The failure of a life and health insurer is rare. But effective resolution planning requires preparation long before a crisis occurs.
As insurance groups become increasingly complex and operate across borders, authorities around the world face a common challenge: how to manage severe insurer distress in a way that protects policyholders and maintains confidence in the financial system.
International guidance helps support this objective by promoting common principles for recovery and resolution planning and enabling jurisdictions to learn from one another’s experiences.
In July 2026, the International Association of Insurance Supervisors (IAIS) published updated Application Papers on recovery planning and resolution powers, preparation and plans[1]. The papers provide practical guidance to support the implementation of international recovery and resolution standards, including standards applicable to internationally active insurance groups (IAIGs). As Canada’s policyholder protection scheme (PPS) for life and health insurers, we participated in the consultation process by providing feedback informed by our resolution planning work for the Canadian life and health IAIGs.
Key Themes from the Canadian Experience
Our comments focused on practical issues that affect whether a resolution strategy can be executed during stress. While legal frameworks differ across jurisdictions, many resolution challenges are shared. Large insurers often have complex legal structures, cross-border operations, operational dependencies, and significant information needs.
We highlight several themes that are important for effective insurer resolution planning.
Policyholder Protection Schemes as Resolution Partners
PPSs are often associated with protecting eligible policyholders after an insurer fails. In some jurisdictions, they may also play a broader role in resolution readiness.
In Canada, our experience has shown that PPSs can bring valuable practical insights to resolution planning. This may include input on policyholder outcomes, funding considerations, policy transfers, operational execution, and resolvability assessments.
Recognizing this role can improve preparedness before a crisis occurs. It can also help ensure that resolution strategies remain focused on protecting policyholders.
Information Readiness Matters
Resolution decisions often need to be made quickly. Those decisions depend on timely and reliable information.
To this end, we emphasize the importance of information readiness. This includes understanding what information may be needed, where it is held, and how quickly it can be produced. Information such as legal entity-level financial information, policyholder data, reinsurance information, and operational dependency mappings can play an important role during a resolution event.
Good information does not solve every problem. But without it, even a well-designed resolution strategy may not be executed successfully.
Operational Preparedness Is Essential
Resolution planning is only useful if it can be implemented in practice. In our view, resolution planning should not be limited to written plans. It should also include testing, capability development, and regular assessment of potential execution challenges.
This practical focus is central to assessing resolvability. It helps identify barriers before a crisis occurs and supports better decision-making when time is limited.
Coordination Supports Better Outcomes
Coordination is particularly important for IAIGs, which often operate across multiple legal entities and jurisdictions. Cross-border forums such as Crisis Management Groups (CMGs) help supervisors, PPSs, and other stakeholders develop a shared understanding of potential resolution strategies and responsibilities before a crisis occurs. These arrangements can support more effective decision-making and resolution outcomes when they are needed.
International Guidance Reinforces Assuris’ Resolution Planning Approach
The revised IAIS Application Papers reinforce many of the same principles that underpin our approach to resolution planning in Canada. Through our analysis of large and complex insurers, we have examined areas such as legal entity structures, capital, asset location, business valuations, transferability, and stakeholder coordination.
The IAIS guidance also highlights additional resolvability considerations, including operational continuity and the potential transmission of risks across legal entities and jurisdictions. As our resolution program continues to evolve, these insights will help shape future analysis and further strengthen resolution readiness in Canada.
The Value of Industry Engagement
Strong resolution planning depends on industry engagement. Our contribution to the IAIS consultation was informed by the insights gained through our evolving resolution planning work and ongoing dialogue with industry stakeholders. Continued engagement with Canadian IAIGs will remain an important source of insights into resolvability challenges and practical implementation considerations.
Looking Ahead
The publication of the revised IAIS Application Papers marks another step in the evolution of global insurer recovery and resolution standards. For us, the consultation process was an opportunity to contribute Canadian perspectives to an important international discussion and exchange ideas with regulators, insurers, and policyholder protection schemes from around the world. As resolution practices continue to develop globally, these conversations will remain an important source of learning and collaboration.
