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When risks return to the insurer

Illustration for the analysis: When risks return to the insurer

After a simulated reinsurer failure, how do insurers recover assets, absorb risks and fund annuity payments? An investigation into the British stress test.

dated revision: October 23, 2026French originalprimary sourcesno tracker

When investment firms buy insurers · Article 7/8 · Research cutoff: 23 October 2026

In a stress exercise published in November 2025, the British supervisor models insurers taking back £12.3 billion of liabilities after a simulated counterparty failure. The firms absorb the shock. Understanding that result means following the collateral, the rights over the assets and the funding of payments, including the test’s assumptions about liquidity.

This seventh investigation moves from the prudential treatment of insurance promises to the return of risks, rights over assets and the funding of payments.

An annuity payment still falls due while the companies financing it work through their difficulties. An insurer may have passed some of the investment and longevity risks to a reinsurer, but its obligation to the policyholder remains. The International Association of Insurance Supervisors, or IAIS, expressly distinguishes reinsurance from a novation that replaces the debtor under the policy. The cedant, the insurer transferring the risks, remains legally responsible for paying the benefit. 1

Recapture, the taking back of ceded risks, puts that responsibility to the test. Collateral may come back under the insurer’s control, financial hedges need reviewing, and the capital requirement changes as the firm takes on the risks again. The challenge is to make the assets serve the annuity payment schedule when their availability, currency and value may have changed. British supervisory expectations require insurers to prepare for precisely this sequence, including the long-term management of assets that are difficult to sell. 2

The Prudential Regulation Authority, the UK’s prudential supervisor for insurers, examined this question publicly in its Life Insurance Stress Test 2025, known as LIST. Results published on 17 November 2025 use balance sheets at 31 December 2024. The exploratory recapture scenario brings back £12.3 billion of liabilities, approximately half the funded reinsurance exposure within the defined scope for the firms concerned. That amount measures the obligations being taken back. The report then assesses firms’ ability to support them, allowing for recovered collateral and the actions permitted by the exercise. 3

One crisis, two branches of the calculation

The core scenario begins with a market shock: lower risk-free interest rates, wider credit spreads and falling equity prices. Conditions deteriorate further through defaults, rating downgrades and property losses. At the third stage, markets begin to stabilise. Firms can recognise certain management actions and must restore part of their investment portfolios to their original credit quality. The exercise is designed around severe but plausible conditions and a common balance sheet date. 3, 4

Recapture follows a particular branch of this story. Section C of the instructions starts from the second stage and modifies the third to bring a reinsurer’s risks back to the cedant. For each firm, the chosen counterparty is the one whose recapture would have the most adverse immediate effect on its solvency ratio, agreed with the PRA. The choice is specific to the insurer. The publication therefore does not describe a single identified reinsurer failing across all participants. 4

The modelled trigger is a breach of a solvency condition applying to the reinsurer. This matters because a contract can give the insurer a recapture right before formal insolvency. Supervisory expectations ask firms to examine trigger thresholds, opportunities to remedy a deterioration, and the merits of exercising recapture. Depending on the circumstances, continuing the treaty and taking the assets back expose the insurer to different risks. 4, 2

The collateral assumptions are tightly specified. The test uses the contractual minimum held at the end of 2024 and applies the market and credit shocks from the second stage. Any collateral above that minimum is stripped out, as are additional recoveries the insurer might hope to receive later. Benefits from existing protection within the group are recognised as a separate movement where the conditions allow. These conventions limit the resources firms can count in the calculation. 4

LIST: the scenario branchesLIST 2025 applies to balance sheets at 31 December 2024; results were published on 17 November 2025. After common Stages 1 and 2, the core scenario proceeds to market stabilisation in Stage 3. Section C modifies Stage 3 by adding recapture triggered by breach of a reinsurer solvency condition. The core scenario covers eleven entities; recapture covers the material-exposure subset. Each firm’s selected counterparty is the one with the largest immediate adverse solvency-ratio impact. £12.3 billion of liabilities are recaptured, approximately 50% of the qualifying end-2024 FundedRe exposure. Scope: agreements from 1 January 2016, excluding intragroup reinsurance. No cash requirement or loss amount is shown. Branching diagram without proportional time or monetary volume. The initial shock combines falling rates and equities with widening spreads. Stage 2 adds downgrades, defaults and falling property values. Core Stage 3 narrows spreads and permits rebalancing and management actions. The exploratory recapture scenario has no target probability.l0g / 0123.10.2026LIST: the scenario branchesLIST 2025 · balance sheets 31.12.2024Results: 17.11.20251 · Initial market shockRates, equities, spreads2 · Downgrades and defaultsSame shock on collateral3 · Core · 11 entitiesMarkets stabiliseRebalancing and actions3 modified · Section CSolvency trigger breachedWorst effect for each insurerGBP12.3bn liabilitiesAbout 50% of the subsetSeparate core andexploratory branches.Arrows carry no timeor cash-flow scale.Year-end 2024; since 01.01.2016, intragroup excluded.Sources:S03S04
LIST: the scenario branchesLIST 2025 applies to balance sheets at 31 December 2024; results were published on 17 November 2025. After common Stages 1 and 2, the core scenario proceeds to market stabilisation in Stage 3. Section C modifies Stage 3 by adding recapture triggered by breach of a reinsurer solvency condition. The core scenario covers eleven entities; recapture covers the material-exposure subset. Each firm’s selected counterparty is the one with the largest immediate adverse solvency-ratio impact. £12.3 billion of liabilities are recaptured, approximately 50% of the qualifying end-2024 FundedRe exposure. Scope: agreements from 1 January 2016, excluding intragroup reinsurance. No cash requirement or loss amount is shown. Branching diagram without proportional time or monetary volume. The initial shock combines falling rates and equities with widening spreads. Stage 2 adds downgrades, defaults and falling property values. Core Stage 3 narrows spreads and permits rebalancing and management actions. The exploratory recapture scenario has no target probability.l0g / 0123.10.2026LIST: the scenario branchesLIST 2025 · balance sheets 31.12.2024Results: 17.11.20251 · Initial market shock2 · Downgrades and defaultsCollateral takes the same shock3 · Core11 entitiesStabilisationActions allowed3 · Section CTrigger brokenCounterparty:worst effectRecapture: GBP12.3bnAbout 50% of the subset’squalifying funded reinsuranceAgreements since 01.01.2016;intragroup excluded · year-end 2024Sources:S03S04
FIG. 01 One crisis, two branches of the calculation[S03][S04]
Method and scope

