Non-paper Following the trilogue meeting on 18 September (see Solvency II Wire 20/9/2012) in which negotiating parties failed to reach an agreement, the Commission circulated a “non-paper” (24/9/2012) on the LTG package and timings of Solvency II. The document, seen by Solvency II Wire, proposes two alternative implementation timelines depending on whether the impact assessment is carried out before or after Omnibus II is finalised.
- An ex ante approach – conducting the assessment before finalising Omnibus II – proposes conducting the assessment between November 2012 and April 2013; political agreement on Omnibus II will then be reached in June 2013. The Solvency II Directive will be published in October 2013 and full implementation will be set for 2015. The interim period between publication and full implementation will allow for adopting the Level 2 delegated acts.
- An ex post approach – conducting the assessment after finalising Omnibus II – proposes doing the assessment between October 2012 and March 2013; political agreement on Omnibus II will also be reached in October 2012. The Solvency Directive will be published in January 2013 and full implementation will be set for 2016. The later implementation date will allow for a two year observation period during which there will be a parallel run of Solvency I alongside Solvency II.