8 UKEB Post-implementation Review of IFRS 17 Insurance Contracts

26 February 2026 Agenda Paper 8 OFFICIAL - PUBLIC

Executive Summary

Project Stage

Project Type

UKEB Post-implementation Review

Project Scope

Significant

Purpose of the Paper

The purpose of this paper is to set out the revised plan for the UKEB Post-implementation Review of IFRS 17 Insurance Contracts (UKEB PIR of IFRS 17).

Summary of the Issue

The UKEB adopted IFRS 17 Insurance Contracts in May 2022. The Board assessed that the standard led to a significant change in accounting practice. As a result, the UKEB is required, under the legislation, to conduct a post-implementation review and publish a report of the results no later than 1 January 2028.

This is the first post-implementation review for a standard adopted by the UKEB. The Secretariat considers that initiating the project at this time will help raise awareness amongst stakeholders, accommodate the lead time necessary to commission an external report and allow for contingency within the timeline.

The Secretariat has revised the draft Project Initiation Plan (PIP) to address the comments made by the Board at its January 2026 meeting.

---

Decisions for the Board

1. Subject to addressing any comments raised at this meeting, does the Board approve the PIP for publication?

Recommendation

The Secretariat recommends that the Board approves the PIP for publication.

Appendices

Appendix A [Draft] Project Initiation Plan: UKEB Post-implementation Review of IFRS 17 Insurance Contracts

---

Background

1The UKEB adopted IFRS 17 Insurance Contracts in May 2022. The Board assessed that the standard led to a significant change in accounting practice. As a result, the UKEB is required, under the legislation, to conduct a post-implementation review and publish a report of the results no later than 1 January 2028.

2This is the first post-implementation review for a standard adopted by the UKEB. The Secretariat presented a draft Project Initiation Plan at the January 2026 Board meeting. The Board discussed it and requested a number of revisions.

3This paper tables an amended PIP for consideration to the Board, reflecting the Board's comments.

Summary of key changes to the draft Project Initiation Plan

4Following the Board's discussion in its January 2026 meeting, the Secretariat made the following key changes, which are highlighted in grey in the revised PIP in Appendix A:

1. Lack of effect of PIR on endorsement and adoption decision: The PIP now explicitly notes that the PIR does not alter or affect the endorsement and adoption decision the UKEB made in 2022. [Paragraph A8]
2. Objective of UKEB PIR of IFRS 17: The PIP now clarifies that the PIR focuses on the Board's decision to endorse and adopt IFRS 17 and not the objective of IFRS 17 in the Standard. [Paragraphs A17-A20]
3. Issues to be included in the final report: The PIP clarifies that the PIR report will focus solely on significant UK post-implementation issues. [Paragraph A24]
4. Removal of Connectivity section: The PIP does not feature a connectivity section anymore, in line with the UKEB's remit on the topic, which is to actively consider it when conducting influencing projects\ ¹. The UKEB PIR will consider the financial reporting and economic impact associated with implementation of IFRS 17 Insurance Contracts in the UK. If an issue

---

relating to connectivity is raised, it may be considered as part of the UKEB's influencing activities on the IASB's PIR of IFRS 17.

1. Removal of table of key activities: This table has been removed to streamline the paper, as most of the information is included in the table outlining the timeline. The timeline table has been updated to include references to the Due Process Handbook (DPH).
2. External report – scope change: Table 2 was amended to reflect that the UKEB intends to commission an external report focusing on understanding the capital market effects of adoption of IFRS 17 only.
3. Lessons learnt: The PIP now includes a lessons learnt session in the Project activities and timeline section, after completion of the UKEB PIR of IFRS 17.

Question for the Board

1Subject to addressing any comments raised at this meeting, does the Board approve the PIP for publication?

Next steps

5Subject to addressing any comments raised and approval by the Board, the Secretariat expects to publish the PIP and commence work on the UKEB PIR of IFRS 17.

6The Secretariat also expects to publish an Invitation to Tender for external report on capital market effects, subject to any necessary amendments, in March 2026.

