2024 Year-End Filing Requirements for Class 1, 2, 3, A and B

Summary

This BMA document sets out the specific forms, schedules and attachments that Class 1, 2, 3, A and B insurers must submit as part of their 2024 year end Electronic Statutory Financial Return (E-SFR), under the Insurance Act 1978 and related Accounts and Returns and Solvency Regulations. It also confirms the filing deadline and system access process.

Class 1, 2 and 3 filing package

• Core forms: Company Information Form, Statement of Control Form, Financial Statements (Form 1A Balance Sheet, Form 2A Income Statement, Form 8 Capital and Surplus), Solvency Page and Annual Statutory Declarations.
• Attachments: Auditor's Report, Notes to the Financial Statements, Loss Reserve Specialist Opinion (LRSO) where applicable, Schedule of Cyber Risk Management, Schedule of Compliance with Suspicious Activities Reporting and Sanctions, Alternative Capital Schedule, Schedule of Segregated Accounts and SAC Summary, and Schedule of Outsourcing Services.
• Own Risk Assessment: Risk Register, Risk Appetite and Investment Guidelines, plus Schedule I Underwriting Analysis.

Class A and B filing package

• Core forms: Same structure as Class 1/2/3 but with Form 4 Balance Sheet, Form 5 Income Statement and Form 8 Capital and Surplus; includes an Actuary Certificate instead of an LRSO.
• Additional attachment: Schedule of Anti-Money Laundering/Anti-Terrorist Financing Questionnaire, required for long-term direct insurers only.

The document also specifies LRSO filing frequency rules and confirms that insurers must enrol to access the E-SFR system, that the return is due within six months of financial year end (extendable on application), and that the BMA may request further documentation in a given year.

Key obligations

• File the completed E-SFR package (Company Information Form, Statement of Control Form, Financial Statements, Own Risk Assessment, Schedule I Underwriting Analysis, Solvency Page and Annual Statutory Declarations plus required attachments) within six months of the financial year end, or such longer period as the BMA approves on application, not exceeding nine months.
• All Class 3 insurers must file a Loss Reserve Specialist Opinion (LRSO) annually.
• Any Class 1 or Class 2 insurer writing more than 30% professional liability business, or discounting loss and loss expense provisions and not meeting solvency requirements on an undiscounted basis, must file an LRSO annually.
• All other Class 2 insurers must file an LRSO triennially.
• Long-term direct insurers (Class A and B) must complete the Schedule of Anti-Money Laundering/Anti-Terrorist Financing Questionnaire.
• Insurers must enrol for access to the E-SFR system by emailing esfr@bma.bm before they can file.
• Insurers must provide any additional documentation requested by the BMA in a given year.

Applies to

Class 1 insurers, Class 2 insurers, Class 3 insurers, Class A insurers, Class B insurers

Deadlines

• within six months of the financial year end: Deadline for filing the E-SFR and accompanying documents.
• up to nine months (on application to the BMA): Maximum extension period the BMA may grant for filing the E-SFR beyond the standard six months.
• annually: LRSO filing frequency for all Class 3 insurers and for Class 1/2 insurers meeting the specified professional liability or discounting criteria.
• triennially: LRSO filing frequency for other Class 2 insurers not meeting the annual filing criteria.