apply the equity method to that associate or joint venture (after reflecting any adjustments made by the entity).
  2. IFRS 9 might be subsequently applied, if the temporary exemption from IFRS 9 was previously applied in the financial statements used to apply the equity method to that associate or joint venture (after reflecting any adjustments made by the entity).

An entity may apply the requirements above separately for each associate or joint venture.

Disclosures about the temporary exemption from IFRS 9

The disclosure objective for an insurer that elects to apply the temporary exemption from IFRS 9 is to disclose information to enable users of financial statements:

  1. To understand how the insurer qualified for the temporary exemption; and
  2. To compare insurers applying the temporary exemption with entities applying IFRS 9.

To achieve this disclosure objective, an insurer shall disclose:

  1. The fact that it is applying the temporary exemption from IFRS 9 and how the insurer concluded that it qualified for the temporary exemption from IFRS 9, including:
    1. If the carrying amount of its liabilities arising from contracts within the scope of this IFRS was less than or equal to 90% of the total carrying amount of all its liabilities, the nature and carrying amounts of the liabilities connected with insurance that are not liabilities arising from contracts within the scope of this IFRS;
    2. If the percentage of the total carrying amount of its liabilities connected with insurance relative to the total carrying amount of all its liabilities was less than or equal to 90% but greater than 80%, how the insurer determined that it did not engage in a significant activity unconnected with insurance, including what information it considered; and
    3. If the insurer qualified for the temporary exemption from IFRS 9 on the basis of a reassessment:
      1. The reason for the reassessment;
      2. The date on which the relevant change in its activities occurred; and
      3. A detailed explanation of the change in its activities and a qualitative description of the effect of that change on the insurer's financial statements.
  2. If an entity concludes that its activities are no longer predominantly connected with insurance, the following information in each reporting period before it begins to apply IFRS 9:
    1. The fact that it no longer qualifies for the temporary exemption from IFRS 9;
    2. The date on which the relevant change in its activities occurred and a detailed explanation of the change in its activities; and
    3. A qualitative description of the effect of that change on the entity's financial statements.
  3. To comply, the fair value at the end of the reporting period and the amount of change in the fair value during that period for the following two groups of financial assets separately:
    1. Financial assets with contractual terms that give rise on specified dates to cash flows that are solely payments of principal and interest on the principal amount outstanding, excluding any financial asset that meets the definition of held for trading in IFRS 9, or that is managed and whose performance is evaluated on a fair value basis;
    2. All financial assets other than those specified in paragraph 3.a. above; that is, any financial asset:
      1. With contractual terms that do not give rise on specified dates to cash flows that are solely payments of principal and interest on the principal amount outstanding;
      2. That meets the definition of held for trading in IFRS 9; or
      3. That is managed and whose performance is evaluated on a fair value basis.
  4. When disclosing the information in point 3., the insurer:
    1. May deem the carrying amount of the financial asset measured applying IAS 39 to be a reasonable approximation of its fair value if the insurer is not required to disclose its fair value applying IFRS 7 (e.g., short-term trade receivables); and
    2. Shall consider the level of detail necessary to enable users of financial statements to understand the characteristics of the financial assets.
  5. Information about the credit risk exposure, including significant credit risk concentrations inherent in the financial assets. At a minimum, an insurer shall disclose the following information for those financial assets at the end of the reporting period:
    1. By credit risk rating grades as defined in IFRS 7, the carrying amounts applying IAS 39 (in the case of financial assets measured at amortised cost, before adjusting for any impairment allowances).
    2. For the financial assets that do not have low credit risk at the end of the reporting period, the fair value and the carrying amount applying IAS 39 (in the case of financial assets measured at amortised cost, before adjusting for any impairment allowances). IFRS 9 provides the relevant requirements for assessing whether the credit risk on a financial instrument is considered low.
  6. Information about where a user of financial statements can obtain any publicly available IFRS 9 information that relates to an entity within the group that is not provided in the group's consolidated financial statements for the relevant reporting period. For example, such IFRS 9 information could be obtained from the publicly available individual or separate financial statements of an entity within the group that has applied IFRS 9.
  7. The fact that an entity elected to apply the exemption from uniform accounting policy requirements in IAS 28 for associates and joint ventures.
  8. If an entity applied the temporary exemption from IFRS 9 when accounting for its investment in an associate or joint venture using the equity method, the following, in addition to the information required by IFRS 12, Disclosure of Interests in Other Entities:
    1. The information described in the disclosure paragraphs above for each associate or joint venture that is material to the entity. The amounts disclosed shall be those included in the IFRS financial statements of the associate or joint venture after reflecting any adjustments made by the entity when using the equity method, rather than the entity's share of those amounts.
    2. The quantitative information described above in aggregate for all individually immaterial associates or joint ventures. The aggregate amounts:
      1. Disclosed shall be the entity's share of those amounts; and
      2. For associates shall be disclosed separately from the aggregate amounts disclosed for joint ventures.

