Good morning, everybody. And welcome to NN Group's investor update. Let me start by saying that I'm very glad that you managed through the weather today. Very good, to see you all here. many of you know me already. I'm, Ruben van der Hulst, head of investor relations, and I will be your moderator for today. It has been a while, actually, five years ago, since we last hosted our, in-person Capital Markets Day event, back then that was in Rotterdam, in the Van Nelle factory. And of course our CMD, in 2020 was a fully virtual event as that was in the midst of the COVID-19 pandemic.
Investor engagements is extremely important for us and we have had many interesting conversations over the past year. On the variety of topics ranging from the macro environments to free cash to cash flow to OCG outlooks to capital returns. And we appreciate all the feedback and the good conversations we had in the last year. Our key objective of today is to give you an update on NN Group, and to do this, we have a full schedule. Seven presentations by our management including free Q&A sessions so there will be plenty of opportunity to ask all your questions. Before we get started, let me mention a couple of formalities. First, we will be recording today's session.
Second, we would appreciate if you would take a moment to review our disclaimer or forward-looking statements, which you can also find at the back of the presentation. Having said that, I would like now to hand it over to David to kick off the day with his presentation on the strategy of the NN Group. David, the floor is yours.
Yes, good morning. Did I scare you?
Good morning, everyone. Also for me, a very warm welcome. Very happy to see you guys. I saw you guys all coming in, and it does feel like a long time despite all the online meetings. What is always, of course, interesting also for us is to talk to all of you in between breaks and before and after, which is, you know, not possible in online meetings. Really looking forward to this morning to catch up and also get your perspectives and views. Indeed, as Ruben was saying, two years ago we had our CMD and we presented our strategy at that point in the middle of the global pandemic.
Understandably a lot of you had a lot of questions at that point because we came out with a target of EUR 1.5 billion OCG, and our 2020 was below EUR 1 billion. We still had quite a step to go and there was, of course, an unprecedented virus going around the world. I remember thinking, well, this is not an easy time to set targets in the middle of a COVID-19 pandemic and certainly at the beginning of the pandemic. Now since then we have seen that with a very strong balance sheet and a very resilient business model we've proven that NN Group can weather such volatile conditions very well while we continue to deliver on growth and attractive capital returns. We've clearly overachieved our targets in these challenging times.
Now today's environment is obviously no less challenging, and we have obviously the war ongoing in the Ukraine. I think most of you know we have four countries where we operate that are bordering to the Ukraine. Of course, you know, there's an enormous amount of things happening there, and I must say I'm very proud of all the NN Group colleagues also because the amount of refugees that come out of the Ukraine that come into the Polish markets, Slovakia, and the other markets, you know, I'm very proud actually on how people are trying to help out in such a horrible war.
Now obviously energy crisis, driving up inflation, that is clearly now starting to impact the purchasing power of households and we've seen, of course, an increase of rates and very volatile financial markets. Today, you know, with the world probably at the brink of a recession, it's also not much easier to set long-term targets. At the same time, it is really not only doom and gloom when we look at what's happening with customers in our markets. Given the experience of the pandemic but also everything we see happening around climate change that customers are starting to feel, we see that customers now more than ever are actively looking to protect themselves but also actively look to protect what they care about, what is around them. That is a real opportunity for us as a company.
Based on our strong balance sheet and our resilient business model and further building on the strategy that we have set, we are announcing today our new financial targets and obviously also our new strategic targets around customer, people, and society. The aim for today is to explain how we will deliver on these targets, but to be honest, more importantly, by the end of the morning, I hope you will not only share our conviction that we will deliver on these targets that we have set, but that you will also share our enthusiasm for NN Group as a company. That brings me to today's key takeaways. We've been successful in delivering on our strategy launched in 2020 and have therefore overachieved on our targets for 2023. Also, our strategic KPIs show real improvement.
At the same time, we've laid a foundation for long-term sustainable growth by investing in our businesses and by strengthening our portfolio through acquisitions and divestments. This has led not only to a stronger set of businesses but also to a better-diversified company. Now, following all these actions and despite the challenging environment, we are well-positioned to increase our OCG target to EUR 1.8 billion from our target of EUR 1.5 billion in 2023 and to continue to achieve a mid-single-digit OCG growth in the long-term, also from the higher base of OCG at 2021. Despite having brought forward some of the OCG growth in the past two years and by achieving a mid-single-digit growth of free cash flow, we also updated our strategic targets with new goals for 2025 with continued focus on customer, employees, climate action, and society.
Finally, we will continue to be very disciplined in returning capital to you, our shareholders. Let's get started. This is our NN Group's strategy. In the middle of the slide you can read our ambition that we set in 2020. Our ambition was that in five to 10 years we want to be an industry leader known for customer engagement, talented people, and contribution to society. I would argue that these three elements are even more relevant today than they were in 2020 when we launched our strategy. Attracting and retaining talent to drive transformation in our business forward is even more urgent today given the war on talent. Almost all markets where we operate in today have full employment and many business leaders now cite this as their biggest challenge. I'm glad that we already started with this in 2020.
Playing an active role in society, in particular meeting our net-zero ambition, has again increased also in importance in the last few years. Finally, customers will always remain central to our business. The next slide shows the progress that we have made, measured against our strategic targets for customer, employees, and society. We have seen underlying improvements in customer engagement. Strong improvement in our broker satisfaction scores, but we are not yet beating the competition in all of our markets. In the middle, you can see the good results on our targets for employee engagement and diversity. As I was saying, we operate in markets with full employment, and therefore it's crucial that we are an attractive employer for talent from all backgrounds and that we keep our colleagues highly engaged.
On the right-hand side you can see that we have taken big steps in integrating ESG in our scope three investments and working towards a net-zero investment portfolio. It's still early days in terms of sustainable customer propositions but our first offerings are doing well. Now of course most companies claim strong performance in these areas so external recognition matters and is a result also from investments, from our side for many years now. On this slide you can see some of the examples of the awards we have been receiving such as a very recent award for a human capital planner which supports our SME customers based on data analytics. Top right you see the recognition as an employer, top employer for the fourth time in a row as well as being an employer that supports diversity by being included in the Bloomberg Gender-Equality Index.
NN Group has been included in the Dow Jones Sustainability Index and the FTSE4Good Index since 2016. Most recently we were ranked number eight out of the 400 largest financials in the world by the World Benchmarking Alliance, which is something that we're also very proud of. Now our focus on our strategic commitments, underlying investments in our business have allowed us to lay the foundation for further growth, which you can see on the next slide. These slides give you more insight in the progress we have made and it's based on the three pillars of our strategy. Firstly, a strong balance sheet with Group Solvency Ratio at 205% at the end of September while returning EUR 3.7 billion to shareholders since 2020.
Secondly, strong cash flow generation in the Netherlands supported by an additional EUR 200 million of OCG from the shift to higher yielding assets, which was achieved one year ahead of plan. Growth in defined contribution assets to EUR 27 billion with a continued net inflow. A structurally improved Non-life combined ratio with an expense ratio below 10%. Netherlands Life steadily remits each year as seen in the chart while Non-life and Banking also continue to remit. The third pillar is profitable growth in Europe and Japan and this is driven by outgrowing the market in life protection in Europe with NN Group growing around 10% while the market grows at around 5%. We maintain a leading position in the SME Life insurance space in Japan despite headwinds from tax and regulatory changes and we are leveraging on our strong multi-distribution platform both in Europe and Japan.
Now we have combined these investments in our business with decisive portfolio actions. Two years ago, we said that when it comes to acquisitions we would apply strict financial and strategic criteria. This slide shows that we did exactly that. For example, with the strengthening of our number three position in Poland and creating the number one player in Greece, we expect to make a double-digit return on this deal. We also committed two years ago to continue to evaluate whether we are the right owner of portfolios and business units, which we did, as you can see in the lower table on this side, such as exiting Bulgaria, selling a closed book in Belgium, and of course a strategic partnership with Goldman Sachs Asset Management due to a lack of growth perspective of the asset management business stand-alone.
The result of all these actions is that we have a robust and well-positioned set of businesses providing diversification, as you can see on slide eight. On the left-hand side you can see diversification of cash generation versus long-term growth and we expect the growth part to become larger over time also due to the significant VNB generated by our growth businesses, which you can see in the middle of the chart. On the right-hand side you can see the diversification in sources of income, which is increasingly coming from fee and technical margin and also that trend we expect to continue. Moving on to slide nine, we show you how these actions in the past two years are reflected in our performance.
In terms of our financial targets that we set in 2020, you can see that we are ahead of plan for the 2023 plan not only for Group but also for the underlying segments. All individual business units have shown strong operational performance and have either already delivered or are on track to deliver. An overall strong business performance is also translating into solid financial results. Now, of course, the next question is whether the strategy that helped us navigate through the COVID-19 pandemic is also the right strategy in the current volatile economic climate. Yes, it is. We are relatively insensitive to interest rates thanks to our strategy of closely matching assets and liability cash flows, an approach that has worked well for many years and it means that we're economically well hedged.
As you know, it does give some volatility on our Solvency II balance sheet, but these stock and flow items are manageable. As you will see in Bernhard's presentation, increasing rates marginally support our ratio. Higher rates also mean we can reinvest at higher yields and higher rates are positive for sales. Overall, therefore, higher rates are generally supportive for our business. As you know, inflation has significantly increased, impacting the purchasing power of our customers. With regard to our own financial exposure, we have largely hedged our inflation risk and the impact of inflation on our expenses is manageable. On the DC Pension side, the DC Pension business is less sensitive to inflation risk. For the closed books, we will continue to be vigilant on running the expenses down in line with the run-off of the book.