LIST 2025, balance sheets at 31 December 2024; results published on 17 November 2025. Section C modifies Stage 3 after Stage 2. Each participant’s chosen reinsurer is specific to that firm. £12.3bn measures recaptured liabilities, with no corresponding cash amount published. The eleven core entities and the recapture subset are distinct. Arrows encode no monetary volume.

The population matters as much as the scenario. The core test covers eleven UK legal entities; the recapture exercise applies only to those with material funded reinsurance exposure. For the latter, qualifying agreements were entered into from 1 January 2016 and exclude reinsurance within the group. The individual results published on 24 November 2025 concern the core scenario. Recapture results are published only in aggregate, leaving the effects on individual insurers undisclosed. 3, 5

The capital requirement rises with the risks

For the subset of firms taking liabilities back, the capital coverage ratio falls from 154% in the core comparator to 144% with recapture. The PRA attributes most of the change to a 6% increase in the solvency capital requirement, or SCR. Eligible own funds fall by 1%, mainly because the risk margin increases. These are the supervisor’s published, rounded changes. 3

The ratio relates two amounts: the financial resources a firm can count as available to absorb losses, and the capital required for the risks on its balance sheet. When credit or longevity risks return, the second amount can grow much faster than the first declines. Coverage then falls without an equivalent loss draining a bank account. In the exercise, the PRA points to the return of risks already present at the cedants, whose impact depends on their interaction with the rest of the balance sheet. 3

A simple normalisation makes the mechanism visible. Set the comparator’s SCR to 100. Coverage of 154% then implies eligible own funds of 154. Applying the rounded published changes gives approximately 152.5 of own funds against a capital requirement of 106, producing coverage close to 144%. These index values explain the ratio movement; they do not establish the corresponding sterling amounts. 3

Recapture shifts the ratioLIST 2025 material funded-reinsurance exposure subset. Published SCR coverage is 154% in the core comparator and 144% with recapture. The PRA reports a 6% rise in SCR and a 1% fall in eligible own funds. Illustrative indices: setting core SCR to 100 and own funds to 154, the rounded changes produce SCR of 106 and own funds of 152.46; 152.46 divided by 106 is approximately 143.83%, consistent with the published rounded 144%. Bars use one scale beginning at zero. The indices explain the calculation without reconstructing capital amounts in pounds.l0g / 0223.10.2026Recapture shifts the ratioLIST 2025 · material FundedRe subsetYear-end 2024 · published 17.11.2025154 % → 144 %−10 published coverage points04080120160Eligible funds−1%Before 154After 152.46Required capitalSCR: +6%Before 100After 106Indices: core comparator SCR = 100.152.46 ÷ 106 × 100: about 143.83%.Rounded inputs; PRA ratio: 144%.Sources:S03
Recapture shifts the ratioLIST 2025 material funded-reinsurance exposure subset. Published SCR coverage is 154% in the core comparator and 144% with recapture. The PRA reports a 6% rise in SCR and a 1% fall in eligible own funds. Illustrative indices: setting core SCR to 100 and own funds to 154, the rounded changes produce SCR of 106 and own funds of 152.46; 152.46 divided by 106 is approximately 143.83%, consistent with the published rounded 144%. Bars use one scale beginning at zero. The indices explain the calculation without reconstructing capital amounts in pounds.l0g / 0223.10.2026Recapture shifts the ratioLIST 2025 · material FundedRe subsetYear-end 2024 · published 17.11.2025154 % → 144 %−10 published coverage points04080120160Eligible own funds: −1%Before : 154After : 152.46Required capital (SCR): +6%Before : 100After : 106Indices: core comparator SCR = 100.152.46 ÷ 106 × 100About 143.83%; PRA: 144%.Rounded inputs.Sources:S03
FIG. 02 The ratio falls mainly because more capital is required[S03]
Method and scope

LIST results, Annex 2. Comparison confined to the exploratory recapture participants. l0g normalisation: comparator SCR = 100; own funds = 154. Using rounded published changes, 154 × 0.99 = 152.46 and 100 × 1.06 = 106, giving approximately 144% coverage. Bars start at zero. The indices do not recover absolute sterling amounts.