The Overlay Approach

An insurer is permitted to apply the overlay approach to designated financial assets. An insurer that applies the overlay approach shall:

  1. Reclassify between profit or loss and other comprehensive income an amount that results in the profit or loss at the end of the reporting period for the designated financial assets being the same as if the insurer had applied IAS 39 to the designated financial assets. Accordingly, the amount reclassified is equal to the difference between:
    1. The amount reported in profit or loss for the designated financial assets applying IFRS 9; and
    2. The amount that would have been reported in profit or loss for the designated financial assets if the insurer had applied IAS 39.
  2. Apply all other applicable IFRS to its financial instruments.

An insurer may elect to apply the overlay approach only when it first applies IFRS 9. An insurer may also apply the overlay approach if the temporary exception from IFRS 9 is no longer available because the insurers' activities are no longer predominantly connected with insurance.

An insurer shall present the amount reclassified between profit or loss and other comprehensive income applying the overlay approach:

  1. In profit or loss as a separate line item; and
  2. In other comprehensive income as a separate component of other comprehensive income.

A financial asset is eligible for designation for the overlay approach if the following criteria are met:

  1. It is measured at fair value through profit or loss applying IFRS 9 but would not have been measured at fair value through profit or loss in its entirety applying IAS 39; and
  2. It is not held in respect of an activity that is unconnected with contracts within the scope of IFRS 4. Examples of financial assets that would not be eligible for the overlay approach are those assets held in respect of banking activities or financial assets held in funds relating to investment contracts that are outside the scope of IFRS 4.

An insurer may designate an eligible financial asset for the overlay approach when it elects to apply the overlay approach. An insurer is permitted to designate eligible financial assets for the overlay approach on an instrument-by-instrument basis. Subsequently, it may designate an eligible financial asset for the overlay approach when:

  1. That asset is initially recognised; or
  2. That asset is held in respect of an activity that connected with contracts within the scope of this IFRS 4 for the first time.

When relevant, for the purposes of applying the overlay approach to a newly designated financial asset in point 2., above:

  1. Its fair value at the date of designation shall be its new amortised cost carrying amount; and
  2. The effective interest rate shall be determined based on its fair value at the date of designation.

An entity shall continue to apply the overlay approach to a designated financial asset until that financial asset is derecognised. However, an entity:

  1. Shall de-designate a financial asset when the financial asset is no longer held in respect of an activity that is connected with contracts within the scope of IFRS 4. For example, a financial asset will no longer meet that criterion when an entity transfers that asset so that it is held in respect of its banking activities or when an entity ceases to be an insurer.
  2. May, at the beginning of any annual period, stop applying the overlay approach to all designated financial assets. An entity that elects to stop applying the overlay approach shall apply IAS 8 to account for the change in accounting policy.

When an entity de-designates a financial asset, it shall reclassify from accumulated other comprehensive income to profit or loss as a reclassification adjustment any balance relating to that financial asset.

If an entity stops using the overlay approach applying by election or because it is no longer an insurer, it shall not subsequently apply the overlay approach. An insurer that has elected to apply the overlay approach but has no eligible financial assets may subsequently apply the overlay approach when it has eligible financial assets.

Disclosures About the Overlay Approach

The disclosure objective is that an insurer that applies the overlay approach shall disclose information to enable users of financial statements to understand:

  1. How the total amount reclassified between profit or loss and other comprehensive income in the reporting period is calculated; and
  2. The effect of that reclassification on the financial statements.

To achieve the disclosure objective, an insurer shall disclose:

  1. The fact that it is applying the overlay approach.
  2. The carrying amount at the end of the reporting period of financial assets to which the insurer applies the overlay approach by class of financial asset.
  3. The basis for designating financial assets for the overlay approach, including an explanation of any designated financial assets that are held outside the legal entity that issues contracts within the scope of this IFRS.
  4. An explanation of the total amount reclassified between profit or loss and other comprehensive income in the reporting period in a way that enables users of financial statements to understand how that amount is derived, including:
    1. The amount reported in profit or loss for the designated financial assets applying IFRS 9; and
    2. The amount that would have been reported in profit or loss for the designated financial assets if the insurer had applied IAS 39.
  5. The effect of the reclassification between profit or loss and other comprehensive income on each affected line item in profit or loss.
  6. If during the reporting period the insurer has changed the designation of financial assets:
    1. The amount reclassified between profit or loss and other comprehensive income in the reporting period relating to newly designated financial assets applying the overlay approach;
    2. The amount that would have been reclassified between profit or loss and other comprehensive income in the reporting period if the financial assets had not been de-designated; and
    3. The amount reclassified in the reporting period to profit or loss from accumulated other comprehensive income for financial assets that have been de-designated.