For the P&C business, the expected claim inflation can be largely offset by premium increases, and we have already taken action. In the disability business, we continue to update wage inflation assumptions. In Europe, too, premiums can be adjusted for inflation. However, we do expect some pressure on sales in the short term due to lower disposable incomes. Over time, the structural demand for protection products should mean a return to sales growth. In summary, increasing rates support our business, and current inflation levels are manageable. Now, going forward, there's, of course, a lot more happening in the world. This slide shows our strategy aligns well with long-term market trends. One of the consequences of COVID-19 is that it has an increased awareness for the need of protection, especially in markets where healthcare is less developed.
We have built strong market positions in protection in the markets we operate. The shift to risk from individual households continues, with governments and employers not willing to take on the risk anymore. We offer life protection products and strong lifecycle products in DC Pensions to fill this gap. We believe that in order to remain relevant in the lives of customers, we need to continue to enhance customer engagement and offer them solutions that go beyond the financial services and meet their changing demands. An example of this is our Carefree Retirement platform. Clearly, investing in technology, in data, in engagement platforms remains crucial in our business. Finally, we see an increased demand for sustainable propositions, and we offer a range of products and services to meet this. In conclusion, this is the right strategy for NN Group going forward.
How does our strategy translate into concrete actions at the business unit level? Starting with the Dutch units on slide 12, we have a strong starting position. Also, after the ASR or Aegon combination, we remain number one in pensions with a 40% market share, number one in individual life, and number one in Non-life. We continue to take actions to support our ongoing cash flow generation. This comes from growth in DC, possible buyout opportunities, but also from efficiency gains such as benefiting from the increased scale after the ABN AMRO Life acquisition. We are further improving the profitability of the Non-life company, leading to a lower combined ratio guidance between 93% and 95%. We're using digital and data capabilities to further improve the efficiency at NN Bank. Now, Leon and Tjeerd will talk more about the Dutch units later today.
Now, all of these actions are reflected in new and higher OCG targets for each segment, Life, Non-life, and Banking. The international businesses are the true growth engines of the Group, reflected in an increase of targets from EUR 325 million-EUR 450 million OCG for Europe, while Japan increases from EUR 100 million-EUR 125 million OCG. We will achieve this by leveraging on our leading protection positions in the 10 markets that we operate. We have unique multi-distribution platforms providing both diversification and excellent opportunities for accelerated growth. We see a structural market demand for protection products that we offer in Europe, but also in the SME market in Japan, where we continue to be able to allocate significant amounts of capital with high double-digit IRRs.
At the same time, we invest in digital capabilities, leading to more digital customers and an increasing amount of digital leads, improving lead-to-sales conversion and agent productivity ratios. Despite the occasional headwinds in Japan from tax and regulatory changes, we expect our shift to protection products will compensate for the declining sales of financial solution products, leading to an increased target for Japan of EUR 125 million OCG. Fabian will talk more about the international units later this morning. In summary, these international units are becoming a more substantial part of the total Group OCG, as reflected in the new higher OCG targets for Europe and Japan. Let's bring the strong balance sheet, strong cash flows in the Netherlands, and the growth of the international business together.
Now, this is a core slide for us, and it's an updated version of the slide that we presented at the 2020 CMD. It confirms a very important point. Despite the fact that OCG growth has been brought forward with the original 2020 expectation and that it grew much faster than the mid-single digit rate, we can reconfirm the mid-single digit growth to 2030, starting from the higher 2021 base. This is driven by organic growth drivers. Firstly, the underlying run-off of the Life portfolio is offset by DC growth and potentially buyouts. International, these units are expected to grow faster given the underpenetration of protection and our unique distribution platform. The Non-life business can grow slightly faster than GDP growth by investing in data, underwriting, and other select pockets of growth. Overall, this remains an attractive long-term growth profile.
The long-term growth profile of OCG enables us to continue to provide strong and sustainable capital returns to you, our shareholders. This shows our strong track record when it comes to our commitment to attractive capital returns. We have achieved a dividend growth of 7% since 2019 and have continued to provide a recurring share buyback of EUR 250 million a year, plus an additional EUR 750 million buyback this year following the completion of the sale of NNIP. On the right-hand side of the slide, you can see the attractive dividend share buyback yield. Therefore, we reconfirm our capital return policy going forward, and we will remain disciplined around capital deployment. Our first priority is to invest in the organic growth of our business and to deliver on our capital return policy via dividends and share buybacks.
Excess capital will be returned to shareholders unless we can invest it in value-creating opportunities, such as inorganic growth, but always subject to our strict criteria. Later on, Annemiek will provide some more details on how we think about the deployment of excess capital. Now, obviously, you also want to know what this means for the coming years, and that this is not only a long-term promise. Therefore, in summary, this slide sets out our financial targets for 2025. Our strong market position and organic growth drivers mean we're confident to grow OCG to EUR 1.8 billion in 2025, and we will achieve a mid-single digit growth in the long term, taking into account the OCG growth brought forward. This will translate into mid-single digit growth of free cash flow.
The segment targets reflect higher expected growth for the international units, higher OCG at Netherlands Life, and an improved combined ratio for Non-life. Expense control has always been important, and even more so in the current inflationary climate. That's why we've also set targets on expenses for our Dutch units, such as an administrative expense ratio for the Non-life business below 10% and a cost-income ratio of below 55% for the bank. As I said, capital return policy is unchanged, with a progressive dividend per share and a minimum share buyback of EUR 250 million. At the same time, we have updated our strategic targets to 2025, with a focus on customer engagement, attracting talent, and working towards our net zero pledge. Because ultimately, these targets drive our long-term growth. In line with our overall ambition, we aim to significantly outperform our competitors in terms of customer engagement.
We have further increased our target for employee engagement to ensure that, also in tight labor markets, we have the capacity to drive our transformation. We have aligned our society targets with our commitment to reach net-zero investment portfolio by 2050. Therefore, we commit to reduce greenhouse gas emissions of our corporate investments, and we are doubling the investments in climate solutions. I will say more on this in the coming slides. Finally, we continue to support the communities around us with a focus on contributing to the financial, physical, and mental well-being of 1 million people. Now, climate change, obviously, is a significant global concern, as discussed also during the recent COP summit in Egypt as well. The financial sector can play an important role in the transformation to a low-carbon economy.
Therefore, we are taking action in our investment portfolio, in our underwriting, our products and services, as well as in our own business operations. We can make the biggest impact with our investment portfolio, and I will talk about that on the next slide. Products and services, sustainability is more and more top of mind for retail customers, too. We want to help them by offering specific products, like coverage against severe weather events or sustainable defined contribution lifecycle pension products. We also have a sustainable mortgage label, Woonnu, which is aimed at supporting people to make their homes more energy efficient. On the insurance side, we joined the Net-Zero Insurance Alliance, and we aim to transition our underwriting portfolio to net zero, while at the same time working with other insurance companies to develop metrics and set targets.
Our own footprint, even though it's a small part of our total environmental impact, we aim to reduce the emissions from our own operations by 70% in 2030. To our proprietary investment portfolio, as an asset owner, we can make a real difference in helping companies to decarbonize. Our goal is to transition to a proprietary investment portfolio to net zero carbon emissions by 2050, and we have set interim targets on this, reducing the carbon emission of our corporate investment portfolio by 25% in 2025 and 45% by 2030. We also aim to invest an additional EUR 6 billion in climate solutions by 2030, more than doubling our current investment to EUR 11 billion. These are investments in green bonds, renewable energy projects such as solar and wind farm, and energy-efficient real estate.
On the funding side of our business, we launched the Sustainability Bond Framework in February this year and completed our inaugural green debt issue in August. To sum up, we are committed to help to limit the impact of climate change in all areas of our business, and this is embedded in our strategy, in our targets, and in our day-to-day activities. Now, if we bring this all together, the question, of course, is what does this mean for you as a shareholder? We are reconfirming our commitment to investors. If I would sum this all up in one sentence, it means that we're committed to being a stable provider of attractive and growing capital returns in a currently volatile world. Which then brings me to the conclusion and the final slide.
Today's key takeaways are we have overdelivered on our targets up to 2023, we have laid the groundwork for future profitable growth, we have set ambitious strategic and financial targets for 2025, we can do this because NN Group has a resilient business model and a relatively low-risk profile, and we're well positioned to weather volatility and to continue to grow OCG in the long term, and we remain committed to delivering attractive returns to shareholders. Now, with that, I would like to give the floor to Annemiek, who joined us this summer, and I'm also very happy that she joined us. Very happy to have you on board, Annemiek, and over to you, and I will see you later on the Q&A.
Thank you, David. Good morning to all of you.
It's nice to meet you in person again, as it has been a while, and it's actually the first time since I became CFO of NN Group about four months ago. In the last four months, I've visited many of the businesses, and I've spoken to a lot of colleagues, and I have to say the colleagues, both within the Management Board and also outside the Management Board, have been extremely helpful in getting me up to speed quickly as a new CFO. Obviously, with the macroeconomic uncertainty and with the market volatility, it's a very interesting time to start as CFO. The key message that really stands out to me here in the first four months is really about NN Group's predictable cash flow. That allows it to continuously invest in growing the business while providing predictable and considerable capital returns to shareholders, even in uncertain times.
That also ties into the key takeaways that I would have today. Over the last couple of years, NN Group steered its business very well through volatile markets and delivered considerable capital returns. We're confident that we will continue to do so, and we have increased our OCG target of EUR 1.5 billion in 2023 to EUR 1.8 billion in 2025. All businesses contribute to this increased OCG target. Although we did bring growth forward versus what we indicated at a previous Capital Markets Day, we do confirm our mid-single-digit long-term OCG growth target. We also expect mid-single-digit growth of free cash flow, both towards 2025 and over the long term. Based on this free cash flow growth in our resilient balance sheet, we confirm our current capital return policy, consisting of a progressive dividend per share and a buyback of at least EUR 250 million.
