Book written in French.
& FINANCE
Your 2027–2028 Transformation
Agenda
AMLR · DORA · CSRD
In 2023, an insurance CFO could sum up the year in one sentence: “we are moving to IFRS 17”. The constraint was heavy, but it was clear. It had an owner, a budget, a steering committee and a date.
The 2027 and 2028 financial years will not be summed up so easily. No single standard will dominate the period the way IFRS 17 and IFRS 9 dominated the previous one. The difficulty lies elsewhere: some fifteen transformations of different origins arrive at the same time, call on the same teams, consume the same data and run on the same systems — some of which, widely used by insurers, will stop being maintained during the period.
On 1 January 2027, IFRS 18 takes effect. On 30 January 2027, the revised Solvency II framework and IRRD apply, the day after their transposition deadline expires.
By 19 March 2027, France must have transposed the Omnibus directive. On 10 July 2027, the European anti-money-laundering regulation becomes directly applicable.
On 2 August 2027, the AI Act reaches its full scheduled application.
On 1 September 2027, French SMEs must issue their invoices electronically.
On 11 December 2027, the Cyber Resilience Act produces its main obligations.
Unsurprisingly, none of these dates was set with any of the others in mind.
To top it all, on 31 December 2027 SAP ends standard maintenance for Business Suite 7. Before that, on 12 January 2027, Windows Server 2016 leaves Microsoft support.
An insurance company, whatever its legal form, is governed first by the same texts as any French company: it pays the CVAE, keeps its accounting records, issues electronic invoices, publishes a gender-equality index and suffers its vendors' end-of-support dates exactly like a manufacturer. Ordinary law does not stop at the door of the regulated sector, and experience shows that insurers absorbed by their own prudential corpus not infrequently discover cross-sector texts late.
In addition, regulatory change produces a specific effect on an insurer. That effect travels through two channels which must be kept distinct:
the insurer as carrier of other people's risks — the channel most often neglected.
That second channel is why every new standard or obligation deserves an exhaustive review.
When the product liability directive brings software within the notion of a defective product, it does not address insurers: it addresses manufacturers. But it changes the exposure of the liability policies those insurers have written.
When pay transparency reverses the burden of proof in discrimination cases, it addresses employers — and it feeds directors' liability and legal protection covers.
When NIS2 imposes security obligations on fifteen thousand French entities, it excludes insurers, who are covered by DORA — but it transforms the profile of their cyber policyholders and of their own suppliers.
Guiding principle no. 1 - A reform that does not target insurance can be, for an insurer, an underwriting matter before it is a compliance matter.
This book does not set out to catalogue every change in a technical and legal environment of legendary complexity.
It focuses on the changes likely to require a management decision from an insurer's executive committee: a programme, a budget, a strategic choice, an IT development, or a material change in the risk profile.
It does not replace advice from a law firm, an audit firm or an accounting firm.
Finally, it systematically separates what has been adopted from what has not. As of 16 July 2026, when we closed the drafting of this guide, the French act transposing NIS2 has not been passed; the pay-transparency bill is before the Conseil d'État; several implementing decrees of the simplification act are missing.
The list of these uncertainties is consolidated in an appendix, so you can track them throughout 2027.
[TO BE CONFIRMED]: a point depending on a forthcoming text, a transposition or a legal analysis. Appendix H gathers and ranks the seven points of this kind;
[INTERNAL POLICY]: a choice belonging to the undertaking's own governance.
Each change is examined against ten possible impacts:
This reading grid makes heterogeneous events — a prudential directive and a vendor end-of-support — comparable on a single plane: that of their effects.
Position as at 16 July 2026.
Click or drag a page corner to turn the pages — or use the arrows.
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