If an entity applied the overlay approach when accounting for its investment in an associate or joint venture using the equity method, the entity shall disclose the following, in addition to the information required by IFRS 12:

  1. The information described above for each associate or joint venture that is material to the entity. The amounts disclosed shall be those included in the IFRS financial statements of the associate or joint venture after reflecting any adjustments made by the entity when using the equity method, rather than the entity's share of those amounts.
  2. The quantitative information described above, and the effect of the reclassification on profit or loss and other comprehensive income in aggregate for all individually immaterial associates or joint ventures. The aggregate amounts:
    1. Disclosed shall be the entity's share of those amounts; and
    2. For associates shall be disclosed separately from the aggregate amounts disclosed for joint ventures.

Interaction with Other Requirements

Reclassifying an amount between profit or loss and other comprehensive income applying the overlay approach may have consequential effects for including other amounts in other comprehensive income, such as income taxes. An insurer shall apply the relevant IFRS, such as IAS 12, Income Taxes, to determine any such consequential effects.

If a first-time adopter elects to apply the overlay approach, it shall restate comparative information to reflect the overlay approach if, and only if, it restates comparative information to comply with IFRS 9.

Transitional Provisions

Temporary Exemption from IFRS 9

The temporary exemption from IFRS 9, is for annual periods beginning on or after 1 January 2018. An entity that discloses the information required for this temporary exemption from IFRS 9 shall use the transitional provisions in IFRS 9 that are relevant to making the assessments required for those disclosures. The date of initial application for that purpose shall be deemed to be the beginning of the first annual period beginning on or after 1 January 2018.

The Overlay Approach

An entity shall apply the amendments, which permit insurers to apply the overlay approach to designated financial assets, when it first applies IFRS 9. An entity that elects to apply the overlay approach shall:

  1. Apply that approach retrospectively to designated financial assets on transition to IFRS 9. Accordingly, for example, the entity shall recognise as an adjustment to the opening balance of accumulated other comprehensive income an amount equal to the difference between the fair value of the designated financial assets determined applying IFRS 9 and their carrying amount determined applying IAS 39.
  2. Restate comparative information to reflect the overlay approach if, and only if, the entity restates comparative information applying IFRS 9.

Future Developments

IFRS 17 Insurance Contracts

IFRS 17, Insurance Contracts, was issued May 2017 to create a comprehensive standard to deal with the identification, recognition, measurement, presentation and disclosure of insurance contracts. IFRS 17 is effective for annual reporting periods beginning on or after 1 January 2021. IFRS 17 will replace IFRS 4. Earlier adoption is permitted provided that the entity also applies IFRS 9, Financial Instruments, and IFRS 15, Revenue from Contracts with Customers, on or before the date of initial application of IFRS 17.

The approach in IFRS 17 is based on the principle that insurance contracts create a bundle of rights and obligations that work together to generate a package of cash inflows (premiums) and outflows (benefits and claims). An insurer would apply to that package of cash flows a measurement approach that uses the following building blocks:

  1. A current estimate of the expected future net cash flows from premiums, claims, benefits and expenses.
  2. An explicit risk adjustment for uncertainty about the amount of future cash flows.
  3. A discount rate that adjusts those cash flows for the time value of money.
  4. A contract service margin.

The first three building blocks are regarded to be the fulfilment cash flows and the contract service margin reflects the entity's risk-adjusted expected profit from the contract. The contract services eliminate the recognition of any gain at inception of the contract. The contractual service margin is therefore the unearned profits on the contract and is reduced as the profits are earned over the duration of the contract. The contract service margin is updated for changes in future service-related estimations.

US GAAP Comparison

The US GAAP guidance on insurance contracts covers insurance activities, acquisition costs, claim costs and liabilities for future policy benefits, policyholder dividends and separate accounts. Four methods of recognition for premium revenue and contract liabilities are developed: short-duration contract accounting and three methods for long-duration contract accounting, which are traditional, universal life and participating contracts. Generally, the four methods reflect the nature of the insurance entity's obligations and policyholder rights under the provisions of the contract. Acquisition costs are amortised over the life of the policy and subject to impairment based on the adequacy of premiums for policies in light of circumstances at the balance sheet date.

Short-duration contracts, which are for a short period, usually one year, generally require revenue recognition on a straight-line basis. Long-duration contracts, in most cases, require offsetting of receivables or cash against unrecognised revenue. This revenue is recognised commensurate with the risk insured. Another feature of long-duration contract accounting is that for each reporting period, liabilities for coverage risk are assessed and increased if needed. The offset is recognised in the current period expense.

US GAAP also covers accounting for reinsurance contracts. These arrangements transfer some or all of the risk of insurance to a third party (not the insured). Generally, the accounting is similar to insurance contracts, although there are specific criteria for determining if the original insurer has transferred the risks to the reinsurer.

The concept of separate accounts specifies accounting when assets are specifically segregated for a particular policyholder, for example, variable annuity contracts that guarantee some minimum level of benefits.

The FASB issued a proposed Accounting Standards Update, Insurance Contracts (Topic 834), in June 2013. Redeliberations based on feedback from the exposure document are under way. The proposed Update would improve convergence of US GAAP and IFRS. The proposals contain similar fundamentals, most notably the use of current estimates, but differences exist. The proposal and a detailed comparison with the IFRS proposal is available at ifrs.org.

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