A delay is delay by any other name
This document looks at the FSA Omnibus II update published on July 1st 2011 regarding the Solvency II implementation date
"Bifurcation, derogation" ... whatever they call it, it's still a delay. The level of frustration heightens as the Financial Services Authority (FSA) adds their interpretation to the furore around the Solvency II implementation date. On 1st July 2011, the FSA published the Omnibus update and their version of the uncertainty that surrounds the Solvency II implementation date.
Reporting on the proposals put forward by the European Council, the FSA said that Solvency II, will not be up-and-running as planned. They also said that the "bifurcation" of the Omnibus II Directive, will create a two part implementation process. One in which the supervisors are "switched on", placed in a state of readiness on 1st January 2013, with virtually nothing to do; followed by the firms being "switched on" to the Solvency II requirements on 1st January 2014.
The FSA added that Solvency II is expected to "go live", on 1st January 2013, however firms could "derogate" i.e., defer reporting their Solvency Capital Requirement (SCR) until 1st January 2014, without incurring any penalties.