The risk margin enters elsewhere in the balance sheet. It supplements the best estimate of obligations within technical provisions. An increase can therefore reduce available own funds, while the SCR remains a separate capital requirement. This structure helps explain why recapture can consume prudential resources even when the recovered collateral continues to make its payments. The test captures the return of risks and the cost of supporting them, reaching beyond a single collateral valuation. 6, 3

The outcome supports the PRA’s assessment of resilience for the exposures held at the end of 2024. Its scope remains the firms, assets and conditions examined. The exploratory recapture scenario carries no target probability. The broadly one-in-a-hundred severity assigned to the core scenario does not become an estimate of how often reinsurers will fail. 3

Rights over the assets follow their own timetable

Access to collateral begins with the rights the treaty allows the insurer to exercise. LIST’s instructions require firms to assess obstacles involving counterparties, other stakeholders and the reinsurer’s regulator. To recognise collateral in the scenario, the insurer must be able to obtain beneficial ownership from the first day of recapture and legal ownership within six months. Those timings are conditions for the calculation required of participants. They do not bind a court to complete proceedings within that interval. 4

Derivatives add another operation to prepare. In this simulation, derivatives within the collateral are assumed to be settled immediately before recapture, after the shocks have been applied. They are not transferred intact to the insurer through novation. The insurer must then consider the interest-rate, inflation or currency hedges needed for the returning portfolio. The instructions permit certain swaps during the calculation, while the results report highlights the significance of the cost of new currency hedges when accommodating recovered assets. 4, 3

Recapture can also concern assets already held by the cedant. Just Group’s 2025 annual report provides a concrete example. For one funded reinsurance partner, collateral can consist of corporate bonds in a segregated account or lifetime mortgages under a funds-withheld arrangement. These loans are secured on the home and are generally repaid with interest when the homeowner dies or enters long-term care. Just explains that the loans remain legally held and managed by the group, while their investment returns are paid to the reinsurer. Holding the loans and receiving their returns are therefore separate parts of the arrangement. 7

This is the company’s disclosure for 2025, separate from the end-2024 portfolio used in LIST. The note does not supply the complete treaty, the thresholds for this particular relationship or a detailed recapture timetable. It does, however, show why tracking only where assets are held would miss part of the transaction: entitlement to income, conditions for returning assets and responsibility for risks must be read together. 7, 2

From recaptured assets to paymentsLIST recognises collateral subject to beneficial ownership from day 1 and legal ownership within six months. These conditions do not guarantee actual transfer times. Annuity payments follow contractual dates. Assets can be held for their cash flows or sold subject to legal control and a liquid market. Available cash funds annuity benefits, margin calls and costs. Matching-adjustment eligibility requires a separate prudential assessment. Only pre-arranged external facilities may be drawn in Section C steps a to d. Arrows have no monetary scale.l0g / 0323.10.2026From recaptured assets to paymentsLIST: recognition under contract and applicable lawDay 1: beneficial ownership6 months: legal ownershipAnnuities: contractual payments throughout transfersRecaptured assets: enforce rights, manageMA eligibilityFirm permissionFlow matchingLiability valueHold assetsAsset inflowsLong-term holdingSell assetsLegal titleLiquid marketPrice and costsCash available when payments fall dueReceived cash flows / sale proceedsPrearrangedexternal linesSection C: a–dExisting rightsAnnuitiesMargin callsCostsCash low pointswithin the horizon.Sources:S04S02S09S01
From recaptured assets to paymentsLIST recognises collateral subject to beneficial ownership from day 1 and legal ownership within six months. These conditions do not guarantee actual transfer times. Annuity payments follow contractual dates. Assets can be held for their cash flows or sold subject to legal control and a liquid market. Available cash funds annuity benefits, margin calls and costs. Matching-adjustment eligibility requires a separate prudential assessment. Only pre-arranged external facilities may be drawn in Section C steps a to d. Arrows have no monetary scale.l0g / 0323.10.2026From recaptured assetsto paymentsLIST collateral recognitionDay 1: beneficial6 months: legalAnnuities: contractual due datesRecaptured assets: rights, controlHold assetsAsset inflowsAsset due datesSell assetsLegal titleLiquid marketPrearrangedexternal linesSection C: a–dAvailable cashAt due datesAnnuitiesMarginCostsSeparate MA check: liability value.Track intrahorizon cash low points.Sources:S04S02S09S01
FIG. 03 Turning assets into payments takes several steps[S04][S02][S09][S01]
Method and scope

The two timetables distinguish asset rights from cash receipts. Day 1 and six months are LIST collateral-recognition conditions, with no guaranteed real-world deadline. Holding and selling assets follow separate paths; a permitted sale requires legal ownership and a liquid secondary market. Prearranged facilities are scoped to Section C movements a–d. Qualitative mechanism, with no numerical cash flows.

