Recovery and resolution planning requirements are a fundamental component of effective resolution regimes for financial institutions, including insurers.

In 2022, the FSB announced it would discontinue identifying global systemically important insurers (G-SIIs) and would, among other things, provide guidance regarding approaches to determine the scope of application to insurers of the FSB Key Attributes of Effective Resolution Regimes for Financial Institutions.

This report offers a structured approach for authorities to assess which insurers should be subject to recovery and resolution planning (RRP) requirements, consistent with the FSB’s Key Attributes. The guidance outlines criteria authorities should use to assess whether an insurer should be subject to RRP requirements and the circumstances under which RRP requirements should always apply.

The approach helps to promote consistency in the application of the Key Attributes across jurisdictions, while leaving some flexibility to accommodate differences in market structures, legal frameworks, and supervisory practices.

The guidance may also help authorities in determining which insurers to report to the FSB’s list of insurers subject to resolution planning standards consistent with the Key Attributes. This list is published annually in the FSB Resolution Report and on the FSB’s website. 

The identification of critical functions is an important part of resolution planning, which is often conducted as a first step to help inform resolution planning decisions.

The Key Attributes of Effective Resolution Regimes for Financial Institutions set out the core elements that the FSB considers to be necessary for an effective resolution regime. Their application should allow authorities to resolve financial institutions in an orderly manner without exposing taxpayers to loss from solvency support and maintain continuity of financial institutions’ vital economic functions. The identification of these critical functions is therefore a core part of resolution planning and is often conducted as one of the first steps to build the basis for further resolution planning decisions.

This Practices Paper sets out the approaches taken by Australia, China, France and the Netherlands for the identification of critical functions of insurers. Each have developed policy for, or significantly progressed their thinking on, the identification of critical functions in their jurisdiction. The paper outlines commonalities and differences in background, scope, methodology and review process. The paper also describes the main critical functions which were identified and the main considerations which supported the identification of critical functions, providing illustrative examples for each jurisdiction.

Methodology for essential criteria to guide the assessment of the compliance of a jurisdiction’s insurance resolution framework.

This methodology paper was originally published in August 2020. The FSB subsequently published Guidance on the Scope of Insurers Subject to the Recovery and Resolution Planning Requirements in the FSB Key Attributes. That guidance revises the definition of a critical function, details of which are included in an explanatory note.

This methodology sets out essential criteria to guide the assessment of the compliance of a jurisdiction’s insurance resolution framework with the FSB’s Key Attributes of Effective Resolution Regimes for Financial Institutions (Key Attributes). It was developed in collaboration with experts from FSB jurisdictions, relevant standard-setting bodies, the International Monetary Fund and the World Bank. It is designed to promote consistent assessments across jurisdictions and to provide guidance to jurisdictions when adopting or amending their resolution regimes to implement the Key Attributes.

The Key Attributes constitute an ‘umbrella’ standard for resolution regimes for all types of financial institutions. Implementation of the Key Attributes allows authorities to resolve financial institutions in an orderly manner without taxpayer exposure to loss from solvency support, while maintaining continuity of their vital economic functions. However, not all attributes are equally relevant for all sectors. The Key Attributes Assessment Methodology provides an insurance sector-specific interpretation of individual KAs. It stresses that a jurisdiction’s insurance resolution regime should be proportionate to the size, structure and complexity of the jurisdiction’s insurance system.

In December 2022, the FSB announced that it would discontinue the annual identification of global systemically important insurers, and would instead utilise assessments available through the IAIS Holistic Framework to inform its considerations of systemic risk in the insurance sector. The FSB reaffirmed this decision in November 2025, and in April 2026, published Guidance on the Scope of Insurers Subject to the Recovery and Resolution Planning Requirements in the FSB Key Attributes, which updates the definition of a “critical function”.

A resolution strategy should make it feasible to resolve an insurer while protecting vital economic functions, without severe systemic disruption or exposing taxpayers to loss, through mechanisms that make it possible for shareholders and unsecured creditors to absorb losses

This guidance should assist authorities in meeting the resolution planning requirement under the Key Attributes of Effective Resolution Regimes for Financial Institutions (Key Attributes) and support Crisis Management Groups of global systemically important insurers in their resolution planning work. It sets out considerations for determining a preferred resolution strategy based on a strategic analysis of insurers’ business models, the criticality of insurers’ functions and policy holder protection arrangements. It also identifies a range of elements that need to be in place so that a resolution strategy can be credibly and feasibly be implemented, including effective cross-border cooperation, information systems and resources to absorb loss.