Public consultation on ICS-related ComFrame standards
Comments due by 5 February 2026 24:00 CET
The consultation includes development of ComFrame material for ICS supervisory reporting (ICP CF 9.4), public disclosure (ICP CF 20.10) and a new paragraph 47 of ComFrame Assessment Methodology
The IAIS has launched a public consultation on the development of ComFrame material for ICS-related standards. The consultation includes material and questions on three elements of the ComFrame:
- ICS supervisory reporting (ICP CF 9.4)
- ICS public disclosure (ICP CF 20.10)
- a new paragraph 47 of ComFrame Assessment Methodology
Background
The Common Framework for the Supervision of internationally active insurance groups (ComFrame) builds upon the Insurance Core Principles (ICPs) and establishes supervisory standards and guidance specifically focused on the effective group-wide supervision of internationally active insurance groups (IAIGs).
The Insurance Capital Standard (ICS), adopted in 2024, forms the quantitative element of ComFrame and has been developed as a consolidated group-wide capital standard for IAIGs. The purpose of the ICS is to create a common language for supervisory discussions of group solvency of IAIGs to enhance global convergence among group capital standards.
Following the adoption of the ICS, the IAIS has developed specific ICS-related supervisory reporting and public disclosure requirements. These ComFrame requirements have been added to ICP 9 (supervisory reporting) and ICP 20 (public disclosure).
Articulation of alignment between supervisory reporting and public disclosure (ICP CF 9.4 and ICP CF 20.10)
While supervisory reporting (CF 9.4) and public disclosure (CF 20.10) serve distinct purposes, there are instances where certain required information is the same. In such cases, the text in CF 9.4 and CF 20.10 has been aligned to ensure consistency as the requirement refers to the same information.
Implementation assessment of the ICS and specificities of the US Aggregation Method
The implementation assessment of the ICS is subject to a specific, supplementary methodology within the ComFrame assessment framework. The ICS implementation assessment methodology is being developed by the IAIS and is subject to the High-Level Principles (HLPs) which were agreed by the IAIS Executive Committee (ExCo) at its June 2025 meeting.
Subsequent to the publication of the HLPs for the ICS Assessment Methodology, the IAIS has resolved that the ICS Assessment Methodology will also cover the ICS-related ComFrame standards on supervisory reporting and public disclosure.
To give effect to these decisions, a new paragraph (paragraph 47) has been added to the ComFrame Assessment Methodology section of the ICP and ComFrame Introduction.
This new paragraph:
- References the ICS Implementation Assessment Methodology as a specific, supplementary methodology within the ComFrame assessment framework;
- States that the ICS Implementation Assessment Methodology also covers the implementation assessment of the ICS-related ComFrame supervisory reporting and disclosure standards; and
- States that the ICS Implementation Assessment Methodology also sets out how the specificities of the US implementation of the ICS, in the form of the Final US AM, should be considered in the ICS implementation assessment.
The consultation documents present the proposed changes to ICP 9 (CF 9.4) and ICP 20 (CF 20.10), following the development of ICS-related reporting and disclosure requirements. The proposed changes are shown in blue ComFrame boxes under CF 9.4 and CF 20.10 respectively. For clarity, the text of ICP 9 and ICP 20 that is not subject to public consultation appears in light grey font.
The proposed new paragraph 47 of the ComFrame Assessment Methodology is presented in blue font. For clarity, the text that is not subject to public consultation appears in light grey font.
How to provide feedback:
The consultation is now open. Please use the consultation tool available at:
Instructions for use are available when you access the tools. Only comments submitted through the tools will be considered. All comments will be published on the IAIS website unless the option in the tool to keep comments confidential is chosen.
Please note that some formatting (eg bullet points) may not be preserved when copying and pasting your comments into the consultation tool from other software such as Microsoft Word.
A public background session will be held via webinar on 11 December 2025 at 15:00 – 16:30 CET to present the consultation documents and answer questions from stakeholders. Click here for details and registration.