Once assets have been recovered, another assessment concerns their regulatory use. Subject to conditions, the matching adjustment allows insurers to recognise part of the yield on assets whose payments match future benefits. It affects the present value assigned to liabilities. Under LIST, recovered collateral can enter a portfolio receiving this adjustment only if it meets the insurer’s existing permissions. Participants assessed most of the recaptured collateral as eligible. The PRA identifies that as an important factor limiting the shock. 8, 4, 3

Eligibility makes assets immediately useful in the regulatory balance sheet. Their ability to provide cash on a particular date still depends on coupons, repayments, currency and market conditions. Supervisory expectations consequently require preparation both for managing the recovered assets and for meeting the liquidity needs associated with recapture. 2, 9

Cash needs run through the scenario

Annuity payments and collateral calls on financial hedges have their own due dates. A portfolio with ample value can need temporary funding if its receipts arrive after its outgoings. The British liquidity framework asks insurers to examine those timing gaps, the assets they can mobilise and the availability of funding under stress. Solvency and liquidity therefore need to be assessed together, using their respective measures. 9

LIST includes a substantial modelling convention here. During the first two stages of the core scenario, firms may assume an unlimited liquidity facility. The regulator explains why: it prevents liquidity constraints from dominating the capital impact while sales and other management actions are heavily restricted. Among other things, this assumption allows firms to meet margin and collateral calls without the exercise turning on that funding need alone. Identified shortfalls must be explained in the qualitative report submitted to the PRA. 4

The recapture branch tightens the framework. Permitted drawings rely on facilities already arranged; external trades require a liquid secondary market and control of legal ownership. Firms can use the permitted hedges. Additional reinsurance is excluded, and recapitalisation can be assumed to be in place only where existing contractual arrangements allow it. The test thus brings several funding decisions into view, within a deliberately standardised set of options intended to make results comparable. 4

Just’s disclosures illustrate tools that exist outside this modelling convention. Its 2025 solvency report describes a £400 million revolving credit facility, with direct access extended during the year to its two insurance subsidiaries, Just Retirement Limited and Partnership Life Assurance Company Limited. The report expressly separates liquidity management from the SCR calculation. It also describes a funding plan that considers the time, cost and difficulty of the available options. 10

The facility is a documented funding resource whose drawing conditions and competing uses then need to be examined. The share of the £400 million available for any particular recapture remains to be established. Reconstructing a transaction’s funding would require matching expected benefit payments and margin calls against cash inflows from assets and the facilities the relevant legal entity could actually draw on. That reconciliation is also missing from LIST’s aggregate results: I found no published amount for a recapture-specific cash shortfall. 10, 3, 4

The cost of restoring credit quality

Asset sales appear in the exercise within a scope that can be traced. In the core scenario, the PRA requires firms to restore 25% of downgraded assets in each matching-adjustment portfolio to their initial credit quality, excluding equity-release mortgage securitisations, which receive separate treatment. Firms must sell some securities damaged by the shock and buy higher-quality investments at a cost specified by the test’s conventions. In the recapture branch, this prescribed rebalancing expressly excludes the collateral recovered from the reinsurer. 4

The PRA estimates that prescribed rebalancing leads to £3.4 billion of sales of sub-investment-grade bonds. Firms also exchange a further £0.9 billion of sub-investment-grade bonds for higher-rated investments through management actions. These volumes describe adjustments to the eleven entities’ portfolios in the core scenario. No amount is published for sales specifically involving recaptured assets. 3

Prescribed rebalancing as a whole reduces eligible own funds by £800 million after tax. That overall cost covers a wider scope than the £3.4 billion of sub-investment-grade bond sales alone, so dividing the two amounts cannot establish a sale haircut. The published effect on the coverage ratio is limited to one percentage point because improving investment quality also reduces the capital requirement. 3

