For some of us, this journey started back in 2018 when we were notified that the Consorcio de Compensacion de Seguros (CCS) was implementing a new reporting requirement. The intention was to make insurance companies provide information at a transactional level on an ongoing monthly basis. To date, this change has had one of the biggest impacts on insurers’ reporting requirements that we have seen in the insurance industry due to the significant technological updates involved and the level of details that now need to be provided. These new reporting requirements became a reality on 1 July 2019 for any insurance company writing business in Spain.
Not only has preparing for the new reporting requirement been a challenge for insurers, it has also been a testing time for us at Sovos due to the complexities involved in the preparation and submission of the new report.
The first challenge was to find a bank that could provide the correct type of direct debits in order to register an entity under the new system. Once any registration is completed, the next step is to prepare a monthly report that contains a full set of details on a policy level including additional supplementary information such as the type of movement, e.g. cancellation, mid-term adjustment.
Without a doubt, the most common difficulty for insurers has been to identify the location of each insurance contract and allocate the relevant postcode of the risk, especially those insurers acting on a Freedom of Services basis.
There’s a useful library of frequently asked questions submitted by the market available from CCS.
The CCS has also issued guidance on the system’s specifications and the required format of the report which you can find on the same page.
The next stage is to transform your data into a specific format for uploading into the CCS reporting system. Whilst we started to develop our software back in 2018, it is still evolving based on our discussions with the CCS and the insurance market.
The system is sophisticated enough to validate data provided within hours and will provide a list of informative and invalidating errors depending on the quality of the data submitted. If errors are identified, the relevant changes must be made and resubmitted as many times as needed until the file is accepted. This could be as simple as a missing space in a policy number. And, the final challenge is to make sure your completed, and accepted, report is submitted before midnight on the 20th of each month.
Despite these challenges, this journey has helped to adapt the insurance market as it starts to feel the effects of the global digitalisation of tax that governments globally are enforcing as they seek to close tax gaps, reduce fraud and demand more granular detail.