The Standard Formula

In this episode of “The Standard Formula” global prudential solvency series, host Robert Chaplin is joined by colleagues Connor Williamson and Dev Jain to examine the prudential solvency regimes of Taiwan and Vietnam. Together, they explore Taiwan's capital adequacy regime under the Taiwan Insurance Capital Standard, currency risk challenges facing life insurers, market entry requirements in both jurisdictions and policyholder protection mechanisms. They also examine Vietnam's ambitious growth agenda, as well as the country’s push to establish International Financial Centers in Ho Chi Minh City and Danang to attract foreign investment and become a regional financial hub.

Top takeaways from this episode

1. Taiwan has implemented the Taiwan Insurance Capital Standard (TWICS), which aligns with the International Association of Insurance Supervisors' ICS 2.0. Insurers must maintain a ratio of total adjusted net capital to risk-based capital of at least 100%, with a tiered regulatory intervention ladder applied to firms falling below that threshold.
2. Approximately 70% of Taiwanese life insurers' invested assets are held in foreign currency, predominantly U.S. dollar-denominated bonds, creating a significant mismatch against their New Taiwan dollar liabilities. In response to sharp Taiwan dollar appreciation in 2025, the country’s insurance regulator introduced new rules allowing insurers to use additional reserves to offset foreign exchange losses, with 10 insurers adopting the new reserve rules.
3. Vietnam welcomes foreign investment with no statutory caps on foreign ownership, and a commercial presence can be established through joint ventures, wholly foreign-owned enterprises, acquisitions or foreign branches — though branches cannot carry out life insurance business. Vietnam's 2025 amendments set out a roadmap for a risk-based capital regime, which will become mandatory starting in 2031.
4. Insurers, reinsurers and foreign branches operating in Vietnam must contribute annually to a compulsory reserve fund at 5% of after-tax profits, capped at 10% of charter capital, providing a safety net for policyholders in the event of insolvency.
5. Vietnam’s government has established two international financial centers in Ho Chi Minh City and Danang that are designed to attract foreign capital, foster innovation and offer fast-track licensing and sandbox approvals.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

Name: Connor Williamson

What he does: Connor has a wide-ranging financial institutions and regulatory practice, with extensive experience advising insurers, asset and wealth managers, banks, payment institutions, credit rating agencies, non-bank lenders and financial sponsors on transactional and stand-alone advisory matters.

Organization: Skadden

Words of Wisdom: “Policyholder protection is another cornerstone of Taiwan's regime. In particular, the Stabilization Fund, a private organization sponsored by insurers, is designed to safeguard policyholders’ interest. It can provide loans to troubled insurers, advance claims payments if an insurer's unable to pay, and can make other payments as approved by the FSC. All insurers are required to contribute to the fund.”

Connect: LinkedIn

Name: Dev Jain

What he does: Dev Jain advises on a wide range of domestic and cross-border mergers and acquisitions, disposals, investments, carve-outs, consortium deals, group restructurings, governance issues and regulatory matters.

Organization: Skadden

Words of Wisdom: “Taiwanese life insurers face substantial currency mismatches as a majority of their New Taiwan dollar liabilities are backed by U.S. dollar assets. Approximately, 70% of their invested assets are in foreign currency predominantly U.S. dollar-denominated bonds. This imbalance in the denomination of invested assets therefore render Taiwanese insurers highly vulnerable to future appreciation of the New Taiwan dollar.”

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The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

In the latest episode of Skadden's global series on prudential solvency, host Robert Chaplin is joined by Skadden colleagues Stan Amoah and James Pickstock to examine the regulatory frameworks governing two of Asia Pacific's most prominent insurance markets, Hong Kong and Singapore. The discussion covers Hong Kong's transition to a three-pillar risk-based capital regime under the Insurance (Amendment) Ordinance 2023, the Greater Bay Area initiative, Hong Kong's ILS hub, Singapore's evolving RBC2 framework, the matching adjustment and market entry routes for foreign insurers, among other in-depth analysis.