Has done historically, if we have excess capital, we will either invest it in value-creating opportunities or we will return it to shareholders. Let's take a step back and look at the financial development since the last Capital Markets Day. Since 2019, we generated EUR 4 billion of OCG and returned 55 percentage points of solvency to shareholders and generated 55% solvency points in OCG. We returned EUR 3.7 billion or 42 percentage points of solvency to shareholders, and the OCG generated also allowed us to partially mitigate the impact of regulatory changes, of which we observed quite a few. You can see that in the bucket order. Those include the 15% UFR step-downs, the 10% impact on Group solvency by including the Bank and the solvency ratio, and a few more.
In addition to the capital returns, we also significantly invested for inorganic growth in both Non-life and Europe with the acquisitions of VIVAT Non-life, Heinenoord, and with MetLife. This was broadly offset by the sale of NNIP and therefore largely self-funded. During this period, we observed significant market volatility, yet the overall impact of it was relatively neutral with 4%, demonstrating the resilience of our balance sheet. In short, we managed risk well through volatile markets, and our resilient balance sheet, as well as strong operating capital generation, allowed us to invest for growth, absorb regulatory changes, and continuously provide an attractive return to shareholders. We will continue to do so, which is reflected by our new targets. Let's have a look at these. At the last Capital Markets Day, we guided for mid-single-digit OCG growth long-term, a guidance that we will reconfirm today.
For the medium term, as said, we've increased our OCG target of EUR 1.5 billion in 2023 to EUR 1.8 billion in 2025, and all segments contribute to this growth. For Life, we increased the OCG target of EUR 900 million to EUR 1.15 billion, reflecting both the shift to higher-yielding assets that we've done so far and the current market environment. In addition, expenses are guided to continue to decrease in line with a run-off of the portfolio, which remains a crucial element for our Life business. On Non-life, we increased OCG guidance of EUR 250 million to a target of EUR 325 million, and we've also decreased the combined ratio with one percentage point to 93%-95%, showing our confidence that we can further optimize the business, also post the current benign environment. In Europe, we continue to see strong performance despite the current macroeconomic challenges.
We've therefore increased the OCG target from EUR 365 million-EUR 450 million. For Japan, we increased the OCG target of EUR 100 million-EUR 125 million, and for the Bank, we've upgraded the OCG target from EUR 70 million-EUR 80 million. For the Bank, we also maintain our minimum ROE of 12% and a cost-to-income lower than 55%. For Group, we now expect mid-single-digit free cash flow growth in line with our long-term OCG growth. We reconfirm our progressive dividend per share and our buyback annually of at least EUR 250 million. Let me give you some more insights into these OCG targets. As you can see on the slide, the originally targeted OCG growth of EUR 1.5 billion in 2023 was actually brought forward with a 2022 level clearly ahead of plan and exceeding this. There are three key drivers for this acceleration.
We accelerated the shift to higher-yielding assets in Netherlands Life as we took advantage of dislocated markets during COVID-19. We also saw very strong business performance, mainly reflecting the Non-life transformation and the current benign claims environment in the Netherlands, as well as profitable growth in Insurance Europe, which is all reflected in the business improvement bucket. We saw market impacts clearly visible in 2022. Whilst we do not expect this acceleration of OCG to continue with the same trend, we do expect to be able to continue to grow OCG mid-single-digit from the reported 2021 levels onwards. For illustrative purposes, we've also updated the chart that we show on the previous Capital Markets Day, which indicates the expected longer-term OCG evolution.
As you can see on the slide, we continue to expect mid-single digit OCG growth over time, but from a higher starting base, the EUR 1.6 billion in 2021 versus the EUR 1.3 billion that we had in 2019, and this is really driven by underlying business growth. The basis is formed by a large and stable contribution of Netherlands Life. We've seen an uplift due to markets in 2022 so far, and over the next years, the impact from the run-off of the portfolio is broadly offset by a lower UFR drag, growth in DC, and to a lesser extent, buyout opportunities. As Bernhard will explain later, we expect limited upside from further optimization of the investment portfolio. Insurance International remains a key driver for OCG growth.
In Europe, continued profitable new business sales in growing markets will continue to increase OCG, while in Japan, we focus on long-term modest growth by a shift to protection. For Non-life, further improvement of the combined ratio and growing fee business contribute to a long-term gradual increase of OCG. The bank will first have to recoup the OCG decrease experience in 2022, driven by lower income and a higher RWA, but the expected net interest margin expansion and moderate portfolio growth is expected to lead to modest growth from 2021 levels over time. We expect the increased contribution from the segments to more than compensate some increased holding expenses, which largely relate to higher debt servicing costs due to interest rate rises. Now, let's move from a long-term growth perspective to the key drivers of our OCG target in 2025.
The updated target of EUR 1.8 billion reflects over EUR 300 million growth versus a 2021 figure of EUR 1.6 if you would adjust that for the sale of NNIP. It reflects overall moderate growth from current levels as the market-related uplift has already largely materialized in 2022, which is reflected in the second bucket on the slide. This is mainly why we expect the Life contribution to be relatively stable from current levels. It increased materially since 2021, mainly driven by higher interest rates, so a lower UFR drag, and an increased investment portfolio and an increased investment return, which was also based on the shift to higher-yielding assets. Going forward, we expect limited further upside here, as I indicated before. For Europe, we do expect strong OCG growth to continue, also towards 2025, as new business feeds into OCG and the contribution from MetLife, Poland, and Greece expands.
This is reflected in the second bucket and also the reason why we increased the third bucket and also the reason why we increased the target of Poland of international from EUR 365 million-EUR 450 million. Now, although we do expect both Non-life and the Bank to further improve their underlying business performance, you don't see any clear contribution of them to the EUR 1.8 billion growth target in 2025. Non-life reported very strong full year 2021 results, benefiting from a very benign claims environment and strong market sentiment in both P&C and D&A. Over time, we would expect some normalization here of claims and also of debt market environment, but we do expect to compensate that by further improvement and by further underwriting improvements and also by the growth in the fee business.
Bank enjoyed a very strong 2021 as well, which was largely driven by high prepayment penalties and high fee income based on strong investor demand for mortgages. This obviously really reverted into 2022, driven by higher interest rates, but we're confident that the gradual expansion of the net interest margin and selective portfolio growth will get the Bank close to those levels again over time. Summarizing, we expect the positive impact of markets, largely captured already in 2022, as well as the continued OCG growth of Insurance Europe, to more than offset the increased debt servicing costs and to be the key drivers of growth to EUR 1.8 billion in 2025, whilst at the same time, we expect the underlying OCG of Non-life and Bank to improve. Now, it is stating the obvious, but the OCG does remain sensitive to market movements.
We've listed a few here on the slide, and there are a few more in the appendix, as you're all aware of. So, let's move from OCG to free cash flow. Main message here is that we expect free cash flow to grow mid-single digit. This is based on a normalized 2001 level adjusted for items such as the sale of asset management, which is now completely out, as well as a higher catch-up dividend from the bank following a COVID-19 dividend ban earlier. For free cash flow, we expect mid-single digit growth not only in the long term but also towards 2025, as especially the dividends from insurance Europe and Non-life are expected to grow materially, driven by strong business performance in those areas and also by improved local solvency positions.
Let me point out that free cash flow doesn't always fully follow OCG, as there tend to be items that impact the local solvency ratio and remittance capacity that are not part of the OCG, like the UFR step-downs. As we've seen on one of the earlier slides, they reduced the solvency by around 15 percentage points. Now, there could be another UFR step-down in 2024, which will have to be absorbed by the solvency of Life. For the Bank, we have now been imposed a countercyclical buffer of 2%, which we will need to grow into in 2023 and 2024, which is also not captured by the OCG figure. For the international business, we see local restrictions on dividend. They're typically based on U.S. GAAP, which is the basis for OCG, leading to partially non-available owned funds and impacting remittances.
However, the remittances are expected to grow over time as OCG growth also grows over time based on local GAAP profits. Having said that, we do expect free cash flow to grow long term in line with our OCG growth. Few words on our balance sheet. Our balance sheet is strong, and it offers sufficient financial flexibility. Our group solvency position ended at 205% in September, and all business units are well capitalized. With a Tier 1 headroom of EUR 1.2 billion, Tier 2 of EUR 900 million, we continue to have ample flexibility. We also have a robust liquidity framework in place both at entity level and at group level. This consists of immediately available cash, repos, committed repos, and a revolving credit facility at group. Zooming into leverage on the next slide, I would say the key takeaway being here is that we're comfortable with our current leverage position.
We've historically had low financial leverage, and we continue to have a well-balanced maturity profile and strong debt servicing capacity driven by our strong free cash flow generation. Our credit ratings are well in line with a single-A rating target, and we successfully replaced an old 9% coupon Delta Lloyd legacy bond in August. Now, the strength of our balance sheet and leverage position are important drivers for our capital framework, as is shown on the next slide. As you know, NN Group has a three-pillar framework that looks at solvency, cash capital, and financial leverage. We've added a solvency ladder as an indication on how we look at the solvency pillar within this capital framework. Obviously, it's not mechanical. It will take onboard macroeconomic outlook, OCG expectations, and upcoming regulatory and model and assumption changes.
We've defined a comfort level between 150% and 200% of solvency, and within this level, we expect to pay a progressive dividend per share and a regular buyback of up to EUR 250 million. If the solvency ratio is sustainably above the 200%, this will provide opportunity for additional capital returns. For the operating segments, we keep capitalization at a level to be commercially successful. Any surplus capital is upstreamed to the holding. For Netherlands Life, though, we continue to manage the business on sustainable and stable remittances and on maintaining a strong solvency level. This is key to the predictability of our capital return. The second pillar, cash capital at holding, enables us to have cash available to cover stress events in the operating segments, as well as to cover holding expenses for one year.
