Why Spreadsheets can send the Pillars of Solvency II Crashing Down


Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?

Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.

A little background about spreadsheets might help.

Who needs an IT solution when you can have spreadsheets?

Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?

You probably haven’t heard of spreadsheet hell

Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.

And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.

Solvency II Impact on Spreadsheet-based Financial and IT Systems

Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.

The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.

There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.

A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.

Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.

Because of spreadsheets you now need an IT solution

It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.

One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.

More Spreadsheet Blogs


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Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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2015 ESOS Guidelines Chapter 1 ? Who Qualifies

The base criteria are any UK undertaking that employs more than 250 people and/or has a turnover in excess of ?50 million and/or has a balance sheet total greater than ?43 million. There is little point in attempting to separate off high polluting areas. If one corporate group qualifies for ESOS, then all the others are obligated to take part too. The sterling equivalents of ?38,937,777 and ?33,486,489 were set on 31 December 2014 and apply to the first compliance period.

Representatives of Overseas Entities

UK registered branches of foreign entities are treated as if fully UK owned. They also have to sign up if any overseas corporate element meets the threshold no matter where in the world. The deciding factor is common ownership throughout the ESOS system. ecoVaro appreciates this. We have seen European companies dumping pollution in under-regulated countries for far too long.

Generic Undertakings that Could Comply

The common factor is energy consumption and the organisation’s type of work is irrelevant. The Environmental Agency has provided the following generic checklist of undertakings that could qualify:

Limited Companies Public Companies Trusts
Partnerships Private Equity Companies Limited Liability Partnerships
Unincorporated Associations Not-for-Profit Bodies Universities (Per Funding)

Organisations Close to Thresholds

Organisations that come close to, but do not quite meet the qualification threshold should cast their minds back to previous accounting periods, because ESOS considers current and previous years. The exact wording in the regulations states:

?Where, in any accounting period, an undertaking is a large undertaking (or a small or medium undertaking, as the case may be), it retains that status until it falls within the definition of a small or medium undertaking (or a large undertaking, as the case may be) for two consecutive accounting periods.?

Considering the ?50,000 penalty for not completing an assessment or making a false or misleading statement, it makes good sense for close misses to comply.

Joint Ventures and Participative Undertakings

If one element of a UK group qualifies for ESOS, then the others must follow suit with the highest one carrying responsibility. Franchisees are independent undertakings although they may collectively agree to participate. If trusts receive energy from a third party that must do an ESOS, then so must they. Private equity firms and private finance initiatives receive the same treatment as other enterprises. De-aggregations must be in writing following which separated ESOS accountability applies.

Are Target Operating Models strategic compasses?

The short answer is they usually are, because every organisation needs a road-map of where they are going. Target operating models can be complex documents with illustrative details including project management structures, special tools, implementation procedures and management metrics. They can also be simple statements, as for example Winston Churchill?s promise that ?we shall fight them on the beaches, on the landing grounds and in the fields? which gave Britain the strategic direction it needed.

Many initiatives unfortunately fail because managers are ?too busy? to bottom on what their target operating model should say, or simply don’t believe in paperwork. As a result, promising initiatives may blunder off course or die a slow death without them really noticing. We cannot manage what we cannot measure, which is where the management metrics fit in. One of my favourite quotes is ?if you don’t know where you are going any road will get you there? which is what the Cheshire Cat said to Alice in Wonderland when she got lost.

The author blundered through life without a plan because there was no one else with his particular brand of imagination. The current business climate is different because everybody is trying to ramp up, and investors want to know exactly what is going to happen to their money and by when. Hence a target operating model can be indispensable throughout a change or product cycle.

The benefits of having a measurable operations / technology plan can produce powerfully tangible results if the organisation follows through on it. Built-in metrics with milestones are powerful tool for management, and, when they map through to the company financial plan almost irreplaceable as cash-flow forecasters.

Other benefits may include:

  • Shorter times to market and greater agility when launching new ideas
  • Reduced investor risk through a predictable process that’s readily monitored
  • A stable operating environment where there is consensus on direction
  • Greater likelihood of delivering on time and leading to repeat orders
  • A more cost-effective process, with less risk of loss of quality and money

Although it dates back a few years the Wills UK and Ireland Retail model still provides an excellent benchmark of a target operating plan that worked. The strategic goals were exceptionally clear, and they brought in a proven project manager to help them drive the program forward.

We have delivered advanced business management services to many of our clients, and believe you will find our personalised approach time-efficient and effective too.

The Cloud: Changing the Game for Small Businesses

There is a consensus among cloud experts that the onset of cloud computing will benefit small organisations the most. In fact, many even go as far as saying that the cloud and small businesses are a match made in IT heaven. How much of this is true and how much of this is merely part and parcel of the hype surrounding cloud computing?

The Cloud as the Great?Equaliser

If you closely examine the essential characteristics of cloud computing, particularly public cloud services, you will see why small organisations would be very interested in the cloud, and would eventually flock to it, like moths to a flame. And why not? Cloud computing is turning out to be the weapon that can allow small and medium organisations to compete on a more level playing field against large enterprises.

Here are some cloud computing benefits that may just close the gap between the two.

  • Significantly lower IT spending. With little to no investment at all on hardware infrastructure and practically zero maintenance costs, SMBs that would have required substantial capital for IT are now finding it easy to get a business started from scratch or develop and test out new products by using the cloud as the backbone of their IT set-up. The pay-as-you-go pricing scheme that cloud computing offers allows companies to start small and scale up as needed, or when the revenue starts coming in.
  • Higher employee productivity. Licensing fees for software applications can run high even if you don’t have a large staff. Good thing there are now a host of cloud-based office tools – word processors, spreadsheets, presentations, accounting systems, etc. – that can boost employee productivity without the corresponding costs that small businesses can ill afford. Plus, team members in remote locations can continue to collaborate with the rest through any internet-connected device in real time.
  • Easier, better communication. The easy accessibility of communication apps has also changed the way employees interact with fellow employees and more importantly, with customers. Whether through email, instant messaging, or social networks, cloud services have given individuals and businesses more ways of giving and getting feedback. The best thing about it is that most of these services don’t cost much or are even free, giving SMBs ample tools to create better products and improve service.
  • A Look at the Figures Many small businesses are already seeing the potential in the cloud, with SaaS (Software as a Service) applications most commonly used among the early adopters. These services include email and other communication apps, file sharing, and backup.

In a February 2012 Edge Strategies survey (commissioned by Microsoft) of 3,000 small businesses in the US, the following data came to light:

  • The number of small companies with 2 to 10 employees using paid cloud services will triple in the next three years;
  • Current cloud users report purchasing an average of 4 services in the cloud now and expect to use 6 in the future;
  • Fifty percent agree that cloud computing is going to become more important for businesses such as theirs.

Further, a survey of 323 SMBs recently released by social business site Spiceworks and sponsored by EMC reveals that from 48 percent at the start of 2012 and 28 percent a year ago, 62 percent of the businesses surveyed now use some type of cloud app.

What these numbers show is that cloud adoption among small and medium enterprises is starting to gain ground and for sure, more will do the same as understanding and awareness increase. Yes, these businesses should still perform their due diligence as there is no one-size-fits-all cloud solution. But for those companies who have managed to find the right cloud apps and services for their needs, it’s all sunny skies up ahead.

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