🗝️ Key Points 🗝️

Top takeaways from this episode

1. Hong Kong's Three-Pillar Risk-Based Capital Framework: Hong Kong implemented a comprehensive transition from a rules-based solvency regime to a three-pillar risk-based capital framework under the Insurance (Amendment) Ordinance 2023, as of July 2024. The framework mirrors Solvency II.
2. Capital Requirements and the PCA/MCA Structure: Under Pillar 1, the Prescribed Capital Amount, or PCA, is calibrated to a 99.5% confidence level over a one-year period — roughly equivalent to a one-in-200-year stress event — while the Minimum Capital Amount, or MCA, is set at 50% of the PCA. Capital is tiered into unlimited Tier 1, limited Tier 1 (capped at 10% of the PCA) and Tier 2 (capped at 50% of the PCA), reflecting different levels of loss-absorbing capacity.
3. The Greater Bay Area Initiative and ILS Hub: Hong Kong's Insurance Authority has taken steps to facilitate cross-boundary business under the Guangdong-Hong Kong-Macao Greater Bay Area Initiative, including implementing after-sales service centers in GBA cities. Separately, Hong Kong has established a legal framework for insurance-linked securities, introduced in 2021, with government grant schemes to subsidize ILS issuance costs and position Hong Kong as a leading ILS domicile for the Asia Pacific region.
4. Singapore's RBC2 Framework: Singapore's insurance sector is regulated by the Monetary Authority of Singapore under the Risk Based Capital 2 framework, first introduced in 2004. Insurers must calculate a Capital Adequacy Ratio against a Prescribed Capital Requirement calibrated at 99.5% value at risk over one year — the same methodology as the SCR under Solvency II — and a Minimum Capital Requirement set at 90% VaR and pegged at 50% of the PCR. The framework also allows eligible insurers to apply a matching adjustment when valuing long-term insurance liabilities.

💡 Meet Your Host 💡

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

💡 Featured Guest 💡

Name: Stan Amoah

What he does: Stan advises insurers, financial sponsors, asset managers and other financial institutions on a wide range of corporate matters, including U.K., cross-border and global mergers and acquisitions, disposals, joint ventures, carve-outs, investments and group restructurings.

Organization: Skadden

Words of wisdom: “Singapore's insurance market is on a strong growth trajectory, projected to expand at an annual rate of 6.3% between 2026 and 2030, with gross written premiums expected to reach about 6.5 billion U.S. dollars by 2030. The market is dominated by personal accident and health, motor, property and liability insurance. These lines make up over 80% of total gross written premiums.”

Connect: LinkedIn

Name: James Pickstock

What he does: James advises on a wide range of corporate and regulatory matters, including U.K., cross-border and global mergers and acquisitions, group restructurings, reinsurance transactions and Part VII transfers, as well as governance and conduct issues.

Organization: Skadden

Words of wisdom: "The IA has a graduated ladder of supervisory intervention tools. At the outset, an insurer must notify the IA immediately if any of its directors or key control personnel reach a view that the insurer is at risk of contravening its capital requirements. Failure to do so is an offense."

Connect: LinkedIn

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The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

Malaysia's insurance market is one of Southeast Asia's most developed, with total gross written premiums for general insurance totaling 23.1 billion Malaysian ringgit — approximately $5.8 billion — in 2024, representing year-on-year growth of 6.9%. In this episode of Skadden's global series on prudential solvency requirements, host Robert Chaplin and colleague Caroline Jaffer examine the country’s distinctive dual financial system, which covers onshore and offshore insurance, as well as Malaysia’s landmark risk-based capital framework that is scheduled to be implemented in January 2027, the Sharia governance framework governing Takaful operators, the new Digital Insurers and Takaful Operators framework and the offshore regime on the island of Labuan.

Top takeaways from this episode

• Dual Regulatory Framework: Malaysia operates a unique dual system in which conventional insurance regulation runs alongside a comprehensive Islamic insurance framework known as Takaful. Each is governed by separate primary legislation: the Financial Services Act 2013 and the Islamic Financial Services Act 2013. Onshore insurance is supervised by Bank Negara Malaysia (BNM), the country’s central bank, while offshore business conducted on the island of Labuan falls under the Labuan Financial Services Authority.
• RBC2, a Landmark Reform: BNM issued an exposure draft in June 2024 proposing significant changes to its risk-based capital framework (RBC2), with implementation targeted for 1 January 2027. The reform draws on concepts from the Insurance Capital Standard (ICS) issued by the International Association of Insurance Supervisors while preserving features of Malaysia's existing framework.
• Takaful and Sharia Governance: Every licensed Takaful operator must maintain an internal Sharia committee, with BNM's prior written approval required for all appointments. Crucially, noncompliance with Sharia is a statutory criminal offense under the IFSA — a feature with no real parallel in conventional insurance regulation globally.
• The DITO Framework: With approximately 90% of the Malaysian population underinsured, the BNM's Digital Insurers and Takaful Operators (DITOs) framework aims to close that protection gap.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

Name: Caroline Jaffer

What she does: Caroline has extensive experience working on insurance matters and liaising with regulators in both the U.K. and internationally,

Organization: Skadden

Words of wisdom: “The BNM, through its Sharia Advisory Council established under the Central Bank of Malaysia Act 2009, holds wide powers to assess, intervene, direct and penalize for breaches. This statute of enforcement architecture has no real parallel to Solvency II or indeed for the most comparable international frameworks, as it is the threshold consideration for any practitioner advisee on the Takaful market entry.”