The third pillar relates to financial leverage, where we aim to maintain a level consistent with our Single A financial strength credit rating. We manage our capital in a holistic way, looking at these three parts in conjunction that are closely linked, with the aim of providing attractive and predictable returns even in these volatile markets. In doing so, we remain absolutely committed to have a progressive dividend per share and an annual buyback of at least EUR 250 million. As done historically, whenever we have excess capital, we will either invest it into value-creating opportunities or return it to shareholders in the most efficient way, similar to the return of the net M&A proceeds of EUR 750 million out of the sale of NNIP and the recent acquisitions.
Now, let me wrap up and conclude that over the last couple of years, NN Group steered its business very well through volatile markets and created substantial capital returns to shareholders. We're confident that we will continue to do so, and we've upgraded our EUR 1.5 OCG target of 2023 to EUR 1.8 billion at 2025. Although we did bring growth forward versus what we indicated on our last Capital Markets Day, we do reconfirm our long-term mid-single-digit growth guidance. We also expect mid-single-digit free cash flow growth to 2025 and also over the longer term. Based on this and our resilient balance sheet, we confirm our current capital policy consisting of the progressive dividend per share and an annual buyback of at least EUR 250 million. With that, I'd like to hand over the floor to Bernhard, our CRO.
Yeah. Thank you, Annemiek. Hello, everyone. Good to see you. In my part of the presentation, I will give you insights into how we manage risk in these uncertain times. I want to address how our diversified risk profile supports operating capital generation, and I want to discuss the strengths and resilience of our balance sheet. Let me start with our risk profile and the financial strength. Our capital position is strong with a solvency ratio of 205% end of September. If you look at the development of our solvency capital requirements since our previous Capital Market Day, this is the table to the left-hand side of the slide, there are two main changes, market risk increased and insurance and business risks decreased. The increase in market risk is reflecting the shift to higher-yielding assets.
We now have achieved a good asset mix with capital requirements for interest rates being close to zero. The main driver for the decrease in insurance and business risks is the reduction of longevity risk. Even though longevity remains the largest insurance risk driver, we achieved the reduction of longevity risk via the reinsurance transaction that we did over the last years. We have a well-diversified risk profile, which is supporting sustainable operating capital generation. Now, let me go through the key sensitivities of our solvency ratio. At current interest rates, our closed economic interest rate position leads to a relatively low interest rate sensitivity for both parallel shifts and steepening of the interest rate curve. Interest rate sensitivities have reduced over the last years. There are some moderate changes to the other sensitivities.
Those are mainly reflecting our re-risking and rebalancing activities within our asset portfolio over the last two years. For example, a joint 50 basis point spread widening of corporate credit and mortgage spreads would now lead to a -5% total impact on our solvency ratio. Please note that our sensitivities are point-in-time estimates and linear approximations. Therefore, if market movements are larger, the range of the application of the sensitivities is limited. For all of our key sensitivities, we have defined tolerance levels. We monitor the respective exposures on an ongoing basis, and we take actions to stay within the levels if needed. Since the introduction, we have never had a breach of these tolerance levels. Even so, we have not changed our tolerance levels in the last years, and our sensitivities have not changed very much.
We observe in the current environment a higher volatility of our solvency ratio simply because of elevated market volatility. Let's discuss the key drivers of volatility of our solvency ratio in a bit more detail. I will start with interest rates. Our approach to interest rate risk management has not changed. We continue to view interest rate risk as a non-rewarding risk, and therefore, we do not make interest rate bets. We apply strict cash flow matching of assets and liabilities on an economic basis using fixed income securities and interest rate swaps. As you can see on the visual on the right, this means the economic impact from changes to interest rate is close to zero. There is a remaining interest rate sensitivity of the solvency ratio according to Solvency II valuation principles, so resulting from risk margin and UFR impact.
In this environment of higher interest rates, the resulting sensitivity is now low. When we manage our interest rate position within our economic steering approach, we take these sensitivities and the impact on the solvency ratio into account. Lastly, on interest rates, the recent increase of interest rates triggered additional collateral requirements for our swap portfolio. We actively manage the liquidity requirements for required collateral, and our conservative balance sheet is very liquid, and we have prudent liquidity policies in place on Group and on legal entity level. This consists of immediately available cash on legal entity and on Group level, but also committed repo facilities and a revolving credit facility at Group. With this, we feel very comfortable with our current liquidity position. Another driver of volatility of our solvency in this year were mortgage spreads.
As you can see from the chart on the left, mortgage spreads this year were exceptionally volatile. This is a result of larger volatility in interest rates, while commercial client mortgage rates are typically adjusted with a time lag. Our whole mortgage portfolio is valued on the Solvency II balance sheet using the current point-in-time mortgage rates offered to clients in the Dutch market. The volatility of these rates directly translates into volatility of our solvency ratio, and this is obviously leading to artificial volatility. In addition, unlike for corporate bonds and government bonds, there is no dampening effect on the liability side in the form of a volatility adjustment for Dutch mortgages under Solvency II, which is problematic as mortgage spreads are not moving in line with other credit spreads.
The underlying volatility or the resulting volatility is really not an adequate representation of the underlying risk. What are potential measures to mitigate this artificial volatility? One way is to address non-economic point-in-time effects, and another way is to include a dampening mechanism specifically for Dutch mortgages in the internal model to enhance the volatility adjustment. These adjustments take time to explore and implement, and therefore, it's too early to comment on feasibility. To wrap up this section, please be reminded that the impact of changes of interest rates and credit spreads, including mortgages, are mainly related to stock and flow items. An immediate negative impact of market movements on the solvency ratio means an increase of operating capital generation over time and vice versa. The related volatility is not impacting the real underlying cash flows.
Now, some more insight into our financial strengths and resilience in this environment. An essential part of our NN Group strategy is to maintain a strong and resilient balance sheet, which is supported by our high-quality investment portfolio. We will continue with our conservative approach to investment risk. What we have achieved is that the target that we set previously on Capital Markets Day 2020 to increase operating capital generation by at least EUR 200 million shifting to higher-yielding assets, this is something we have achieved. Our current asset allocation is close to our target strategic asset allocation. We now gradually further optimize our asset allocation without further increasing market risk, and therefore, we expect only limited further upside on OCG. Let us go through the key asset classes in a bit more detail and how they are impacted in a recession or inflation scenario.
One of the asset classes that we have strategically invested in is Dutch mortgages, representing around 1/4 of our total investment portfolio. The profitability of this asset class is good. Spreads are around 200 basis points. The risk profile is low. Most of the mortgages are originated by NN Bank, providing unique sourcing capabilities. We stick to a very disciplined underwriting approach. In our investment portfolio, we hold long maturities and long maturity mortgages with fixed rates. This asset is embedded into a strong institutional framework in the Netherlands. There's strong social security, adequate unemployment benefit. There are restrictions on LTV, special tax treatments, and around 30% of the portfolio is backed by the Dutch government. Therefore, we do not expect a large number of forced sellers in this market, even in an inflation or recession scenario with less disposable income of households.
The current loan-to-value level of our mortgage investment portfolio is low at around 55%, which is even lower than pre-COVID-19 levels. That means that even with pressure on housing prices, we do not expect large impacts given current low LTV levels. Lastly, there's still a large shortage of houses in the Netherlands, which will also offset the pressure from higher mortgage client rates. Historically, mortgage losses in the Dutch market in times of recession, and especially in NN Group portfolios, have been low, as shown on the next slide. In a recession scenario with high unemployment, we expect losses to increase, but unemployment levels and losses currently are at historical lows in the Netherlands. At a reference point after the financial market crisis, we have observed peak losses of around 10 basis points, which is still a low level.
So overall, this makes our mortgage business a very attractive asset class from a risk-return perspective. It's matching our long-term liabilities, and we are very comfortable with this asset class also going through an economic downturn despite the volatility it implies on our solvency ratio. Now, I move to real estate and corporate bonds. We have a well-diversified real estate portfolio across sectors and geographies in good locations. Overweight is Western Europe, and we underweighted UK Island, which served us well in the Brexit context. And overall, we also overweight industrial and underweight offices, which has helped during COVID-19 times. And the occupancy ratio of the portfolio is high with 94 percent, and we put much focus on location and selection. In some markets, we see house prices already declining, and in a potential recession, there could be a negative impact on valuations also on our real estate portfolio.
As a long-term investor, we can look through the economic cycles, and real estate is over the long run profitable and an inflation-protected asset class. For corporate bonds, the first thing to note is that our exposure is small, representing only 60% of our total investment portfolio. The majority are single-name exposures, and the credit quality of the corporate bond portfolio is high. Also, this becomes clear when we look at the limited impact from credit migration and defaults, which is on the next slide. On the left-hand side of the slide, the results are shown for a one big letter downgrade for 20% of the total corporate bond portfolio to assess the impact from credit risk migration. From such a scenario, we expect a negative impact of around three percentage points of solvency.
We also looked at peak-level default rates during the Great Depression and the financial market crisis in 2008 to calibrate the impact of a default risk scenario. You can see that the impact in both scenarios on the Solvency II ratio would be in the order of a few percentage points, representing our very good underlying credit quality of the portfolio. Now, how are we doing in the current economic environment? So far, the impact from inflation and the economic headwind has been limited. For Netherlands Life, the majority of liabilities are not sensitive to inflation. For Netherlands Non-life, the impact so far is also low, which Tjeerd will cover in more detail later. The impact of market value changes on our risky assets and our solvency has also been limited. We've done remarkably well in this current turbulent environment.