Rebalancing the MA portfolioLIST 2025 core scenario, eleven entities. At Stage 3, prescribed rebalancing restores 25% of the relevant downgraded assets in each MA portfolio to their original rating; ERM securitisations are excluded. The PRA estimates £3.4bn of sub-investment-grade sales; firms trade a further £0.9bn through management actions. The total prescribed-rebalancing cost is £0.8bn of post-tax eligible own funds, with a one-percentage-point effect on SCR coverage. The bar volumes are not recapture costs or cash needs. In the exploratory branch, recaptured collateral is explicitly excluded from the 25% rule. The overall cost covers a wider scope than the sub-investment-grade sales shown by the bars. GBP0.8bn is the aggregate after-tax reduction in eligible own funds; GBP3.4bn and GBP0.9bn are separate transaction volumes. The modelled own-funds effect and traded amounts have different perimeters.l0g / 0423.10.2026Rebalancing the MA portfolioLIST 2025 · core · 11 entities25% of affected downgraded assets.Restore original rating; ERM excluded.01234Prescribed rebalancing: 3.4Management actions: 0.9Sub-IG transaction volumes · GBP bnSell lower-rated securitiesBuy better-rated assetsCredit risk −; SCR −MA −; provisions +Eligible own funds −Global cost: GBP0.8bn after tax; coverage −1 point.Wider scope than sub-IG sales alone.Sources:S03S04
Rebalancing the MA portfolioLIST 2025 core scenario, eleven entities. At Stage 3, prescribed rebalancing restores 25% of the relevant downgraded assets in each MA portfolio to their original rating; ERM securitisations are excluded. The PRA estimates £3.4bn of sub-investment-grade sales; firms trade a further £0.9bn through management actions. The total prescribed-rebalancing cost is £0.8bn of post-tax eligible own funds, with a one-percentage-point effect on SCR coverage. The bar volumes are not recapture costs or cash needs. In the exploratory branch, recaptured collateral is explicitly excluded from the 25% rule. The overall cost covers a wider scope than the sub-investment-grade sales shown by the bars. GBP0.8bn is the aggregate after-tax reduction in eligible own funds; GBP3.4bn and GBP0.9bn are separate transaction volumes. The modelled own-funds effect and traded amounts have different perimeters.l0g / 0423.10.2026Rebalancing theMA portfolioLIST 2025 · core · 11 entities25% of affected downgraded assets.Restore original rating; ERM excluded.01234Prescribed rebalancing: 3.4Management actions: 0.9Sub-IG transaction volumes · GBP bnSell → buy better-rated assetsCredit risk −SCR −MA −Provisions +Own funds −Global cost: GBP0.8bnAfter tax · coverage −1 pointWider than sub-IG sales alone.Recapture: collateral outside the 25%.Sources:S03S04
FIG. 04 Restoring credit quality carries a cost[S03][S04]
Method and scope

Core scenario, eleven entities: PRA estimate of £3.4bn in prescribed sales and £0.9bn in additional trades of sub-investment-grade bonds. The £0.8bn after-tax cost covers prescribed rebalancing as a whole; it cannot establish a haircut on these sales. The 25% rule excludes ERM securitisations and, in the recapture branch, recovered collateral. Sales specific to recapture remain unquantified.

The balance sheet explains the movement. Buying a higher-rated asset reduces credit risk but can also lower the yield recognised through the matching adjustment. A fall in that adjustment raises the value assigned to liabilities and weighs on own funds. The insurer restores portfolio quality at a financial cost that the final ratio expresses only in part. The PRA reports that several participants were struck by the limited benefit of rebalancing in stressed and illiquid conditions. 3

For recovered collateral, retaining the assets can therefore be a rational choice when their payments fit the insurer’s obligations and the firm can manage the risks. SS5/24 asks insurers to prepare the capabilities needed when illiquid assets must be held for a long period because selling them at the expected price proves difficult. Preparing for recapture is as much about administering a portfolio as it is about selling it. 2, 11

Resilience depends on the portfolio that comes back

The strongest argument in favour of the arrangements lies in the results themselves. Using end-2024 exposures, the participating firms absorb the simulated return of liabilities from the counterparty selected for the greatest immediate adverse effect on each firm’s coverage ratio. Much of the collateral is assessed as suitable for their matching-adjustment portfolios. Assets intended to finance annuities over many years can thus continue to serve that purpose after the economic risks return to the insurer. Restrictions on excess collateral, later recoveries and new capital also give weight to the result. 3, 4

Other scenario choices define its limits. Collateral composition is fixed at the mix observed at the end of 2024, with no forward-looking allocation changes. No currency shock is applied, although a high proportion of collateral is denominated in US dollars. The PRA says sterling appreciation would have worsened the outcome. It also notes that greater volumes, more complex assets or reduced matching-adjustment eligibility could produce non-linear effects. 3

The supervisor identified gaps in the modelling of some recapture costs and announced individual follow-up. The publication does not quantify those gaps. Their financial importance therefore remains an open question, alongside the cash required, the prices at which recovered assets might be sold and the full cost of rebuilding hedges. Coverage of 144% answers a solvency question within the defined scenario; continuity of payments also requires the operational evidence. 3, 9

That connection appears in an IAIS paper published in July 2026 on preparing for insurer resolution. Its discussion of asset-intensive reinsurance highlights legal and operational obstacles to collateral availability and the potential effects of recapture on the different parties. The paper provides implementation guidance without creating new standards; the mechanisms described depend on authorities’ powers and contractual arrangements. It encourages the authorities concerned to prepare coordination and examine potential contagion between the reinsurer and its cedants. 12

To take the investigation further into a specific transaction, the decisive document would be a shared timetable: enforceable rights over each asset, cash that can be collected, annuities and margins falling due, confirmed funding, and the choices between holding and selling. Public documents allow the stages and several constraints to be reconstructed. They show why protecting an annuity has to be judged over time: the insurer must be able to turn returning resources into payments at every due date under the policy. 2, 9, 4

Method. Investigation based on public documents, distinguishing simulation results, supervisory requirements, company disclosures and explanatory calculations. Just’s 2025 information illustrates a mechanism; it does not replace LIST’s end-2024 balance sheet. No interviews or access to confidential treaties are claimed. The source notes below identify the documents, dates, checked passages and questions requiring further evidence.

Further reading: Jackson and Athene’s Bermuda reinsurance, pensions and the cost of recapture, and the guide to reading a life insurer’s financial strength.