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☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

Colombia's total gross written premium (GWP) is projected to reach $8.9 billion this year and grow to over $11.5 billion by 2028, signifying its rise as a significant and expanding insurance market. In this special additional episode of “The Standard Formula,” host Rob Chaplin is joined by colleague Caroline Jaffer explore Colombia's prudential solvency regime, building on their recent episodes focused on Central and Latin America. They examine the regulatory role of the Superintendencia Financiera de Colombia (SFC), Colombia's alignment with international standards through IAIS membership and the country's gradual shift toward a risk-based capital model. Rob and Caroline also discuss progress toward Solvency II adoption, technical reserve requirements and cross-jurisdictional reinsurance rules through the REACOEX registry.

Top takeaways from this episode

1. Colombia's Insurance Regulatory Framework: Colombia's insurance sector is regulated by the SFC, which holds wide-ranging powers for licensing, supervision, consumer protection and regulatory enforcement. The Ministry of Finance also retains policymaking authority over the broader insurance sector.
2. Shift Toward Risk-Based Capital: Since 2010, Colombia has been gradually shifting towards a risk-based solvency framework. Insurers now calculate required capital based on asset risks, underwriting risk and other exposures, with the minimum capital required to be comprised of paid-in capital, reserves and retained earnings.
3. Progress Toward Solvency II Adoption: Colombia is working toward a more extensive adoption of Solvency II, encompassing not only quantitative capital requirements but also governance, risk management, reporting and transparency. One challenge has been the availability of data, leading the Colombian government to foster capacity-building within the insurance sector to ensure an ordered transition.
4. Cross-Jurisdictional Reinsurance and the REACOEX: Domestic insurers may cede risk to foreign reinsurers, provided those reinsurers are registered in the REACOEX — the SFC's public registry for foreign insurers and reinsurance intermediaries.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

Name: Caroline Jaffer

What she does: Caroline has extensive experience working on insurance matters and liaising with regulators in both the U.K. and internationally, having practised in both the U.K. and the Middle East.

Organization: Skadden

Words of wisdom: "Colombia has increasingly aligned its supervisory and prudential systems to international standards in recent years. The SFC became a member of the International Association of Insurance Supervisors, or IAS, Multilateral Memorandum of Understanding in 2022. Accordingly, Colombian regulation follows all their guidelines specifically regarding prudential supervision, market conduct, corporate governance and risk management."

Connect: LinkedIn

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

Australia and New Zealand sit at opposite ends of the international solvency spectrum — as Australia is among the largest in the Asia Pacific region, while New Zealand is smaller in scale and undergoing significant evolution to align with international best practices. During this penultimate episode of “The Standard Formula” series on global prudential solvency requirements, host Rob Chaplin and associate Connor Williamson examine the two countries’ markets and regulatory regimes, regulatory structures, capital standards, governance and reporting requirements, and reinsurance frameworks, among other topics.

💡 Meet Your Host 💡

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

💡 Featured Guest 💡

Name: Connor Williamson

What he does: Connor has a wide-ranging financial institutions and regulatory practice, with extensive experience advising insurers, asset and wealth managers, banks, payment institutions, credit rating agencies, non-bank lenders and financial sponsors on transactional and stand-alone advisory matters.

Organization: Skadden

Words of wisdom: “The first point to understand is that New Zealand has its own regulatory regime, and that's actually more different from Australia than you might expect.”

Connect: LinkedIn

Connect with Skadden

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

South Korea's insurance industry is estimated to be the seventh-largest globally, with high market concentration: three life insurers hold approximately 50% of the life insurance market while the top four non-life insurers control about 70% of the non-life market. In this episode of Skadden's yearlong podcast series on global insurance regulatory regimes, host Rob Chaplin and colleague Chiara Iorizzo explore South Korea's robust, multi-layered regulatory framework. Tune in for their detailed analysis of the country’s regulatory and prudential regimes and observations about how the country aligns with global insurance standards.

Name: Rob Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

Name: Chiara Iorizzo

What she does: Chiara advises on domestic and cross-border mergers and acquisitions, group restructurings, regulated financings, governance and regulatory matters for private equity sponsors, asset managers, reinsurers, brokers and other financial institutions within the insurance and financial services sector.

Organization: Skadden

Words of wisdom: “If an insurer's KICS ratio falls below the minimum, the FSC has broad powers to take prompt corrective action. This can include requiring the insurer to raise capital, dispose of assets, close sales offices, merge, or transfer business. The regime is designed to ensure that insurers remain financially sound and can meet their obligations to policyholders.”