Even in a more adverse economic environment, we are well positioned to weather the storm. As just explained, the potential impact from defaults and credit risk is rather limited. In general, inflation, higher real rates are good for savings products and life insurance and also to reinvest at higher rates. To close this section, a few words on the regulatory environment. We still assess the impact from the Solvency II 2020 review to be digestible. Implementation of the new regulation is not expected before 2025. Regarding IFRS 17, we expect no additional constraints on remittances, capital management, or solvency, and our strategy and business model is unaffected. More on this also later in the IFRS 17 presentation. For NN Bank, the regulation introduced now the phasing in of a countercyclical buffer.
For NN Bank, it's also relevant for 2023 and 2024, which will increase SCR and therefore also has a negative impact on the Group solvency ratio. On ESG, we are implementing the various regulatory requirements and embed those, be it internal according to our strategy and goals, but also the external requirements in our risk management processes. Yeah, we continue to have a regular dialogue and discussion with supervisors and regulators on various topics. To summarize, we have over the last years successfully implemented our strategy and improved the risk profile, which is well diversified and supports sustainable operating capital generation. Obviously, we cannot fully mitigate solvency ratio volatility, especially not in these markets, but most of the volatility goes back to stock and flow items and does not impact the real cash flows.
We have a strong and resilient balance sheet supported by our high-quality investment portfolio with low credit risk, and we are well positioned to weather even more severe economic scenarios. With this, I will hand over back to Ruben for the Q&A.
Yes, thank you, Bernhard. Now it's time to move to the first Q&A session. A lot of hands, I see, so that's a good sign after the session of Bernhard and the update of the strategy and our targets. I'm inviting David and Annemiek on stage as well. Maybe before we start on a practical note, yeah, so please raise your hand so that part is already covered. That's very good. Thanks, all. Enough excitement here. Please wait till there's a microphone. We have two here so that everyone can hear the question.
I would also like to ask you whether you can state your name and the company. Please limit your questions to two, and then we can do a second round if required later. One thing I need to stress is that at 10:00 A.M., there's going to be a fire alarm. We might be in the middle of the Q&A, so just good for you to be aware that that might happen. We will briefly pause the Q&A for a minute. Time to go to the Q&A. Thanks, guys. Maybe we can start on the right with Ashik. Please go ahead, Ashik.
Thank you, Ashik Musaddi from Morgan Stanley, and good morning, everyone. Just a couple of questions.
First of all, I would like to get a bit more color as to what is the definition of sustainable when you think about this above 200% solvency and higher dividend? You want your solvency to be sustainably above 200% to think about extra buybacks. How do we think about that definition of sustainable, especially in light of the presentation by Bernhard that market risk is not really a big thing? I mean, whichever way you look at it doesn't look like your solvency will move around a lot given the diversification of the book. The second thing is, if I remember correctly, in the past, there is always a view that free cash flow and OCG would more or less be similar over time.
Are we trying to say that now going forward, there will always be a gap between the two because OCG is moving mid-single digit, free cash flow is moving mid-single digit, but with a lag of EUR 300 million, which is a 20% gap? Is that gap going to stay in the near future? Thank you.
Yeah, thank you, Ashik. Annemiek?
Yeah, I think they're both mine. Your question on sustainability, sustainably above the 200%, what we mean by that is that based on the forecast that we have at that point in time, which takes on board the macroeconomic situation, the OCG outlook, upcoming model and assumption, or regulatory changes, we feel that we're sustainably above that 200% level.
Your question related to OCG versus free cash flow, as I already said in my presentation, there are some items that are actually not captured within the OCG that do impact the free cash flow. I've mentioned the U F R step-downs. There could be another one which will have to be absorbed by Life, which is not in the OCG but is actually reflected in the free cash flow. Same goes for the bank where we have to absorb for the countercyclical buffer. That would roughly be it's divided over two years, but in total, it could be 3 % on Group Solvency ratio. And then for the international business, the actual remittances are defined on local gap. And we typically have some non-available owned funds there. As a rule of thumb, you could maybe think about 1 percentage points of solvency over the year.
There are always some items that are just not in there.
Sorry, just one clarification on this. If I understand, the bank mortgage thing and the UFR thing is a drag on OCG, but why would it be a drag on free cash flow? Because, I mean, if you increase the capital requirement for Bank, your OCG comes down. Probably so that should actually mean that free cash flow should be even higher than OCG, if I understood correctly.
No, that's not the case for the bank. What we've seen in the UFR step-downs for Life, they will have to absorb that within their solvency ratio, and it is not part of the OCG. In total, that is a difference between the actual capital generation that we see and the OCG. It is not fully aligned. The growth trend will be similar.
All right, next question. Cor, please go ahead.
Good morning, Cor Kluis, ABN AMRO ODDO BHF. Thanks for the presentation. Two questions. First of all, on re-risking. You made during the last Capital Markets Day, of course, clear that you had EUR 200 million OCG by re-risking or optimizing. I think if you look through your balance sheet versus peers, it's still clearly less risk than at others. 2% equities, I think, is one of the lowest around, at least in Europe. Why not re-risk more? Stock markets are down 20%-30%. In the past, you had some nice timings during COVID-19 sometimes to buy some equities. You don't do it now. Is there a signal, or is there something about solvency, or what's the view? Do you have a quite pessimistic view on the world the next three years? Normally, you buy in times of crisis.
I think somebody in the U.S. bought EUR 60 billion the last nine months, who's generally good at timing. Why not re-risk, and especially in the current environment with low stock markets and nice credit spreads? The second question is Japan Life. Of course, you can never say what you're going to do with it, but there are things around quite some ineligible capital. There's quite some excess capital there, which you cannot touch. How committed are you to Japan? Do you totally exclude a divestment in the future, or what do you view on that? Those are my two questions.
Yeah, thank you, Cor. Let me start on Japan. Yeah, as I was saying also in my introduction, so we continue to evaluate all the units and portfolios in our businesses.
You've also seen that we have been taking action on the portfolio, and that includes Japan. The reason why we haven't set any steps in Japan is that there's a couple. First of all, it's a business that we know very well. We started this over 30 years ago ourselves. We have a leading position in the corporate Life space. Obviously, Japan is a very large market. It's the third largest market in the world. It enables us to deploy a significant amount of capital at attractive IRRs. At the previous Capital Markets Day, we talked about 14% IRR, and that's still the case. In fact, protection products actually give even a higher IRR than that. The positioning of that business makes it attractive.
Additionally, it also helps to diversify the profile of the group, so in terms of cash and growth, but also in terms of spread. Originally, when we IPO'd the company, we were very much a spread-oriented company because of the dominance of NN Life. We've seen over time a better diversification because of the VNB coming out of Europe and Japan, that we now see a more diversified mix between spread and also technical margin and fee business. Japan helps to diversify that profile. Now, there's some smaller benefits in terms of diversification as well in our internal model. That, all in all, makes Japan an attractive business for us. Again, as I say, we'll continue to evaluate if we feel at some point. That is not specifically for Japan.
If we feel we're not the right owner, then we will take action on that. Yeah, let me start on re-risking, and maybe Bernhard can add. At the previous Capital Markets Day, we announced a EUR 200 million uplift of OCG because of re-risking. We didn't do that because we didn't think that was more possible, but it was also because we want to maintain a very strong and predictable balance sheet. That's also why we came up with, let's say, the EUR 200 million. Now, as you know, COVID-19 created some very good opportunities. I think some of the things that we did were very well timed, and therefore, it was actually achieved ahead of plan. Now, if we look today at where we are, there might be some room left and right to increase, for example, investment-grade corporate bonds.
If we would look at our strategic asset allocation, there might be some room. First of all, today, we don't think this is the right moment to do that. Second, even if we would, it's certainly not as material as the steps that we were looking at in the past. Now, this can change over time. Today, given the economic climate but also that we really want to maintain a strong and predictable balance sheet, we're really looking more at optimization than really a big additional step in terms of re-risking.
All right, maybe we can move over to Benoît.
Yes, good morning. Benoît Pétrarque from Kepler Cheuvreux. The first question is really on OCG growth, maybe focusing more on 2022-2025. You have the EUR 1.8 billion level for 2025.
Now, if we do the math on 2022, I think we will get towards EUR 1.7 billion, maybe a bit more than EUR 1.7 billion. It looks like the CAGR 2022-2025 will be close to 1%. I wanted to get your view on, yeah, this kind of growth for the coming three years, basically, what you expect. Is that a realistic level, or that's just a very cautious growth outlook for NN Group? The second one will be on the dampening effect on the mortgage portfolio, what you plan to implement. Can we expect some effect on the stock at implementation date, or will that be just a dampening effect going forward with no impact on the stock of capital? I just wanted to clarify that.
Maybe to come back on this, yeah, the 200% level and the sustainability, I know it should not be too mechanical, but if we are above 200% for, say, two, three, maybe four quarters in a row, can we expect at some point action on your side? Thank you.
Okay, thank you, Benoît. Annemiek, talk about the OCG growth and the 200% not mechanical, as you say. Bernhard can do the question on mortgages.
On the OCG growth, I think your expectations on the 2022 level is a fairly good one. Also your conclusion that there is then towards 2025 still some growth. It's towards 2025, not mid-single digit from the 2022 level. I think that's a good conclusion. It's based on a couple of items. I think Life is fairly stable.
What we've seen versus the last Capital Markets Day, we actually brought part of that growth forward by the re-risking. We still have the benefit, if the book runs up, that we have a lower UFR drag. The UFR impact has just become less than what it was in 2020. That's more or less stable where we compensate the run-off of the book still by lower impact of the UFR and also by a bit of the increase in the DC proposition. That's stable. Europe is expected to grow. If you think about the 2022 expected versus 2025 level, that growth is also really coming from the European business. We see some impact there from rising interest rates on our own debt cost that you would have to mitigate for.