Sources

Each note identifies the document, period, relevant passage and limitations. Company and regulatory assessments are attributed to their authors.

  1. S01 · International Association of Insurance Supervisors · Accessed: 2026-10-23Insurance Core Principles and ComFrame : December 2024
    Passages and scope

    Compilation adopted in December 2024. ICP 13 itself had been revised in November 2017.

    ICP 13.0.4, PDF p.146; ICP 13.5.2–13.5.5, PDF p.153; ICP 14.1.5, PDF p.161

    Reinsurance and novation differ. The cedant remains liable to policyholders; delayed recoveries can create a cash-flow need.

    International supervisory framework, not legal advice on a contract or jurisdiction. 5 December 2024 is the announced adoption date; publication of this consolidated file is not separately confirmed.

  2. S02 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/24 : Funded reinsurance, October 2025
    Passages and scope

    Effective 27 October 2025; official version register checked 23 October 2026.

    §§2.5–2.7A, 2.14–2.23, 3.9–3.15, 4.7–4.13; PDF pp.8–10, 14–17, 19–22 / printed pp.7–9, 13–16, 18–21

    Recapture planning, access and transfer processes, illiquid assets, uncertainty over collateral replenishment and matching-adjustment eligibility.

    UK supervisory expectations. Individual contractual rights require separate analysis; no universal recapture deadline is prescribed. The immediate-recapture limit metric is distinct from the operational plan.

  3. S03 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Life Insurance Stress Test: 2025 Results
    Passages and scope

    Balance sheets at 31 December 2024; LIST 2025 modelled scenarios

    Executive summary; §§1.3–1.4, 2.1–2.2; Annex 2; Annex 3; footnotes 4 and 7

    Primary aggregate results. Annex 2 reports £12.3bn of liabilities recaptured; SCR coverage 154% to 144%; SCR +6% and eligible own funds −1%. Separately, the core scenario reports estimated prescribed sales of £3.4bn and additional trades of £0.9bn of sub-investment-grade bonds.

    Recapture covers the material-exposure subset, whose firm count is not disclosed in Annex 2. No target probability or FX shock for recapture. £12.3bn measures liabilities; no aggregate amount of received assets or recapture cash needs is published. Core sales do not measure recapture-specific sales.

  4. S04 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23LIST 2025: Scenario specification, guidelines and instructions
    Passages and scope

    Final instructions for 2025 exercise; shocks applied to 31 December 2024 balance sheets

    C.1–C.1.2, printed pp.21–23 / PDF pp.23–25; A.2.2 and A.3.2; A.4.2(8), printed p.16 / PDF p.18; D.4, printed pp.25–26 / PDF pp.27–28; D.8, printed p.27 / PDF p.29; Annex 1, printed pp.40–41 / PDF pp.42–43

    Exact recapture instructions: modified Stage 3 after Stage 2; counterparty with largest immediate solvency-ratio impact; stressed minimum contractual collateral; derivatives settled before recapture; beneficial ownership on day 1 and legal ownership within six months; MA eligibility and sale conditions. The prescribed 25% rebalancing excludes recaptured collateral.

    Exercise assumptions and conventions, not universal insolvency rights or observed settlement delays. Management-action horizons guide modelling rather than forecast a timeline. Stages 1 and 2 allow extra liquidity drawings with shortfalls reported; Section C restricts drawings to prearranged facilities.

  5. S05 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Annex 4: Life Insurance Stress Test 2025 insurer-specific results
    Passages and scope

    Eleven UK insurance legal entities, 31 December 2024 balance sheets; core scenario

    General information, PDF pp.2–4; core tables in remaining pages

    The annex explains business mix, management actions and ring-fenced with-profits funds. Firm-level tables cover the core scenario only.

    Subsidiary ratios do not describe all group resources; comparisons without business-mix and ring-fencing controls can mislead. No named attribution of recapture loss.

  6. S06 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23PRA Rulebook : Technical Provisions
    Passages and scope

    Rulebook accessed 23 October 2026; rule 2.4 effective 1 January 2016, rules 4.1–4.2 displayed as effective 31 December 2020.

    Technical Provisions 2.4–2.5, 3.1, 4.1–4.2; definition of cost-of-capital rate and 4A–4B for calculation context

    Direct UK rule source: technical provisions comprise best estimate and risk margin; the latter reflects the cost of own funds needed to cover the SCR over the obligations’ lifetime.

    Rule 2.5 provides an exception for cash flows replicable with market instruments. No full risk-margin calculation is attempted. The indexed web view displays 21 October 2026; direct capture explicitly displays the Rulebook as at 23 October 2026.

  7. S07 · Just Group plc · Accessed: 2026-10-23Just Group plc : Annual Report and Accounts 2025
    Passages and scope

    31 December 2025 reporting date; contractual arrangements disclosed as of that date.

    Note 27(c)(iii), printed p.205 / PDF p.207; note 27(d), printed p.206 / PDF p.208; note 24, printed p.198 / PDF p.200. LTM glossary: printed p.227 / PDF p.229.

