This article outlines a collection of common and problematic pitfalls I’ve seen in ORSA stress and scenario testing, capital modelling, and governance. Some are technical, some cultural, and all are worth addressing if we want the ORSA to do what it should: support better decision-making under uncertainty.

These insights reflect my experience across a wide range (and varying quality) of ORSAs, including independent reviews, informal and formal regulatory feedback (including from the Prudential Authority), informal discussions with regulators, and public statements from supervisors across multiple jurisdictions.

1. Toothless Scenarios and Soft Stresses

• Many ORSA scenarios are too mild to test anything meaningful.
• Often there’s no indication of severity. Is this a 1-in-5 or 1-in-50 event? Without context, interpretation is impossible.
• Firms are sometimes surprised they survive a 1-in-200 scenario, forgetting that survival at that level is by design.

2. Recycled, Stale, or Misaligned Scenarios (and Ignored Emerging Risks)

• Same tired stresses reused each year without meaningful refresh.
• Narrative scenarios assigned numerical calibrations that don’t match the story.
• Horizon scanning is often absent or perfunctory; emerging risks must be systematically identified and tested.
• Scenario testing should anticipate what could plausibly happen next, not merely repeat past events.

3. Implausible or Alienating Scenario Design

• Unrealistic or inconsistent scenarios alienate management and the board.
• Severe scenarios are valuable, but they must be framed with historical precedent or research to be credible.
• Overconfidence in models is dangerous; even the best models can fail catastrophically, as history shows.

4. Over-Engineering vs Usefulness

• Attempting to build the “most accurate” pandemic scenario misunderstands the point: scenarios are for learning and planning, not for prediction.
• Prioritise strategic insight over technical perfection.

5. Investment Returns Detached from Reality

• While not common, flat investment income across stress scenarios is a serious modelling failure.
• Investment returns must reflect changes in asset levels and market conditions under stress.

6. LACDT: Tax Calcs Behaving Badly

• Deferred tax recoverability often lacks robust testing.
• Future stressed profits must first create a DTA before any LACDT benefit can be recognised. Tiering here can hit you – more than you considered for the base SCR calc and your QRT.
• Income vs capital gains treatment and tax fund nuances are often overlooked.
• Just because LACDT can’t be negative (per the FSIs), doesn’t mean you can’t have existing DTAs fail recoverability testing in a stress and have loss amplification from deferred taxes!

7. Tiering and Fungibility Constraints Not Considered

• Capital tiering restrictions often ignored under stress.
• Assumed fungibility between entities or tiers can be unrealistic, especially under stress scenarios.
• See the point about DTA and tiering above too.

8. Over-Reliance on Standard Formula Extrapolation

• Normal distribution assumptions are often inappropriate; t-distributions, Lognormal, Pareto tails, or piecewise fittings are better suited.
• Ideally your own experience should be able to inform 1 in 10 stresses and act as a sanity check on scaled 1-in-200 stresses.
• Thin historical experience leads to poor calibration of rare-event risks, especially for equity markets.
• And really, there are several standard formula stresses that are probably not appropriate as a starting point. Some non-life cat stresses may be too conservative – and mass lapse has its critics, but life cat risk, expense risk, and retrenchment risk stresses are likely too low.

9. Unrealistic Business Volume and Expense Assumptions

• Base cases often adopt stretch targets as certain outcomes.
• Expenses are incorrectly assumed to scale perfectly down with policy volumes, ignoring the reality of fixed costs.

10. Incurred vs Paid Confusion

• Claims incurred and claims paid are routinely confused. The impact on profit vs balance sheet and cash can be counter-intuitve.
• Timing differences, especially under IFRS 17 (LCI/CIP dynamics), matter for liquidity and solvency modelling.

11. Short Projections for Long Risks

• Three-year horizons are insufficient for long-burn risks including the obvious candidate – climate change.
• Five years should be the baseline internally, with qualitative insights over longer horizons. Yes, the reliability decreases as the term increases, but it can still be informative. You may chose to disclose only 3 years more broadly, but the longer view is important to at least understand trends.
• Long-term (10–30 year) qualitative assessments should supplement the ORSA, accounting for amplifying systemic interactions.

12. Disconnect Between ORSA and Management Forecasts

• Management runs the business based on one view; the ORSA is prepared using another.
• Without alignment, the ORSA cannot pass the use test or add value to strategic decision-making.

13. Ignoring Dynamic Risk Interactions

• Risks are often modelled in isolation.
• In reality, correlations and feedback loops matter: lapse impacts guarantees, claims experience shifts reinsurance pricing, and market volatility affects lapse and claims simultaneously.