For Non-life and for Bank, we've indicated that 2021 were very good years there. On Non-life, we still had COVID-19 frequency benefits in there. That was just, in general, a very good year in a very benign environment. We expect underlying further improvements of the combined ratio, but also the market sentiment in Non-life and the claims to normalize a bit. That's why we more or less would assume that to be relatively flattish towards 2025. On the Bank, 2021 was really good as well because we had very high prepayment penalties, very high fee income. That obviously reverted in 2022 by the rise of interest rates. The income from Bank looks different. We do expect that the expanding net interest margin will recoup that. Underlying, there will be improvements for Non-life and for Bank.
In the actual growth 2022-2025, we don't expect a material impact from that. Your question as to the sustainability, if we would be several quarters above the 200 percentage points of solvency ratio and we would have a good outlook, I would qualify that as sustainable.
On mortgages, it's too early to tell because this is something we are exploring. This involves also discussions with auditors, regulators. To manage expectations, I would not expect something before mid of next year. This question you touched on, has this an effect on stock of capital, yes or no? That is too early to say.
All right, maybe move one, gentlemen, to the right of Benoît.
Great, thank you. Andrew Baker from Citi. I guess the first one just on the OCG walk on, I think it was B7.
Just to clarify, I think it's as of the half of June 30th markets. You indicated at the half-year you're expecting EUR 150 million benefit in the second half this year. I know that's come down probably to EUR 100 million or so. Is that number in the EUR 1.8 billion, or is the EUR 1.8 billion actually EUR 1.9 billion if you were looking at markets today, if that makes sense? Secondly, just on the 1-in-20-year cash-at-holding company constraint, what does that look like right now in a sort of absolute number? How volatile is that 1-in-20-year stress to market moves? Thank you.
Yep, thank you, Andrew. Busy day for you, Annemiek.
If you look at the walk on B7, I'm going to get the slide there.
We did indeed guide at the half-year results when we had the EUR 899 million out that we would expect for the second half of the year an uplift of around EUR 150 million. EUR 100 million was related to interest rates, EUR 50 million to mortgages. That was based on June. These figures are based on June. On September markets, that would obviously be different. Given we always lag a quarter behind on OCG, half of that EUR 150 million, so EUR 75 million, we locked in in Q3. On September markets for Q4, that would not be EUR 75 million, but that would be EUR 25 million because of the change in mortgage spread. Having said that, if you roll forward a bit to end of October markets, we're probably roughly in line with June markets. It continues to be volatile.
Given we have a quarter delay, in total, I would say that guidance of EUR 150 million for the second half-year market impact would now be not EUR 150 million but EUR 100 million in total.
Sorry, is that in the EUR 1.8 billion or no?
Yes.
That is? Okay, thank you.
It is. The cash capital level, that was EUR 2 .5 billion in June. Since then, we've obviously continued with the buyback program of EUR 1 billion that we announced, and we've paid out the interim dividend. We haven't disclosed the figure, but it's fair to assume that that would be down now.
Let's move on, gentlemen, further of the table. Please go ahead.
Hi, thanks very much. Hadley Cohen, Deutsche Bank. Just an extension from Andrew's question, which I'm not sure was necessarily answered.
The target range for the Holdco cash has changed, and you've effectively removed the EUR 0.5 billion-EUR 1.5 billion with the 1-in-20. Can you give us a bit more color of how we think about that 1-in-20 shock scenario, where that sits sort of in relation to the EUR 1.5 billion level right now, and how volatile can that be going forward? My second question is on the real estate sensitivity. I appreciate that you're aiming to reduce the volatility of the balance sheet and what have you. For a 10% fall in real estate, it's a 12% hit to solvency. Anyway, I think we've already started to see some real estate prices come down in the Netherlands Bond yields continue to push higher, which could put further pressure. How do we get comfort around that sensitivity within the solvency calculation?
Yeah, the rest of my questions have actually been asked already, so I'll leave it there. Thank you.
Okay, thank you, Hadley. Annemiek, on the where do we sit today in terms of the 1-in-20 shock scenario? Bernhard can take the real estate question.
Yeah, on the cash capital and the 1-in-20 shock, I think historically, we've always guided for between EUR 0.5 billion and EUR 1 .5 billion, which was a couple of years ago. The company grew, obviously. The 1-in-20 shocks depend on the starting level of solvency. It also depends on the scenarios you would take on board. I think it would be fair to say that we would be between EUR 1 billion-EUR 1 .5 billion, more on the upper end of that previous range.
Having said that, if I would look at and try to get a feel of where, at what level, would there be excess capital, I would more look towards the solvency ladder where we've indicated that if we're sustainably above the 200%, that would be a trigger point for additional capital returns.
Yeah, on real estate, we are definitely not immune against market movements. This 10 percentage point drop or sensitivities that we show, I'm assuming it's a shock one point in time and the impact then on solvency. If you look at the forecasts or if you look at also how mortgage valuation works, also in a recession, how the recession scenario will look like, we also expect that some of our mortgages, not only mortgages but also real estate, is doing better than other areas. It will be a longer process.
In this time, we also earn quite a substantial return on this asset class. This is, from my perspective, not a sensitivity or a stress that will materialize in a week or in a month, but it's more really something over one, two, three years. It's also about, again, the earnings that we have on the other side. Therefore, a little bit to put this into context compared to an equity shock, which is instantaneous and hit. Yeah.
All right, let's move over to the gentleman in front, Farquhar. Please go ahead.
Cool. Hi. Morning. Just two to three questions, actually, from me. Firstly, starting with David, actually. In terms of you've talked about the kind of protection opportunity. I just wonder if you could maybe just give us some proof points about where you are feeling you're actually seeing that come on the ground.
Also maybe in terms of new business value, could you just give us a sense of what your IRRs are currently running at on new investments and how much of that maybe is Japan? I'm going to have to come back on Solvency II, to Annemiek. If we come back to the issue of sustainability of the Solvency II ratio, you talk through kind of regulatory changes that are coming through and a bit about non-availability. I think the blunt question for me would be, are we at sustainable solvency levels today, given where we are? I think from the math, it would say looking forward, it would sound like we are, but I just wouldn't mind a fairly definitive answer on that one.
Thirdly, just going to Bernhard on real estate, you're very much profited from being kind of underweight offices, but just on the office portfolio, could you give us a sense of what you're seeing on the ground, particularly in terms of rent renegotiations and actually where vacancy levels sit now versus, say, more recently in history? Thanks.
Yeah, okay. Thanks, Farquhar. You're already allocating the questions too, so that's very helpful. Let's start then on protection. Yeah, we could just mess with you and turn it around. The protection. As I mentioned, so far, we've seen in the last few years the market growing around 5%, and we've been growing 10%. I think that's because of the early focus we put on life protection.
We shifted a bit earlier away from traditional endowment and guaranteed products and to a certain extent also unit-linked towards life protection. I think that has served us well. I mean, for Europe, we report that in VNB, and you've seen the strong development of VNB in Europe. If you look at also the growth that we're forecasting for Europe in terms of OCG, which is we now give a target of EUR 450 million, there's a bit of help of rates, but a lot of it is driven by new business contribution. If you would break down the growth in OCG, new business contribution is a very important contributor. The reason why we're comfortable saying that is that we have been doing it already. The growth has been there. In fact, we would argue that the demand actually has been increasing for customers.
I think the biggest challenge today is actually the affordability. I mean, most of the markets where we operate have double-digit inflation, so there will be pressure on purchasing power of people. I think that will be the challenge for our distribution channels to work away through that. In terms of returns, we all know that protection just has a higher margin than general life products. I think your question on IRR for Japan, we said earlier around 14%. In Japan, we are shifting the mix. I mean, if you make it very simple, we have two types of products that we sell, which is a protection product and then more of a hybrid product that also has a savings element in there. We're more and more focusing on the protection part. I see that the fire alarm will start in a minute. Anyway, we'll see.
We're more and more focusing on the protection part. That actually has today in IRR around 17%, so it is even more attractive. It's still quite a bit of work to get distribution channels to sell more protection because, well, typically, short-term savings products often in the past have been a bit easier to sell for these channels. It continues to be a very attractive market. We guide around EUR 150 million VNB also for Japan in 2025, leading also and supporting the OCG growth. I think on both cases, we're actually positive that despite some of the economic challenges, that the product mix is a high customer demand and very good margin, and that we'll also sustain that in the coming years. Please stop now, it says.
You're on time, David.
Th ere you go. There we go.
Yeah, we'll just have a break for a minute, I guess. The fire alarm is about to be tested. Please take no action. Oh, all right.
Well, thank God we're not evacu ated.
We have to. Yeah, we need the questions back.
Yeah, we're just waiting for everybody to get back online now. Exactly. There you go. Perfect. Yeah. Okay. It's two sustainability. Are we today sustainable, Annemiek?
Bernhard will take the real estate.
Well, our solvency is, in general, sustainable. The question is it sustainably above the EUR 200 million, and would it trigger additional capital return? I guess that's where you're coming from. We reported 205% at Q3. Obviously, we've seen quite some volatility in markets thereafter with mortgage rates widening again, partially offset by VA, etc., probably be marginally lower in October. Hovering around the 200% would, at this point in time, not qualify as sustainably above 200%. Let's wait and see when we get to the full-year results where we are then. Any decision we'll take on additional return will be based on that full-year results situation and outlook.
On real estate offices, but also logistics centers, they had specific dynamics during COVID-19 or the last two years where also there was some tendency, then also rethinking, for example, their whole office program or the way of working. That led more to adjusting contracts, and the contracts are typically rather long-term contracts. Therefore, until now, we have not seen pricing or rent pressure in this time. Too early to tell what now happens if the recession is really kicking in. The main pressure is coming via comparable real estate that is via sales. If now, in this environment, there are sales, and then in the portfolio, you see you have something equivalent. This is more where the pricing pressure, so to say, comes from now. It's not so much the underlying tenants or occupancy ratios or so.
Yeah, I think it's fair.