    Describes collateral structures, including lifetime mortgages held and managed by Just whose returns accrue to an unnamed FundedRe partner. Separates ring-fenced assets from liquidity resources.

    Interested issuer source. No complete treaty, named counterparty for this structure, recapture cash requirement or actual transfer timetable is disclosed. The £1,970m trust aggregate spans several arrangements and is not FundedRe cash. Publication date differs between the official index (27 February) and S25 (7 March); document approved on 26 February.

  8. S08 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS7/18 : Solvency II: Matching adjustment, current and future versions
    Passages and scope

    Current: published 23 October 2025, effective 27 October 2025. Future: published 29 July 2026, effective 31 December 2026.

    Overview; Current version; Future version

    Defines the matching adjustment as an adjustment to the discount rate for eligible obligations and confirms version dates.

    The July 2026 version takes effect only on 31 December 2026, after the article cutoff.

  9. S09 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/19 : Liquidity risk management for insurers, November 2024
    Passages and scope

    Effective 31 December 2024; current status checked against S20.

    §§2.5–2.6, 2.17, 3.2, 4.11, 5.8–5.12, 6.3, 7.3; PDF pp.7, 9, 10–15, 17, 19–23

    Separates solvency and liquidity; addresses available assets, committed facilities and intrahorizon cash-flow low points.

    General liquidity-risk expectations; no LIST-specific or firm-specific cash shortfall can be inferred.

  10. S10 · Just Group plc · Accessed: 2026-10-23Just Group plc / Just Retirement Limited / Partnership Life Assurance Company Limited : Solvency and Financial Condition Report as at 31 December 2025
    Passages and scope

    31 December 2025 reporting date, group and two UK regulated insurance entities.

    P.6, JRL/PLACL direct facility access; §C.4 p.43, liquidity; §C.1.3 p.38, collateral cross-reference to annual report; §D.1.8 p.59.

    Reports direct access for the two subsidiaries to the £400m facility, broadened in 2025. Explains liquidity risk is managed through operational measures and stress tests rather than inclusion in the SCR; contingency funding considers timing, cost and difficulty of options.

    Issuer disclosure without full contracts. Direct access does not quantify a subsidiary allocation or an amount earmarked for recapture. Publication on 27 March is confirmed by official index S27 and S25 p.18.

  11. S11 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23PS13/24 : Funded reinsurance
    Passages and scope

    July 2024 final policy; parts of SS5/24 subsequently amended in October 2025.

    §§1.17–1.19, 2.20–2.24, 2.58–2.60, 2.68–2.70

    Consultation response: provide for long-term management of recaptured assets when sale at the expected price is not possible, even allowing for collateral haircuts.

    Explains the original policy. Use S02 and S16 for current wording and status.

  12. S12 · International Association of Insurance Supervisors · Accessed: 2026-10-23Application Paper on resolution powers, preparation and plans
    Passages and scope

    Final paper published 13 July 2026.

    §2.4, PDF pp.13–15; Box 1 and footnote 14, PDF pp.14–15; §4.5, PDF pp.28–30; status statement PDF pp.2, 6

    Recent analysis of recapture and collateral in asset-intensive reinsurance: contagion, operational capacity and legal availability of collateral.

    Application guidance creating no new standards. Stay powers depend on applicable law; several examples concern cedant resolution and do not establish an automatic block on every recapture following reinsurer failure.

  13. S13 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Life Insurance Stress Test 2025 results: Annex 4 : insurer-specific results
    Passages and scope

    Individual core-scenario results based on 31 December 2024 balance sheets

    Publication date and introductory paragraph

    The named publication on 24 November follows the 17 November sector results and covers the core scenario.

    The page does not disclose firm-level exploratory recapture results.

  14. S14 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Insurance stress testing : LIST 2025 and LIST 2028
    Passages and scope

    Page updated 3 July 2026; status checked 23 October 2026; next exercise intended for January 2028

    LIST 2028 and LIST 2025 sections; last-updated line

    Official publication register: final instructions on 16 January 2025, sector results on 17 November, firm results on 24 November. The next LIST is intended for January 2028.

    3 July is the page-update date. The next exercise’s design may change; targeted searches at 23 October identified no newer methodology notice.

  15. S15 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23Approach to life insurance stress test 2025
    Passages and scope

    Methodological approach preceding January 2025 final instructions

    Executive summary; §§4.17–4.19

    The approach specifies sector-only publication of exploratory findings to support modelling capability development.

    Final instructions S04 govern detailed calibration and requirements. This document explains disclosure policy rather than provide 2025 results.

  16. S16 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/24 : Current-version register
    Passages and scope

    Current version published 23 October 2025, effective 27 October 2025; checked 23 October 2026.

    Current version; Past versions

    The official register still identifies the October 2025 edition of SS5/24 as current.

    A version register alone cannot rule out every later communication. No final CP8/26 decision was identified in targeted searches on 23 October 2026.

  17. S17 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23CP8/26 : Funded reinsurance
    Passages and scope

    Consultation closed 31 July 2026; proposed implementation 1 July 2027; proposed savings provision for risks fully transferred on or before 30 September 2026.