14. Either No Management Actions, or Superhero Versions

• Some ORSAs model no management actions (overly conservative but unrealistic).
• Others assume immediate, flawless actions without delay or cost (equally unrealistic).

15. Unexplained Profit and NAV Changes

• ORSA profit projections must reconcile to balance sheet movements.
• Adjustments between IFRS and SAM/Solvency II frameworks should be clearly documented.

16. ORSA Process Too Slow to Be Relevant

• A nine-month ORSA development cycle leads to stale outputs.
• ORSA timing must be aligned with the business planning cycle and responsive to external shocks.

17. Weak QA and Model Review

• Detailed, independent model review is often absent.
• Common failures include claims timing mismatches, unrealistic ROEs, omitted asset growth dynamics, and unstated assumption interactions.

18. Boilerplate Overload, Insight Underload

• ORSAs are often bloated with standard wording, burying the important insights.
• Focus must remain on what is changing and what genuinely informs management decisions.

19. No Trigger or Process for Out-of-Cycle ORSA

• Firms sometimes only trigger an out-of-cycle (OOC) ORSAs for an SCR breach — far too late. If the risk or solvency situation (internal or external) has changed, it’s time for an OOC.
• Proportional, trigger-based OOC ORSAs must be defined and actioned when material changes occur.
• An OOC doesn’t need to cover the entire process or the full 80 page report. Just the key parts that have changed.

20. Reverse Stress Testing as an Afterthought

• Reverse stress testing needs to explore genuinely different failure modes, not just ramp up severity.
• Defining what constitutes “failure” (capital breach, strategic collapse, or profitability death spiral) needs careful thought.

21. Weak or Missing Rationale for Scenario Selection

• Documenting why scenarios are chosen reveals how the firm prioritises risk.
• Disconnects between identified risks and tested scenarios highlight critical weaknesses.

22. Board Engagement and Use Test Failures

• Board sign-off without meaningful engagement misses the point.
• Effective risk functions bring ORSA components to the Board repeatedly during the year to drive strategic debate.

In Closing

None of these issues is inevitable. Most stem from habits — some from lack of scrutiny, others from good intentions that weren’t tested hard enough. But if the ORSA is to support real-world resilience, it has to reflect how capital and risk actually behave. That means grounding assumptions, engaging the business, and constantly asking: “Would I act on this?†

If the answer is no, the ORSA needs work. If the answer is yes, you’re on the right track.

As the parametric insurance market evolves, so too must our approach to capital modeling. The challenges are significant, but so are the opportunities for innovation and more accurate risk assessment.

• Growing regulatory acceptance as parametric solutions prove their value. (Issues of insurable interest have posed problems. Currently in testing in “sandbox” regulatory environments in a few countries including South Africa, where it has traditionally been viewed as non-compliant.)
• Addresses previously uninsurable risks for corporates and governments, filling protection gaps. Good application for captive insurers (I’ll cover this more in a later post)
• Complements reinsurance by covering areas traditional policies often exclude
• Primarily used for commercial lines, but personal applications are emerging
• Significant applications for transferring country-level risk for governments and certain NGOs
• Basis risk remains a consideration, but can be mitigated somewhat through careful structuring

Exciting developments include parametric ETFs, allowing investors to participate in this innovative market. We’re also seeing creative applications using new data sources, like phone signals to assess footfall.

I can get theoretically excited about smart-contracts for parametric insurance, but in practice this quickly feels like unnecessary complexity with limited current benefit.

Parametric insurance can compete with reinsurance, but it’s often best used in combination, or as a tool for reinsurers to spread risk

As always, professional advice is crucial when exploring these solutions.

With a hefty additional dose of approximations, I get about the same figure all the way back to 1998.

This amounts to an insurer failing every other year.

The primary causes? In every case it’s more than one thing. Here are some of the recent common causes – I’ll expand on each of these in a series of posts.

1 Underwriting risk and pricing

Mispricing, particularly when moving into new markets or new lines of business is a common starting point.

Funeral insurers feeling competitive pressures are looking for new markets – typically semi-underwritten life products, misguided savings products, niche legal expense cover products, or further afield into non-life proper. Here be dragons.

For all the benefit of diversification from a statistical perspective, the research says that focussed insurers fail less often.

Climate change is going to break underwriting and pricing models, meaning that even previously well understood risks increase the chance of failure.

Non-life insurers need to get claims inflation under control – or at least continue the unpopular premium and excess increases to restore sustainability to premium rates.