` I mean, if you look at a real estat e portfolio it's very well diversified then I think we spoke about it across sectors and geographies and I think that will definitely help at the same time you know, nobody can argue that you're immune if markets really come down significantly but I would say so far so good.
Alright then, let's move over to Farooq. Thank you and please go in.
Alright, thanks very much. Farooq Hanif from JPMorgan. Just want to come backon your capital targets overall, I mean, in the past you've really focused on the cash target. I just want to understand why you've shifted to above 200% because you know, you're saying you're going to do a buyback above 150%. You're clearly comfortable with giving capital back to the markets
You're also saying that you're kind of above a 1- in- 20 right now on cash, or you're indicating you're at the upper end. I just don't understand what's driving that decision. Question number two is, obviously, you've just said, "Look, mortgage spreads are widened. VA is widened. You've had some market movements." What does that do to your OCG, and is that in the EUR 1.8 billion target? Thanks.
Okay. Thanks, Farooq. Annemiek.
Well, to start with the latter, I think we already briefly covered it when we went through the bridge as well with the OCG target. We based the EUR 1.8 billion on June markets. In September, obviously, we've seen mortgage rates come in, which was good for solvency, but for the flow, it's a bit worse.
If you then look again end of October, we're probably for mortgages more or less in the same area where we were in June. I think from an OCG perspective, OCG target perspective, not that much has changed there, actually, if you would forward it from June to kind of end of October levels. EUR 50 million? Well, roughly, if you think about mortgage rates, that could be right. I think they first came down with around 50 basis points in three months, and then they went up again with 50 basis points in around one month, which also indicates a bit the volatility, clearly driven by first interest rate movements and then the lag in time with which banks actually adjust the client rates, which happened in October. We're now seeing some indications of that being adjusted downward again, but it continues to be volatile.
If we look at the ladder, we really try to focus on sustainable and predictable capital returns, right? If we're sustainably above the 200%, if we have a strong outlook, there will be room for more. If we're within the 150% to the 200% range, we'll focus on a progressive dividend per share, and we'll also focus on this EUR 250 million buyback. It's not mechanical, as we said before. Having said that, if you look at it, we continuously delivered on that EUR 250 million. We also delivered on it when solvency ratios were a bit higher since 2019. Also in June, when Group was at 196%, when Life was at 187%, even a bit further depressed in July when markets moved further, we continued to remit the EUR 250 million annual buyback. We do feel very comfortable about it.
Now, the cash capital target that we had, it wasn't a hard target, right? We just indicated we want to have a 1- in- 20 shock, and we want to be able to absorb it. It fluctuates over time, and I guess it's also quite hard for you from an outside-in perspective to get a feel on where is that target, what is it now, where is it going. We feel a solvency level that we also take into account on our decisions on dividend is more reflective of how we think about it, and it's also more aligned with what peers do and therefore a bit better to understand also from an outside-in perspective.
Just to confirm, it's internally driven, not regulatory driven.
Correct.
Michael, let's move to the gentleman in front. Please wait for the microphone. Thank you. Other side, yeah. Please go ahead.
Thank you so much. Three questions. I'm sorry. In the U.K., we've been obsessed by LDI, and you mentioned your cash collateral. I wonder if you can give some numbers, and I think one of your peers actually gives numbers on stress and how much it would cost. I remember from the 2020 presentation, and I wasn't there in person. I watched on the screen. There was an uptick in the curve from the maturing Life backbook. There's a lot of cash release coming in 2027. Doesn't appear to be here anymore, and I just wondered if I'd remembered wrong, probably. The other thing is two of your peers are doing something really big, so there'll be some disruptions. You haven't spoken at all about opportunities. Don't you see any opportunities here?
Okay. Thanks, Michael. I think Bernhard can take the cash collateral.
Uptick of the curve, I'll try to answer that, but I'm not sure I understand y our question.
I can do that.
Yeah. Yeah, peers, no opportunities. Well, then I didn't do a good job in explaining that. Yeah, we see a lot of opportunities. When we talk in the European business, obviously, in the Japanese business, we spoke about the growth and protection that we see. Also in the Dutch market, and later today or this morning, Leon and Tjeerd will speak around that. I think we lowered our guidance for the Non-life business, 93%-95%. We also see some pockets of growth, for example, in the direct business on the Non-life side. DC, obviously, and again, we'll talk about it after the Q&A. DC has continued to grow. There is the possibility that the pension reform will further increase the amount of growth.
Even if it doesn't, we already see today that between EUR 1 billion, EUR 2 billion of net inflow we've been seeing, and there's no expectation that that will slow down. Expectations around DC growth, there is the potential with higher rates that we might see some buyouts coming to the market on the Life side. Obviously, on the Non-life side, we have some growth opportunities and a lower ratio. I think the market is still relatively hard if you look at pricing. We've been doing premium increases. The competition also has. We still expect, even though there's always more pressure in retail motor than in some of the other books, it's still a market where we think we can sustain our profitability without actually losing volume and, in fact, grow the business a bit.
Yeah, I think there's more than enough opportunities out there also in the Dutch businesses. Bernhard, on liquidity.
Yeah. What was observable in the U.K. market, if you take this as an indicator of daily movements, these are movements where our cash position is sufficient to cushion this. If this kind of liquidity squeeze would last longer, we are very well prepared to even have higher or cushion higher liquidity requirements. We do not publish a specific number, and there's also not a, let's say, requirement around this in the way of or kind of standard to. Therefore, it's also a little bit difficult to compare a number with another. Very good question on the costs, opportunity costs.
Until now, we were able to do the kind of liquidity free-up that we needed also for the collateral as part of our normal SAA activities as we haven't had enough short-term liquid bonds. Also until now, there was no opportunity costs involved for us.
On your question on the 2020 presentation and the uptick in the curve from maturing Life book, I guess you would refer to one of the deep dives that have been held, which was kind of where we set at end 2020. The UFR drag on OCG was around EUR 1 billion per annum at that point in time. With the runoff of the book, every year, that drag becomes a bit lower. That in itself is a bit of compensation for the actual runoff of the book and the loss of investment income that we've seen there.
That was also one of the reasons why that attributed a bit to the growth going forward. By the higher interest rates, we actually brought that forward because that EUR 1 billion is no longer EUR 1 billion of UFR drag on a per annum basis. It's actually much lower now because interest rates have gone up. That means we have already captured that in the OCG, and the actual growth of a declining book and not having that every year is already captured in there. There is lower growth from that perspective coming out of it.
Yeah. Before we go to the break, maybe one last question from David. Please go ahead.
Thank you. David Barma from Exane. I have two questions on the Netherlands Life, please. The first one on coming back on cash versus capital.
Wouldn't you say in the current rate environments, what we see as capital generation in Dutch Life is a much better reflection of the real generation capacity of your business? Hence, I'm not sure I understand the gap we were talking about before between the two and why those two couldn't converge sooner. To put it next to that, you talk about commercial levels for your capital positions in your local entities, and that Life has been anywhere between 200% and 220% in the last few years. Is that really a commercial level for Dutch Life? The second question is on longevity. You showed a slide about longevity SCR. What's your thinking about your opportunity still there to reduce that? Thank you.
Yep. Thanks, David. On cash capital and commercial levels, obviously, 200% is not, Annemiek. Bernhard, on longevity.
We capitalize all units on commercial capital levels except for Life because for Life, we really focus on having a stable and sustainable remittance out of that. If you look at the remittances for Life in 2019 and 2020, Life actually remitted more than its OCG. That was partially driven by the expected uplift of investment return because we knew we were going to do the shift to high-yielding assets. It was also related to a longevity transaction that we did at that time where we freed up capital, which was also contributed. I think we're now moving more towards an era where, based on current market levels, the OCG will be relatively in line with the free cash flows coming out of Life.
Except when they would have to absorb another UFR step down or other regulatory impact, we would probably like them to absorb that within the solvency ratio as it currently stands. If it has been built up forward and if it is sustainably above a 200% level as well, then that would not be needed, and that would be able to be converted. That's what we mean with potential regulatory impact. It could be something that you would have to absorb within the solvency of Life.
All right. Yeah. On longevity. Oh, sorry. We, as I indicated, reduced our longevity risk, but it's still the highest insurance business risk-related risk driver. There is still potential for additional reduction and also to free up capital.
Because it's no longer such a concentration risk in our portfolio and also because of higher interest rates in this environment, from a risk-return perspective, it's less attractive compared to the deals we've done two years ago. Therefore, this is, of course, what we are also mainly taking into account. Yeah.
Yeah. With that, I would like to thank you, David, Bernhard, Annemiek, for taking all the questions. Also, I would like to thank you for all your questions. I do realize that you might have still quite a few of them that you would like to ask. The good thing of a physical meeting here is that you can, well, have a coffee with them to ask all the remaining questions in the remaining break.
We will be breaking for roughly 30 minutes, and then we will continue the program with presentations on the businesses. Thank you all for now, and see you back in half an hour. Thank you. All right. Welcome back, everyone. Good to see you here again. I hope you had the opportunity to ask all your remaining questions to David, Annemiek, and Bernhard. I did see Annemiek talking with a lot of people and answering a lot of questions still, so that is, that's very good. We now move over to the business presentation. Before I hand over to Fabian, after that we will have presentations from Leon and Tjeerd on the Dutch Life and Non-life businesses. Now I would like to give the floor to Fabian.
Thank you. Thank you. Good morning, everybody.
It's a pleasure to be here in person, and I had quite some interesting and good conversations with you already. I will now present to you, as responsible for the International Insurance activities, where we are in achieving our targets that we set two years ago, how we will actually grow the business, and what our growth ambitions for 2025 looks like. Our International Insurance activities, they are in Eastern and in Southern Europe. They are in Belgium and in Japan. With those 10 International Insurance business units, we generate, meanwhile, close to 30% of the OCG of the group, and so we are a major contributor. We expect this share to grow even further as we are driving most of the VNB of NN Group. Two years ago, in the middle of the COVID-19 crisis, we set ourselves ambitious targets for 2023.