    §§1.5–1.8, 1.15–1.16, 3.6, 3.22, 3.27–3.38

    Proposal for the counterparty default adjustment. Identifies legal uncertainty and resolution regimes not fully tested under stress.

    Proposal, not presented as rules in force. No final decision found as of 23 October 2026; the response period has nevertheless ended.

  18. S18 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23CP8/26 Appendix 1 : Draft Funded Reinsurance Instrument [2026]
    Passages and scope

    Draft instrument; commencement date remains [DATE].

    Annex B, 24A.2; PDF pp.3–4

    Proposed conditions for recognising collateral protections in the treatment of the reinsurance recoverable.

    No proposed provision should be described as already effective.

  19. S19 · Bank of England · Accessed: 2026-10-23Financial Stability Report : November 2024
    Passages and scope

    November 2024 financial-stability analysis, used only for the conditional mechanism.

    Asset-intensive reinsurance discussion: recapture, asset rebalancing and liquidity mismatch

    Describes how recapture and rapid rebalancing could produce distressed sales; notes limited early-exit options for UK annuities.

    Risk scenario, not an observed forced sale. Historical volumes are not used as a 2026 snapshot.

  20. S20 · Bank of England / Prudential Regulation Authority · Accessed: 2026-10-23SS5/19 : Current-version register
    Passages and scope

    Current version published 15 November 2024, effective 31 December 2024.

    Current version

    Confirms the current status of S09 at capture.

    Version register; detailed expectations appear in S09.

  21. S21 · International Association of Insurance Supervisors · Accessed: 2026-10-23Revised Application Papers on recovery and resolution : consultation and final-publication page
    Passages and scope

    Initial consultation page updated with final papers published 13 July 2026.

    Final resolution paper; final documents dated 13 July 2026

    Confirms final publication of S12 despite a URL containing the original consultation date.

    Distinguish the page’s creation date from final publication of its linked document.

  22. S22 · International Association of Insurance Supervisors · Accessed: 2026-10-23IAIS ICPs and ComFrame adopted in December 2024
    Passages and scope

    Adoption announcement dated 5 December 2024.

    Announcement and linked ICPs/ComFrame

    Confirms the adoption date of the S01 compilation.

    Adoption of the compilation does not mean every ICP was revised in 2024.

  23. S23 · International Association of Insurance Supervisors · Accessed: 2026-10-23Insurance Core Principles and ComFrame : current standards page
    Passages and scope

    Current standards page identifies the latest corpus update as December 2024.

    ICPs and ComFrame download and update information

    Supplementary check of the reference version used for ICP 13.

    Does not replace reading the relevant paragraphs in S01.

  24. S24 · Legal & General Group · Accessed: 2026-10-23Legal & General Group Plc : Solvency and Financial Condition Report 2025
    Passages and scope

    Group and specified SFCR reporting perimeters, at 31 December 2025.

    Section C.4, pp.59–61; approval p.10.

    Liquidity arrangements: resources, facilities, coverage monitoring by reporting perimeter and monthly three- and twelve-month stress tests. £2,901m cash/equivalents are in shareholder funds; the syndicated facility is £1.5bn.

    Issuer data and assessments. Group or specifically scoped resources, not allocated to a FundedRe recapture scenario; no public measure of its liquidity shortfall or required sales.

  25. S25 · Just Group plc · Accessed: 2026-10-23Just Group plc : Results for the six months ended 30 June 2026
    Passages and scope

    Results at 30 June 2026; announcement dated 22 September 2026.

    P.11, facility; p.18, preparation and covenant; p.1, acquisition; p.4 note 3, perimeter change.

    The announcement confirms a £400m facility from eight banks, available until June 2027 and undrawn since inception in June 2022. Confirms the acquisition by Brookfield Wealth Solutions on 1 April 2026.

    Group facility not publicly allocated to a specific recapture. Undrawn status is as stated in this announcement; no separate observation date is provided for that statement. The June perimeter includes Blumont UK Annuity from 1 April and is not mechanically comparable with December. Does not republish the S07 LTM clauses.

  26. S26 · Just Group plc · Accessed: 2026-10-23Just Group : Results, reports and presentations, 2026 index
    Passages and scope

    Public index checked 23 October 2026; dates of listed documents.

    Row “Results for the year ended 31 December 2025”, dated 27 February 2026, linking to the annual report.

    Checks the date associated with the annual report in the issuer index. S25 separately gives 7 March as its publication date.

    Changing issuer index. A row date can cover a group of materials; it is retained as a documentary check alongside the reports’ own dates.

  27. S27 · Just Group plc · Accessed: 2026-10-23Just Group : Solvency and Financial Condition Reports index
    Passages and scope

    Public index checked 23 October 2026; dates of listed documents.

    First row: SFCR at 31 December 2025, dated 27 March 2026.

    Confirms the publication date of the 2025 SFCR; S25 p.18 also confirms it.

    Changing issuer index. A row date can cover a group of materials; it is retained as a documentary check alongside the reports’ own dates.

This analysis is not investment advice.

// cite this analysis

l0g, “When risks return to the insurer”, l0g.fr, published October 23, 2026, updated October 23, 2026, https://l0g.fr/en/analysis/insurers-asset-managers-07-risks-return/


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