The current IORP Directive refers to an actuarial function in relation to the calculation of technical provisions (TPs)1. This is expressed in terms of the function being performed by an actuary or another specialist, including an auditor, ‘on the basis of actuarial methods recognised by the competent authorities’ of the Member State in which the IORP is established.

Article 48 of the Solvency II Directive by contrast, sets out in much more detail the regulation of the actuarial function. An edited version of article 48 is set out in the box below. The Solvency II Directive also specifically states that this is an area in which the Commission can adopt a delegated act, which arguably, provides a route by which the Commission can initiate or revise a Directive’s provisions with less scrutiny.  A similar provision with a revised IORP Directive could open the door to future mission creep.

1 In both articles 9 (conditions of operation) and 15 (technical provisions)