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Inclusion of insurance within capital frameworks: Navigating the possibilities

By Mark Hannam | February 8, 2024

The latest article from our Operational Risk Solutions team provides a spotlight on complexities and opportunities of including insurance within regulatory capital frameworks.
Financial, Executive and Professional Risks (FINEX)

The conversation surrounding the inclusion of insurance within regulatory capital frameworks, whilst not new, remains a critical area for exploration in risk management. Over the past two decades, this concept has evolved, yet its practical application continues to challenge many professionals.

At WTW, we have taken a deep dive into this subject to shed light on both the complexities and the opportunities inherent in this integration.

Understanding the regulatory landscape

Regulatory frameworks such as Basel II/III and Solvency II offer a context for this discussion but lack clear directives on integrating insurance into capital models. A detailed examination of these frameworks reveals nuances that can influence a firm's approach. For instance, the way operational risks are treated under Basel III presents unique opportunities for the inclusion of insurance solutions.

Quantitative insights: The overlap and impact

The proportion of capital requirement attributed to operational risk varies significantly across financial institutions. Banks and insurance companies often allocate between 5% and 15% for this purpose, whilst asset management firms may allocate up to 80%.

In many cases, traditional insurance policies covering risks like crime and professional indemnity overlap with these operational risk capital requirements; effectively double counting your protection.

WTW's analysis of market data and experience indicates that a strategic integration of insurance can lead to a significant offset in capital allocation for these risks, freeing up resources for reinvestment.

WTW's expertise in action

Our work with leading financial institutions demonstrates the practicality of integrating insurance into capital frameworks. WTW’s approach involves a comprehensive review of existing insurance policies, followed by a guided modelling approach to quantify the impact of these policies on capital requirements. Our collaboration with banks, asset management firms, and insurance companies has yielded measurable benefits, allowing these institutions to optimize their capital structures efficiently.

Legal and best practice framework

Incorporating insurance into a capital framework is not just a strategic decision but also a regulatory one. Firms must navigate a complex legal landscape, ensuring compliance with relevant regulations while leveraging opportunities for capital optimization. WTW advises a thorough review of regulatory guidelines and best practices in this area, ensuring that any integration aligns with both legal requirements and industry standards.

Benefit analysis: A closer look

Based on WTW's extensive experience, large banks can expect a 3-8% benefit in operational risk capital requirements through the integration of insurance. For asset managers and insurance companies, this mitigation benefit can reach 15-20%. These figures underscore the significant impact that thoughtfully integrated insurance solutions can have on a firm’s capital efficiency.

Next steps: WTW's methodology for growth

WTW’s robust methodology for embedding insurance within capital frameworks begins with a detailed analysis of a client's risk profile and the insurability of these risks. Our Operational Risk Solutions team, leveraging their vast experience across the UK, Europe, US, and other advanced economies, guides institutions through the process of recalibrating their capital composition. This methodology not only optimizes capital allocation but also ensures that our clients remain agile and resilient in the face of evolving economic and regulatory landscapes.

In conclusion, while integrating insurance into capital frameworks presents challenges, the potential benefits are substantial. With WTW's expertise and tailored methodologies, financial institutions can navigate this complex territory, unlocking new avenues for growth and stability.


Associate Director, Consulting and Client Management, ORS – FINEX GB


Head of FINEX Western Europe

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