---

Appendix A: [Draft] Project Initiation Plan: UKEB Post-implementation Review of IFRS 17 Insurance Contracts

Purpose

A1This paper sets out the plan to conduct a UKEB Post-implementation Review of IFRS 17 Insurance Contracts (UKEB PIR of IFRS 17).

A2At the time of writing this paper, the IASB has not indicated when it expects to conduct its post-implementation review (PIR) of IFRS 17 Insurance Contracts.

Background

IFRS 17

A3The primary objectives of the IASB's project to develop IFRS 17 were to make:

1. insurance companies' financial statements more useful to investors and other users of financial statements; and
2. insurance accounting more consistent across jurisdictions and products.

A4IFRS 17 replaced IFRS 4 Insurance Contracts. It established principles for the recognition, measurement, presentation and disclosure of insurance contracts (which IFRS 4 did not prescribe). IFRS 4 permitted entities to use a wide variety of national accounting practices, which were not necessarily comparable with each other. Amongst other things, this meant that, for groups with international subsidiaries, the financial position and performance of subsidiaries would not necessarily be reflected in the group accounts on a consistent basis.

A5IFRS 17 was issued by the International Accounting Standards Board (IASB) in May 2017. It was subsequently amended in June 2020 and in December 2021. Its effective date was 1 January 2023.

Endorsement and adoption of IFRS 17 for use in the UK

A6The UKEB considered the amended version of IFRS 17 for adoption during 2021 and 2022. The UKEB decided to adopt IFRS 17 for use in the UK on 16 May 2022.

---

UKEB PIR

PIR of IFRS 17

A7When adopting a standard for use in the UK, the UKEB needs to assess whether it is likely to lead to a ‘significant change in accounting practice'. When the UKEB concludes so, it is subject to the requirements in paragraph 3 of Regulation 11 of SI2019/685 which requires the UKEB to:

1. carry out a review of the impact of the adoption of the standard; and
2. publish a report setting out the conclusions of the review no later than 5 years after the date on which the standard takes effect (being the first day of the first financial year in respect of which it must be used).

A8The report will outline the main findings of the PIR. It will not alter or affect the endorsement and adoption decision made by the UKEB in 2022.

Significant Change in Accounting Practice

A9At the time of adopting IFRS 17 (in May 2022), the Endorsement Criteria Assessment (ECA) did not include the UKEB’s preliminary view as to whether the implementation of IFRS 17 would lead to a 'significant change in accounting practice'. This is because the UKEB's Due Process Handbook\ ¹, which sets out the need to incorporate this information in the ECA, was not in place at the time of the Board's decision to adopt IFRS 17.

A10The finalised UKEB DPH, published on 8 December 2022, included a requirement that future DECAs and ECAs include the Board's preliminary view on this criterion.

A11During the development of the ECA, the Board considered that a number of different aspects of IFRS 17 were likely to lead to a significant change in accounting practice. After the adoption of IFRS 17, the Board provided a clarification of its view that IFRS 17 meets this criterion by making a statement on the UKEB website that specified the UKEB “will carry out a review of the impact of the adoption of the standard and a report setting out the conclusions of this review will be published by the UKEB by 1 January 2028”.

A12We consider that this decision still holds and that no matters have arisen to contradict it.

---

Guidance

Government

A13The objective of a UKEB PIR is to assess the impact of the adoption of an international accounting standard. The UKEB currently is not required to apply the UK Government's guidance on PIRs. However, as conducting PIRs is part of the UKEB statutory requirements, considering the Government guidance in this area ensures that the UKEB adheres to best practice in the UK public sector.

A14The Government's Better Regulation Framework (BRF)\ ² provides guidance on how to conduct impact assessments and PIRs\ ³. Accordingly, the UKEB PIR of IFRS 17 will be developed to be broadly in line with the guidance for PIRs set by the BRF as well as the principles of best practice of the Department of Business and Trade (DBT)\ ⁴.

