As part of the revised Swiss insurance supervisory framework, FINMA has introduced a new data collection template (“Datenerhebung”) for insurers’ investment activities.

Insurers are required to submit this template from 1 January 2025 onwards. The framework consolidates reporting requirements across the Swiss Solvency Test (SST) and tied asset monitoring under the Aufsichtsverordnung (AVO), with the objective of enhancing transparency while avoiding additional reporting by reusing SST data.

The Datenerhebung template represents a logical step towards a more integrated supervisory framework. We particularly welcome the increased transparency on investment risks and the reuse of SST data to reduce duplication.

At the same time, the practical implementation introduces notable complexity.

Key Implementation Challenges

Data availability and ownership

Look-through requirements for funds and fund-of-funds remain a key challenge, particularly where underlying holdings data is provided late, incomplete, or of insufficient quality for reporting purposes. In many cases, ownership of this data sits with asset managers rather than insurers, which can create practical dependencies in the reporting process. Asset managers may also have limited visibility of the specific regulatory challenges faced by insurers and may therefore not always be in a position to support data corrections or clarifications within the required timelines. As a result, the quality, timeliness, and coverage of fund look-through data become increasingly critical.

Template rigidity and technical constraints

The template imposes strict completeness requirements, with limited tolerance for missing data and no explicit materiality thresholds. In addition, technical limitations (e.g. protected sheets, size constraints, limited capacity for deep look-through structures) add operational burden.

Consistent look-through methodology used for both SST and Datenerhebung

While the framework aims for consistency, important differences remain. The Swiss Solvency Test (SST) implicitly requires full look-through for funds, whereas the Datenerhebung requires it explicitly for bond funds. This creates operational complexity in practice. From our perspective, it is advisable to apply a consistent full look-through approach across both frameworks, rather than maintaining selective methodologies, in order to ensure consistency, reduce operational risk and avoid fragmentation of reporting processes.

Ambiguity in fund classification

As the Datenerhebung specifically requires look-through treatment for “bond funds”, the classification of investment funds becomes an important practical issue. The definition of “bond funds” is not always clear-cut, particularly for convertible bond funds or multi-asset strategies. This creates interpretation risk and may lead to inconsistent reporting outcomes where similar products are classified differently.

Alignment between SST and AVO frameworks

Despite the intended convergence, differences in methodology and interpretation remain, requiring careful reconciliation in practice. This is particularly relevant for the treatment of specific exposures, such as unrated securities, where approaches under the Swiss Solvency Test (SST) and Aufsichtsverordnung (AVO) may differ in terms of credit assessment and classification.

Expected Regulatory Perspective

The Datenerhebung brings together two distinct regulatory frameworks — the Swiss Solvency Test (SST) and the Aufsichtsverordnung (AVO) — where differences in interpretation, look-through requirements, rating approaches, and valuation methodologies still remain. As a result, we expect a number of edge cases and practical scenarios that will require discussion and regulatory judgement during implementation.

At a conceptual level, we expect that FINMA will continue to assess reporting outcomes based on the prudent person principle and a focus on economically relevant risks.

In particular, the emphasis is likely to remain on the identification and monitoring of material credit exposures, while less material positions are expected to be assessed in proportion to their risk relevance. Aggregated views (e.g. largest counterparty exposures) may help demonstrate adequate risk coverage.

Implications for Insurers

While the Datenerhebung aims to streamline reporting, it effectively increases requirements for:

  • Consistent integration of SST and AVO data
  • High-quality look-through data and robust, scalable reporting processes
  • Clear governance over data quality, ownership and interpretation

Early investment in data processes and methodological alignment will be key to ensuring efficient and compliant reporting.

Looking ahead

If your organisation is currently navigating the Datenerhebung requirements, reviewing look-through data challenges, or assessing the interaction between SST and AVO reporting, we would be pleased to exchange views and share practical experience. Please feel free to get in touch with SolvencyAnalytics to discuss how we can support your reporting framework and implementation approach.