Solvency II 2027 – SNCU classification, QRT report and proportionality decision | Word/PDF/Excel

Is your insurance company small enough and non-complex enough to be covered by the new proportionality rules in Solvency II? Prepare a source-tracked classification assessment, gather relevant QRT supporting documentation, test the grounds for exclusion, draft an internal version of the notification to the Swedish Financial Supervisory Authority (FI), and document management's decision on any simplifications.

New for 2026/2027: EU Directive 2025/2 introduces the category of small and non-complex undertakings (SNCU). In Sweden, a government bill was published on November 6, 2026, with the proposed effective date of May 1, 2027. The Swedish reform is not finalized as of November 12, 2026. The product is therefore expressly a readiness package, not an already applicable simplification decision or a completed FI form.

Who Is the Package For?

For Swedish insurance and reinsurance companies covered by Solvency II, as well as their risk, actuarial, compliance, and reporting functions. The package is used, for example, before an internal decision to prepare the notification under Article 29b or before choosing proportionality measures under Articles 29c–29e. Group classification may require a separate assessment under Article 213a and is not included as a completed group calculation.

File Overview

Excel – Nine Tabs and Eight Control Counters

Overview, Company Profile, Criteria, QRT Supporting Documentation, Exclusions, Notification, Measures, Monitoring, and Read Me. The criteria tab contains prepared reference questions but no pre-filled results. The compilation counts, among other things, unclear criteria, missing QRT evidence, exclusion flags, FI objections, and blocked measures. The file has been tested with synthetic scenarios and is delivered without customer or test data.

Note: Zero warnings in Excel may mean that no one has registered anything. It is not an approved SNCU classification, an FI decision, or an automated calculation of the solvency capital requirement.

Legal Control – Important Details

Directive (EU) 2025/2 amends the Solvency II Directive (2009/138/EC). Article 29a contains company and risk-based criteria, usually for the two most recent financial years. A special period procedure applies to recently authorized companies. Some companies cannot be classified, for example according to the grounds for exclusion in Article 29a.3. It is therefore not enough to simply be a small insurance company.

Article 29b deals with notification, submitted evidence, a statement on planned strategic changes over three years, and a list of intended proportionality measures. The standard EU objection deadline is two months from a complete notification; a special four-month rule applies to notifications during the first six months from January 30, 2027. Exact Swedish handling should be checked when the law and FI instructions are finalized. Acknowledgment must not be confused with classification.

Articles 29c–29e distinguish between the use of simplifications for classified SNCU companies and, in certain situations, authorization-requiring proportionality measures for other companies. A company's risk profile, solvency capital requirement, and the supervisory authority's position can affect usage. No template provides its own exemption from capital requirements or policyholder protection.

EIOPA published on April 7, 2026 a technical specification on which QRT data should be used for the classification criteria. It should be consulted together with the directive, legal implementing acts, and relevant company-specific information; the package does not contain falsely pre-filled QRT thresholds or an approved classification result.

The Swedish government's government bill, November 6, 2026, proposes changes to Swedish insurance business law from May 1, 2027. The Swedish Financial Supervisory Authority's message November 12, 2026 distinguishes between a guideline that is followed directly and four that are intended to be followed after national adaptation. FI states that EIOPA's guidelines in their legal status are comparable to general recommendations.

Step-by-Step – Recommended Workflow

1. Verify that the insurance company is covered by Solvency II and the correct company/group category.
2. Follow the status of the Swedish implementing law, FI's possible forms, and EIOPA's specifications.
3. Fill the criteria matrix with the correct QRT report, cell code, calculation period, and expert sign-off.
4. Test the grounds for exclusion and store supporting documentation in permission-protected document management.
5. Prepare a draft notification – do not send until Swedish law and FI's channel are confirmed.
6. Decide separately on potential proportionality measures and whether any regulatory approvals are required.
7. Plan recurring review upon a new risk profile, changed ownership, or identified deficiency.

Frequently Asked Questions

Are small insurance companies automatically SNCU?

No. Classification presupposes fulfillment of relevant criteria, checking of grounds for exclusion, and the prescribed supervisory process.

Do the new Swedish rules apply already on November 12, 2026?

No. There is a government bill with a proposed effective date of May 1, 2027. Final national decision and FI instructions must be followed up.

Can we fill in Excel and get an approved/rejected decision?

No. Excel compiles registered work statuses and identifies open questions. It does not calculate statutory SNCU classification.

Is the draft an official FI form?

No. It is an internal working draft that must be adapted to current Swedish law, the authority's instructions, and the company's actual evidence.

Do the same simplifications apply to companies that are not SNCU?

No. Certain measures may require special prior authorization under Article 29d, and the scope must be checked.

Are the PDF files digitally fillable?

No. The PDF files are searchable and printable. Use Word and Excel for editing.

Are the same working templates available in English?

No. The five working templates are in Swedish. An English user guide describes the workflow and terms.

Version, Legal Review, and Delivery

Product Version 1.0 · November 12, 2026 · Jurisdiction Sweden. Official legal sources have been reviewed with AI assistance. No independent external legal review, legal eligibility assessment, solvency calculation validated by the company's QRT data, FI submission, FI decision, or regulatory certification has been performed. Adapt with a trained risk/actuarial and legal function before actual use. The product draft is unpublished and the customer ZIP is not linked to Digital Products in this round.