IASB

A15At the time of writing this paper, the IASB has not indicated when it expects to conduct its PIR of IFRS 17. The IASB is required to conduct a PIR of each new accounting standard under its Due Process Handbook\ ⁵. The timing of the PIR is usually after the new requirements have been applied internationally for two years, generally 30-36 months after the effective date.

A16The objective of an IASB PIR is to “assess whether the effects of applying the new requirements on users of financial statements, preparers, auditors and regulators are as intended when the IASB developed those new requirements”. The IASB will usually publish a request for information to obtain stakeholder feedback. When the IASB has finished its deliberations, it publishes a report of its findings. When matters are identified in a PIR the IASB considers whether to take any action and the relative prioritisation of those matters\ ⁶.

Purpose of UKEB PIR of IFRS 17

A17The primary focus of this UKEB Post-implementation Review (PIR) is to assess whether the endorsement and adoption of IFRS 17, for application by UK companies, had the intended effect. When adopting a standard for use in the UK, the UKEB assesses whether:

1. the standard meets the technical accounting criteria of understandability, relevance, reliability and comparability;

---

1. the use of the standard is likely to be conducive to the long term public good in the UK; and
2. the standard is not contrary to the principle that the accounts must give a true and fair view.

A18Therefore, as a minimum, the following questions will be considered:

1. the extent to which UK users and other stakeholders consider the information provided by the application of IFRS 17 useful.
2. The prevalence and order of magnitude of implementation costs among UK preparers, both one-off and ongoing.
3. Whether the adoption of IFRS 17 for use in the UK led to any observable capital market effects.
4. Whether any other intended or unintended wider economic effects could be observed in the UK as a result of the adoption of IFRS 17.

A19The UKEB will broadly follow government guidance\ ⁷ on conducting post-implementation reviews to align with best practice in the public sector.

A20Similar to the endorsement and adoption process undertaken by the UKEB, the UKEB will take a holistic approach to the PIR. When considering the objective of the PIR. The UKEB will consider the standard as a whole, including the disclosures it requires and its interaction with other UK-adopted international accounting standards.

A21The UKEB PIR of IFRS 17 is expected to commence ahead of the IASB's PIR. The output of the UKEB PIR will be used to influence the IASB's PIR.

Due process for PIR

A22Section 8 of the UKEB Due Process Handbook (DPH) sets out the requirements for a UKEB PIR. The process is split in two phases. In summary:

1. Phase one: the UKEB sets out the scope of the PIR, undertaking the following steps:
   1. Project initiation plan (PIP) (mandatory).
   2. Desk-based research.

---

1. 1. Initial consultation (mandatory).
   2. Publication of a request for information (mandatory) with a 90-day consultation period.
2. Phase two:
   1. Outreach activities (mandatory).
   2. Publication of final report (mandatory) and a due process compliance statement (mandatory).

A23The content of the report includes:

1. an overview of the UKEB PIR process and its timeline;
2. background information to the international accounting standard under review;
3. a summary of the evidence gathered and findings;
4. a summary of the outreach activities and sources of stakeholder comments (after publication of the request for information); and
5. the UKEB's conclusions from the review.

A24The outreach undertaken to collect evidence may gather a number of post-implementation issues, some of which may not relate to the UK. The report will focus solely on significant UK post-implementation issues, if any.

Project Plan

Proportionality Assessment

A25This is the UKEB's first PIR for a standard that it has adopted for use in the UK. Previous UKEB PIR projects focused on influencing the IASB's PIRs.

A26This consideration will affect the proportionality assessment, as noted in the paragraphs that follow.

Significance and Size

Entities Affected by the Proposals

A27IFRS 17 affects entities that issue insurance contracts, most typically insurance undertakings.

---

A28The insurance industry is strategically important to the UK economy, for example:

1. The UK insurance industry is the largest in Europe and the third largest in the world\ ⁸. Data from the Bank of England indicates that the total value of Gross Written Premiums (GWP)\ ⁹ of UK insurance companies was approximately £350 billion, as of 2024\ ¹⁰.
2. UK insurance undertakings manage a significant amount of assets. The Association of British Insurers reports that the UK insurance sector manages investment of over £1.8 trillion\ ¹¹, nearly 20% of UK households net assets\ ¹².