Connect: LinkedIn

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

On the latest episode of "The Standard Formula," host Rob Chaplin is joined by associates Dev Jain and Richi Kidiata for a comprehensive tour of Africa’s rapidly evolving insurance landscape. The team delves into the regulatory frameworks of South Africa, Morocco, Egypt, Nigeria and Kenya — markets at the forefront of aligning with international best practices and standards such as Solvency II — and breaks down each jurisdiction’s approach to capital and liquidity requirements, risk management and governance, while highlighting recent reforms, local challenges and the growing integration of African insurers into the global financial system.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II.

Connect: LinkedIn

Name: Richi Kidiata

Organization: Skadden

Name: Dev Jain

Organization: Skadden

Connect: LinkedIn

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

While Latin America accounts for just 3% of the global insurance market, the region's total written premiums grew at an impressive 11% annually between 2019 and 2024, with projections indicating this growth will continue. In this installment of Skadden's yearlong podcast series on global prudential solvency requirements, host Robert Chaplin and colleagues Caroline Jaffer and James Pickstock do a deep dive into the insurance regimes in Mexico, Brazil, Chile and Argentina. Tune in as they break down each jurisdiction's regulatory authority, unique prudential requirements and gradual shift toward European or Bermudian-style risk-based systems.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II. 

Connect: LinkedIn  

Name: Caroline Jaffer

What she does: Caroline has extensive experience working on insurance matters and liaising with regulators in both the U.K. and internationally, having practised in both the U.K. and the Middle East.

Organization: Skadden

Words of wisdom: “On investments, Brazil has strict and detailed rules on what type of assets may be invested by insurers and local reinsurers, with such rules being set by Brazilian finance authorities and reviewed periodically. These same rules impose certain investment limits per class of asset and issuer.”

Connect: LinkedIn 

Name: James Pickstock

What he does: James advises on a wide range of corporate and regulatory matters, including U.K., cross-border and global mergers and acquisitions, group restructurings, reinsurance transactions and Part VII transfers, as well as governance and conduct issues.

Organization: Skadden

Words of wisdom: “The Chilean insurance market is reasonably open to international reinsurers and foreign investment, with some standard regulatory overlay. For example, foreign reinsurers can operate directly in Chile provided they meet certain conditions — being that they have a risk rating of at least BBB or equivalent, and that they have an appointed representative on the ground.”

Connect:  LinkedIn

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

Canada has one of the world's most sophisticated and internationally integrated insurance markets, marked by robust capital requirements and an increasing orientation towards ESG- and climate-related considerations. Continuing Skadden’s global tour of prudential solvency regimes, host Rob Chaplin and colleague Chiara Iorizzo examine Canada’s insurance regulation structure, valuation approach, capital quality standards and modernization efforts.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II. 

Connect: LinkedIn  

Name: Chiara Iorizzo

What she does: Chiara advises on domestic and cross-border mergers and acquisitions, group restructurings, regulated financings, governance and regulatory matters for private equity sponsors, asset managers, reinsurers, brokers and other financial institutions within the insurance and financial services sector.

Organization: Skadden

Words of wisdom: “The adoption of IFRS 17 is particularly significant given the market concentration of large diversified insurers and (Canada’s) robust regulatory environment, which emphasizes prudential oversight and consumer protection. The standard’s implementation is expected to drive greater alignment between Canadian insurers and their global peers.”

Connect: LinkedIn

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

In this episode of The Standard Formula, host Robert Chaplin and Skadden colleague Theo Charalambous provide a high-level refresher on Solvency II, Solvency UK and relevant recent developments as part of Skadden’s year-long podcast series on global prudential solvency requirements. The hosts detail both regimes and relevant topics, including the Matching Adjustment Accelerator (MAIA), enhanced liquidity reporting requirements, and new exit planning obligations for Solvency UK that represent a shift away from Solvency II toward a U.K.-focused approach.

Name: Robert Chaplin

Title: Partner, Insurance at Skadden

Specialty: Rob primarily focuses on transactional and advisory work in the insurance sector. He advises on mergers and acquisitions, disposals, joint ventures and strategic reinsurances. He also counsels on regulatory issues, with an emphasis on Solvency II. 

Connect: LinkedIn  

Name: Theo Charalambous

What he does: Theo counsels insurers, brokers and private equity sponsors on mergers and acquisitions, disposals, investments, reorganizations, alternative transaction structures and multijurisdictional regulatory matters.

Organization: Skadden

Words of wisdom: “In the U.K., the PRA requires that insurers’ investment strategies should be aligned with its investment objectives and asset allocation, the board's risk appetite, risk tolerance limits, investment risk-return objectives, as well as alignment of the investment strategy with its business model.”

Connect: LinkedIn

☑️ Follow us on X and LinkedIn.

☑️ Subscribe to The Standard Formula on Apple Podcasts, Spotify, or your favorite podcast app.

The Standard Formula is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.