New reporting models for insurers: what changes in 2027 with Order ECM/974/2026

Key data

Insurers managing insurance linked to pension commitments have a clear deadline: January 30, 2027 to adapt their quantitative information models to the new requirements. Order ECM/974/2026 is not a cosmetic change: it directly affects compliance and reporting departments, which will need to update fields, data structures and submission deadlines to the supervisor.

The regulation modifies Order ECM/271/2025 and integrates into a single framework the statistical-accounting models on pension insurance that until now were regulated by Order EHA/1928/2009, a regulation nearly two decades old. The result is a consolidated regulatory framework aligned with the Solvency II Directive reformed in 2024.

What does this regulation establish?

Order ECM/974/2026 introduces the following specific changes to the reporting framework for insurance entities:

The central objective is twofold: consolidate all quantitative supervisory information into a single regulatory body and modernize the models to reflect the current reality of the insurance market and pension commitments.

Economic and operational impact

The impact of this regulation is not of a direct sanctioning type with published fines, but rather operational and compliance-related. The specific consequences for affected entities are:

• Redesign of information systems: IT and reporting departments will need to incorporate the new fields (redemption due to execution of primary residence and collective insurance expenses) into their databases and extraction flows.
• Update of brackets: Contribution and age brackets have been reviewed, which may involve changes in historical data segmentation and loading processes.
• Separation of models by type of mutual association: Mutual associations for social protection that previously sent a unified model will now need to identify and separate information according to their specific typology.
• New submission deadlines: Adaptation to the Solvency II Directive reformed in 2024 may alter internal schedules for data closure and validation.
• Long-term simplification: The repeal of Order EHA/1928/2009 eliminates the need to maintain two parallel regulatory frameworks, reducing compliance burden once the transition is complete.

Who does it affect?

• Insurance entities that operate insurance that instruments pension commitments (collective company insurance, insured pension plans, etc.).
• Reinsurance entities subject to quantitative supervisory information models.
• Mutual associations for social protection, especially those that until now sent unified models and will need to adapt to the new separation by type.
• Groups of insurance and reinsurance entities, which are also included in the scope of the modified Order ECM/271/2025.
• Regulatory compliance, reporting and technology departments of all the above entities.

Practical example

A mutual association for social protection that manages collective insurance for client companies currently sends to the General Directorate of Insurance and Pension Funds (DGSFP) a single quantitative information model in accordance with Order EHA/1928/2009.

With the entry into force of Order ECM/974/2026 on January 30, 2027, this mutual association will need to:

1. Identify its specific typology as a mutual association for social protection and determine which separate model corresponds to it according to the new structure.
2. Incorporate into its data system the field "collective insurance expenses", which previously did not exist as a separate field.
3. Add the field "redemption due to execution of primary residence" for those insured who have exercised this right.
4. Review the updated contribution and age brackets to correctly reclassify the portfolio.
5. Adjust the submission schedule to the supervisor in accordance with the new deadlines aligned with Solvency II 2024.

If this mutual association does not complete the adaptation before January 30, 2027, its information submissions to the supervisor will be non-compliant with the current regulation, with the consequent regulatory risk.

What should companies do now?

1. Identify if you manage pension insurance: Verify if your entity operates insurance that instruments pension commitments. If so, this regulation directly affects you.
2. Audit current reporting models: Compare the models you currently send with the new requirements of Order ECM/974/2026 to identify gaps (new fields, updated brackets, separation by type of mutual association).
3. Plan technological adaptation: Involve IT teams to incorporate the new mandatory fields (redemption due to execution of primary residence and collective insurance expenses) into extraction and reporting systems.
4. Review new submission deadlines: Update the internal schedule for data closure and validation in accordance with deadlines adapted to the Solvency II Directive reformed in 2024.
5. Withdraw processes based on Order EHA/1928/2009: Once the transition is complete, eliminate any reference or process linked to the repealed regulation to avoid duplicities.
6. Deadline: January 30, 2027 for the partial entry into force of the new models. Plan the project with sufficient margin.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-19424