A29IFRS reporters are an important share of the industry.

1. A total of 17 insurance entities were listed on the London Stock Exchange as of December 2025\ ¹³. These entities are required to produce consolidated accounts using IFRS. The total market capitalisation of these listed insurers was approximately £105 billion as of December 2025\ ¹⁴.
2. An additional 28 unlisted entities voluntarily apply IFRS. These entities were identified as part of the Endorsement Criteria Assessment of IFRS 17, which was published in May 2022.
3. The total insurance revenue of entities applying IFRS was just short of £100 billion of as of 2024 year-end.

A30Table 1 below provides a further breakdown of insurance revenues by size and listing status.

Note: * This analysis is based on the population of unlisted entities that was identified as part of the ECA of IFRS 17, which was published in 2022.

Complexity

A31IFRS 17 introduced complex requirements for entities reporting insurance contracts.

A32As noted in the Endorsement Criteria Assessment (ECA) of IFRS 17, this is because the underlying economics of these transactions is complex. Insurance contracts create a variety of complex bundles of rights and obligations for the issuers. Insurance entities also typically use complex actuarial methodologies and assumptions to price insurance policies and estimate the cost of claims.

---

A33To account for such contracts, IFRS 17 introduced three measurement models, as well as a number of accounting policy choices and transition approaches to reflect the diverse and complex business of insurance entities.

Expected Timeline

A34As set out above, the UKEB is required to undertake the PIR and publish a report setting out the conclusions of the review no later than 5 years after the date on which the standard takes effect (being the first day of the first financial year in respect of which it must be used) i.e. by 1 January 2028 for IFRS 17.

A35The UKEB considers that initiating the project at this time will help raise awareness amongst stakeholders, accommodate the lead time necessary to commission an external report and allow for contingency within the timeline.

A36The planned project timeline is reported (see paragraphs A46-A47).

Expected Interest

A37The UKEB anticipates interest in this project mainly from insurance entities, their shareholders/investors as well as accounting firms and institutes.

A38Another element which may provoke interest among our stakeholders is that this is the UKEB's first PIR.

UKEB Project Scope

A39Based on the proportionality assessment above, the UKEB regards this as a 'Significant' project, and the scope and approach described in this document is based on this preliminary assessment.

A40The scope of the project may be reassessed at a future date based on desk-based research and stakeholder engagement.

Resources Allocated

A41To undertake the activities described in this project plan, a project team has been assigned consisting of a Project Director with oversight of Senior Project Director.

A42The economics team will actively contribute to the project, considering that the PIR will focus on both accounting and economic impacts.

A43It is expected that the Project Director and the Economics Team Leader will jointly:

1. Supervise the drafting of the external report.
2. Conduct stakeholder engagement.

---

Setting up an ad-hoc advisory group

A44The endorsement and adoption project for IFRS 17 was supported by an ad-hoc advisory group as, at that stage, the UKEB had not set-up its Advisory and Working Groups. For this project, we do not propose setting up another group. Instead, the UKEB can use:

1. Input from existing Advisory and Working Groups.
2. Stakeholder feedback from outreach activities.
3. Leverage the stakeholder network built from the endorsement and adoption activities for IFRS 17.

A45Moreover, there is a better understanding of the technical matters arising out of IFRS 17 now, given that three full years of implementation have passed and a number of reviews have been conducted by regulators, accounting firms and accounting institutes, etc.

Project activities and timeline

A46The proposed high-level project timeline, including activities is shown below. This provides a best estimate based on information known at this time. If necessary, a revised PIP will be presented to the Board, to reflect any major changes, as the project progresses.

A47Future dates are based on current expectations and may therefore be subject to modification. The Secretariat will bring a revised PIP to the Board if there are any significant changes to the project plan.

15A separate project timeline diagram has not been included since a precise timeline, such as Board dates in 2027 and 2028, is not available at the time of writing this paper.

---