Public consultation on ICS-related ComFrame standards
The consultation on ICS-related ComFrame standards closed on 5 February 2026 24:00 CET.
The consultation included 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.
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 IAIS consultation documents presented 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 were 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 was not subject to public consultation appears in light grey font.
The proposed new paragraph 47 of the ComFrame Assessment Methodology was presented in blue font. For clarity, the text that was not subject to public consultation appears in light grey font.
A public background session was 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.
The IAIS is currently reviewing responses to the public consultation on the above consultation documents.