OSFI Axes Peer Review Table From 2026 P&C Actuary Filings
One filing table just vanished - and 2027 brings an even bigger cut
OSFI Axes Peer Review Table From 2026 P&C Actuary Filings
LEGAL INSIGHTS
By Gladys Jalipa
23 Sep 2026

OSFI just made actuarial filings a little lighter for P&C insurers, an early sign of a bigger cut still coming.

The Office of the Superintendent of Financial Institutions has finalized the 2026 templates that federally regulated life, P&C, and mortgage insurers use to file their Appointed Actuary's Report Supplementary Tables, per instructions updated September 22. The P&C version now runs one table shorter: Table 14, which used to make insurers log peer-review details row by row, is gone.

That trim tracks with a much bigger shift already in motion at OSFI, though the notice announcing the 2026 templates doesn't say outright why Table 14 disappeared. Separately, under a revised Guideline E-15, OSFI is scrapping the long-standing rule that an appointed actuary's work be checked by an outside peer reviewer, effective January 1, 2027. The guideline covers more than 200 federally regulated life insurers, fraternal benefit societies, and P&C insurers, and OSFI says peer review has done what it set out to do: the practice helped standardize actuarial work around liability valuation and financial condition testing since it began in 2003, but the regulator now figures the cost to industry outweighs the payoff. The Superintendent keeps the power to call for a peer review whenever needed.

The rest of the P&C filing hasn't budged. Insurers still submit the workbook as a structured return through OSFI's Regulatory Reporting System, and the clock still starts the same place - 60 days after the insurer's fiscal year ends. The numbers need to reflect the fiscal year-end on a consolidated basis, in thousands of Canadian dollars, calculated for insurance contract liabilities under IFRS 17.

The workbook itself is still tightly locked down. Insurers can't add or delete columns, rename or delete tabs, or reformat cells. Data entry runs on a color code - blue for manual entry, green for drop-down picks, gray for auto-calculated fields, white for fixed text - and anything in a green cell has to come straight from the approved drop-down list. OSFI built it this way so the data feeds directly into its own databases, and it can send a filing back for a redo if the numbers don't check out.

Two tables still in the workbook show just how granular this gets. Table 1 wants every link between a portfolio and an actuarial line of business spelled out, one row per pairing. Table 2 covers the reference discount curve, where the total discount rate has to equal the risk-free rate plus the applicable illiquidity premium.

P&C isn't the only sector getting a lighter load. OSFI trimmed a table from the Life template and another from the Mortgage Insurer template in the same release, plus made small clarity fixes to the Life data dictionary.

The full instructions for the P&C Supplementary Tables are available at https://www.osfi-bsif.gc.ca/en/data-forms/reporting-returns/filing-financial-returns/financial-reporting-instructions/instructions-property-casualty-insurer-appointed-actuarys-report-aar-supplementary-tables-2026.

For appointed actuaries, the immediate win is small - one fewer table this filing season. The real payoff lands in 2027, when mandatory outside peer review disappears from the job altogether.

Related Stories
Free newsletter

We'll keep you up-to-date with the latest breaking news, cutting edge opinion, and expert analysis affecting both your business and the industry as whole.

Free newsletter

Our daily newsletter is FREE and keeps you up - to - date with the world of Insurance. Please complete the form below and click on subscribe for daily newsletters from IB CA.