2 Cost of customer acquisition outstripping funding and VNB

Rapid growth may be many insurers’ dreams.

However, too rapid growth can strain capital adequacy. Rapid growth can also be a telltale sign of under-pricing, leading to large volumes of unprofitable business. Selling many policies that don’t cover their acquisition expenses is a short cut to real trouble.

A worrying sign here is the reduction in VNB margins across broad sectors of the underwritten life insurance space. This ramps up pressures to dilute new business metrics, which is a terrible idea.

3 Misuse, and misrepresentation of (financial) reinsurance

Reinsurance is a fundamentally important tool to manage risk, manage capital requirements, gain expertise in a new market, and to provide liquidity.

Reinsurance, especially financial reinsurance when misused, can obscure the deteriorating solvency position of an insurer and lead to a false sense of security for risk managers, NEDs, and regulators.

The principles on how to treat financial reinsurance and contingent commissions are about right – but the detailed rules and the rigour and honesty with which those principles are implemented sometimes are not.

The overall lesson is – the improvement in your solvency should reflect the actual risk transferred and economics of the transaction.

The most egregious error is claiming that a FinRe deal has resulted in an increase in assets without an increase in liabilities. Tricks of claiming that repayment of the commission (a loan) is contingent on future profits and therefore isn’t a liability are invalid. Games with contract boundaries include recognising the upfront commission (which is to be repaid over many years of renewing contracts), but not recognising years of future reinsurance premiums because the in-force policies have annual contract boundaries.

On contingent commissions, the key question to ask is “has my SCR gone down by more than the risk transferred?”. If one reinsures 70% of the portfolio using QS, but 90% of that risk comes back through contingent commission, then applying the FSIs blindly can result in a 10x overstatement of the benefit of reinsurance. You have shared 7% of the risk, not 70%.

My rule of thumb is not to take advice on the regulatory, solvency, or accounting treatment of the reinsurance from the one selling you the reinsurance.

4 Complex, incestuous asset transactions, and poorly controlled ALM

Aggressive asset valuations, typically of unlisted, illiquid investment that have some related party in the mix, are one of the clearest red flags for an insurer about to fail.  There is always the next Warren Buffet wanting to “invest the float† and make money in some undeveloped property, associated business, or beautiful basket of tulips.

Careful ALM is critical for long-tailed policies. There it needs to be managed carefully and regularly. Monitoring isn’t enough – there needs to be a mechanism to change the portfolio when mismatch parameters breach thresholds.

For other portfolios, sometimes a simpler portfolio that introduces less complexity, fewer tax risks, less operational and liquidity risks, is better than a supposedly more ALM-tuned portfolio that actually increases risks of catastrophic failure.

Asset concentration has been a primary cause of at least one major South African insurance failure before too. Although, as always, this wasn’t the single cause.

5 Taking large (binary) risks when already in trouble

As solvency positions decline, some CEOs, seeing the writing on the wall, choose to take significant risks that will either solve their solvency problem, or increase the impact of insolvency to policyholders.

Something as simple as continuing to write business, especially long-term business, when the solvency capital isn’t available to support this business places existing and new policyholders under additional risk.

Pinning hopes (and management bandwidth) on big-bang investment deals without addressing underlying operational concerns usually don’t pay off.

6 Failed corporate governance

Corporate governance failures are usually the second or third thing to go wrong. Poor internal controls, ineffective or insufficiently independent risk and compliance teams, and outright financial statement fraud mean that serious problems are overlooked, sometimes for years.

Fraud is more often a response to problems (especially where management believes they are in the right and it’s just a matter of time before markets/the cycle/business turns). In select cases, insurers are used as vehicles to instigate fraud as first step

Some boards and shareholders deprioritise good governance. When times are good it’s easy to emphasise good governance. What about when governance gets in the way of decisions executives want to make? Or when it raises awkward questions about pet projects? Or where the business is struggling but management is confident they can trade out of the difficulty as long as they are given the space and time?

It’s easy to do the right thing when it doesn’t come with costs.

7 Slow regulatory intervention

Too often, regulatory intervention is too slow and not targeted at the underlying causes. It’s hard to blame the regulator entirely, given the massive opposition to statutory managers and curatorships.

There are many amazing, skilled, and experienced individuals at our regulator. Are there enough? Is the quality and approach consistent? Are they hamstrung by insurers under resourcing their own control functions and lines of defence?

Can anything be done to decrease failure rates?

Having a strong, experienced, and independent actuary who pays close attention to the regulations and guidance is crucial. Your head of actuarial function should provide good advice on business issues. They should also occasionally constrain your options and make you rethink your positions.

A solid, experienced, and independent Head of Actuarial Function goes a long way.

Appropriate risk management and governance practices are defined in multiple different places, and they can all work well enough if followed diligently. Making sure the teams are experienced and skilled and empowered to tell truth to power is rather more difficult.

That’s the ballpark figure I usually work with as the minimum number of micro insurance policies required for scale. The expenses of running even a micro insurer are not that trivial.

For underwritten products within a full life licence? Larger premiums per policy but definitely more complexity. Competition is tougher too. Hyper local brands don’t translate into trust at this level. Viable niches may exist, but at what volumes?

You might wonder if there is scope to sell greater value products at higher premiums that can bring that number down in some contexts?

The rise of embedded insurance

Turns out this has been given plenty of thought already – “micro” insurance is the less popular name these days from a product and provider perspective. Inclusive Insurance certainly sounds better and more inclusive (!)

I think part of that push though was recognising the challenges and limits of truly “micro” insurance, at least at an individual level in providing commercially viable options that meet needs at the scale necessary.

Inclusive Insurance has been eclipsed in some words for “embedded insurance”, a term that talks less to the needs and objectives for society, and more to one that is practical and viable commercially. Embedding insurance in other products are services can drive down some of the costs, but then by virtue of being embedded, the absolute amount of premium is even further limited. Volumes may go up – and there have been some success stories here – but margins typically remain fine so I’m going to guess that my 40,000 may be too low in these instances. The success stories are in the 6- and 7-digit volume space.

Microinsurance licence restrictions

Back to “microinsurance” and the regulatory restrictions that apply in South Africa:

• Savings elements might seem attractive to increase premium size and provide “value” rather than a set price point. But savings elements are not permitted in microinsurance policies in South Africa.
• Loyalty schemes or cash back may be a way to attach greater value to a product, but again are not permitted in the microinsurance framework.
• Fairly large sums assured are possible within microinsurance – often attracting increased adverse selection or outright fraud.

Can product tailoring increase average premium?

Product tailoring can be expensive and can counter plans for
economies of scale while simultaneously targeting a smaller market. I’d still like to see more of this rather than pure commodity products. I’d be happy to be wrong if this approach meant a viable micro insurer could provide genuine value, see strong demand, and require fewer than 40,000 policyholders or comfortably sell more than that.

Microinsurance pros and cons – an important choice

A key point here is whether a standalone microinsurer is the right vehicle for a truly niche insurer? The increased governance and compliance policies effected by the major cell providers have frustrated cell owners and entrepreneurs, slowed down innovation and led them to look elsewhere. A microinsurance licence is a great option for some, but not a panacea for everyone.

I’ve helped insurers apply for licences, buy licences, consider alternative arrangements, and I’m sure at some point I’ll be working with micro insurers to transfers portfolios to other insurers and close down licences.

There is also opportunity to apply to the Prudential Authority for scope to do more with the licence, with careful consideration of the risks and capital.

Does digital fix everything?

Digital sales is a complex area. Some insurers have had some success with purely digital sales. But when these distribution channels are owned by someone else, the costs are not as low as “digital† might make you think. If NTUs are high, and premium collections are low, it can quickly become expensive. There’s a fine line between removing friction from a sales and underwriting process (which definitely improves sales) and making it so easy to “sell† that the customers haven’t really decided that they want what they’ve bought.

Parametric insurance – watch this space!

We should be doing far more with parametric insurance in South Africa. Thinking around climate risk and the positive role insurers can provide in this space (rather than only worrying about the risks it poses to them) may present some new opportunities. Insurers can apply their expertise in understanding and pricing risk, while providing a socially and economically beneficial product at a price that shows value and profit.

I have been pondering whether IFRS17 makes life interesting for microinsurers given the wording of FSM2 “Valuation of Assets, Liabilities and Eligible Own Funds” for microinsurers (issued by the PA). The interpretation and application challenges actually predate IFRS17. FSM2 makes some silent and unlikely assumptions around treatment of premium debtors for typical microinsurance business. More on that in a future article.

IFRS17 does make life interesting (in the worst meaning of the word) for microinsurers, in that they must all apply IFRS17 to their insurance contracts. There’s no reason not to apply the Premium Allocation Approach given restrictions on policy term – and this simplifies many of the calculations significantly. Whether the audit firms looking at microinsurers understand IFRS17 or the required disclosures is an important quite separate topic, but one which must be resolved independent of the prudential reporting basis itself.

So here’s a wild idea. Why not drop FSM2 altogether and align the prudential balance sheet with the IFRS one?