We have achieved them both for Europe and for Japan. That was possible thanks to the inherent market growth and fueled by, actually, the increased awareness around protection where the COVID-19 crisis for sure helped. A strong contribution came, actually, from the implementation of our strategic investments and the commitments and efforts of the teams on the ground. Let's get started with Europe. We've put ourselves a target of EUR 450 million OCG, and that translates into a year-on-year growth of 9% from 2021-2025. We can comfortably build on the following levers. First of all, we have tailwind from the higher interest rates that support the investment margin going forward. Second, we have had very good years of growth in the past already.
This growth and this new business, as you know, will now be recognized gradually in our OCG figures going forward. Third, of course, we are in the middle of the integration with MetLife. Those three levers are there, and they will help us to ensure that growth. To sustain our growth both in the short and the long term, we will continue to drive our new business up. This will be possible thanks to our strong positions in really attractive markets and thanks to the scaling of our strategy that has already shown clear traction. Our international markets, they have all in common that the insurance penetration in those markets is much lower than in mature markets. When you look at the slide, you see on the left side, you see Romania, you see Greece, you see Turkey.
They have 1%-2% compared to an average of 9% of the OECD countries. Even if you go to the right side, you see that with Spain and Belgium, with 5% and 6%, even there is a gap to the average. What does that mean? That means that when the GDP in a country grows, sales of insurance will even grow faster. That is, simply said, because if households have more budgets, insurance will be then one of the categories people invest first into. That will overall be a very important part of our growth. We have a strong position in most of the markets in life and in pension, which is actually quite a scale business. We are the number one in Romania, in Slovakia, and in Poland. These are our big pension businesses.
All of those businesses, they have been built organically. We just celebrated 25 and 30 years of existence in markets like Czech, in Greece, in Japan, even 35 years. The fact that they have been organically built and were so long and stable in those markets, this, of course, helps our reputation, helps the trust, and ensures, you know, that we have been building teams over the time with a solid know-how in what they do. Let me now speak about the principal drivers of new business growth. The first one is protection. David already mentioned it. We are focusing already since quite some time on protection as a market in which we believe. You see that over the last years, we have been growing at 10% compared to a market which is at 5%.
We plan to continue on that path and to invest into data and product innovation. To give you an example, we have a new cloud-based platform that can be deployed in any country and that allows us to develop in really a very short time because it's fully parameterized, innovative, fully digital protection products. We're just in these days launching a new innovative health product in Spain. Thanks to that platform, we have been able to launch it to the market in about 30% of the time which we would have needed with the old system. It's a real, you know, tangible advantage which we can use in order to drive that. The second driver of growth is our partnership management.
You've seen that, in the past, we have had a very strong growth with our partners. Here, it's important that we continue to invest jointly with them, be it brokers or banks, into digital roadmaps fully API-driven. We just launched such platform for brokers in Belgium for the retail protection. Here, one of the most important USPs which we actually have is our capability that we can offer the banking products of our bank partners and their services through our distribution channel to our customer base. This becomes a reciprocal relationship. It's not only, you know, the bank selling our products. It's as well, the other way around. A good example for that is when you look at the mortgage businesses which we have in Spain, Poland, Slovakia, and Romania. These are mortgage products from our bank partners.
We've become, in those countries and those markets, the number one external distributor of mortgages of our partners. It's really building strategic relationships which, of course, is a very, very attractive value proposition. Another differentiator is that we have built a strong position in sustainable investment solutions. For example, we just launched last year in Slovakia the first ESG-driven pension fund. In just a little bit more than a year, we got more than 35,000 customers, more than EUR 200 million of assets into that fund. That's a very nice differentiator to have. This is about now the third pillar or the third driver of growth, which is the leveraging and the growing of our own customer base via digitalization. We have built our own customer base through our agents.
These are our customers. It's around 7 million customers which we have and fully directed towards us. Here, we did investments, you know, since several years. We get now already, quite encouraging, results and really traction. In most cases, we have started pilots in one market. Now it's about to roll out those into the other markets. To give you an example here as well, in Romania and Poland, these two markets have been leading in the digital sourcing of our customers. We have in those markets between 25%-45% of our new business is already digitally sourced for our own customer base. This initiative is now being rolled out. The objective here is in 2024 to have 50% of our business is digital sourced.
Of course, that helps a lot in terms of customer service because you use the data. You understand the customer much, much better. It helps as well, the agents to become more productive because they will be much more targeted, whenever they are needed. It's not a full direct flow. I refer now to the fourth point on the bottom. We have created open platforms for our own distribution, allowing them to sell third-party products. An example of how we do that is in Slovakia where we have bought 70% of a broker portal. We will transform now our tied agent organization into a broker organization. That broker organization then will use the services of that portal.
That means that we give our customers and our ex-agents basically access to the products to all products from all providers in the markets, while at the same time, you know, we can leverage that technology from the portal. We don't need to invest and to build it ourselves. Yeah? These are the three drivers of growth which I showed to you, protection, partnership management, and the leveraging and growing of our own customer base via digitalization. That, you know, will be the fundament for the future. I'd like to give you a short update on where we are with the acquisition on MetLife. The integration is going fully according to plan.
We have actually been able to close the business in Greece three months earlier than what we had originally expected and planned for in Poland just on time. The teams are now already working together from the two companies. You can do that really after the closing of the deal. They are now preparing for the legal mergers which are going to happen beginning of next year. Therefore, we are really confident on the OCG guidance which we gave to you to fulfill that and to be really on top of that. That is just a few words on MetLife. Now, given the macroeconomic environment, of course, you'd be interested in a short assessment how that macroenvironment affects our businesses.
Here, we expect that and I think David and Annemiek both mentioned it that our new business will be impacted by the higher rates, first through the higher technical discount rate. That's a technical effect. Of course, by the lower disposable income of the households in the short terms. That is really short-term because medium to long term, we see the inherent market growth. We see the continued productivity increases that we have in sales and the progress we made through all our investments in leveraging our customer base. Medium to long term, we see it back to a growth which we are used to, which is double-digit. On OCG, international is resilient and will be growing.
That will be, in the short term, supported by the higher investment returns, the renewals, from the new business in the past. The new business growth then will continue to be the key driver, in the mid to long term. That's how we see the effect. It's a very limited effect on our business. That's why we are so positive, about the growth opportunities which we will have. Now let's go to Japan. Yeah? I've shared with you at the beginning how Japan contributes to the Group. In Japan, it's really a rapidly changing market environment in the SME space with quite attractive opportunities. We see in the market, and you see it on the table there, we see in the market growth in protection and in the category of long-term financial solutions.
The short-term financial solutions which have been kind of a major pillar of volumes in the past, so those are trending down. We have been leading the protection space with double-digit growth rates in the past. We plan to extend and to drive the growth to higher levels going forward. As mentioned before, it's a highly profitable business, very, very attractive margins, with double-digit IRRs and in a country where risk-free rates are still close to zero. That is on the protection side. We plan to enter into the long-term financial solutions in addition. We considered this segment now more attractive than before. That was very much determined in the past by traditional profit-share products. We see now variable products getting more and more traction. That, for us, makes that segment much more attractive.
In addition, we see as well that in the ownership of SMEs, there's a change, you know, that there's a change of generation. The younger owners come around. They look more for the longer-term solutions whereas the older ones were more focused on the short term. That gives us really, the strong belief that in this market, there are shifts. That market will be quite attractive going forward. That means that the overall VNB, huh? There where we took just over the last two years advantage of higher-than-expected sales in that long-term financial solution space, that in that, for that overall VNB, we will see some volatility going forward. There, in the short term, it will be lower.
We'll be growing back to current levels in the mid-term driven by the growth in protection and the opportunities in the long-term financial solution space. For that, we have a clear action plan how we will achieve that growth. We really differentiate ourselves in the space of insurers in Japan by two things. The first one is that we are really the SME specialist. That is our market. There's a much bigger market around. We focus on that. We do that by offering to SMEs not only classical insurance but a lot of services around. The teams have created, for example, the platform Kagyo-aid , which is a platform for SME successors who can exchange advice and can get connected. That has become one of the most used SME platforms in the market now.
In addition, we offer software solutions for administrative matters to SME owners who are often small companies. They have a real need. We do all of that in direct contact with the SME companies, you know, instead of going through the broker. That means that our name, our brand, is very known now in the SME segment. Of course, that builds trust over time. With that, even though we work with brokers and with banks, we have our position very clearly defined in that market. That builds brand, and, of course, those solutions give us, of course, very valuable data which we can then use as well to go to our customers.
Compared the other differentiator is really that compared to the very traditional hierarchical companies we see in Japan around, that we are able to get quicker and faster to the customer. That with customer-centric, really, solutions. One example which I show here is a living benefit product which we just launched in 2019. In only two years, huh, it reaches already 15% of all protection shares and EUR 10 million of VNB, which is for a new product quite amazing. The advantage is if you're customer-centric, if you're first, that is where you get to, huh? That is our action plan going forward. When you look then at the OCG target, the target which we have set ourselves is EUR 125 million OCG.
That is when you start from a normalized level in 2021, actually 5% growth rate, year-on-year. That is, as always, mainly driven by the strengths of the in-force book which we have built over time. In addition, of course, the new business then will be the driver for the mid- to the long-term OCG growth, a little bit similar to Europe. This is our story on Japan. Let me now summarize. You saw that our 2023 targets, we already essentially met in 2021. You see me very positive on the continued growth in Europe based on the inherent market growth and the strategic actions which we are taking. That despite the, you know, the impacts which we expect from the macroenvironment.
Important is that the protection products in Europe and the protection products in Japan, they all have in common very attractive margins which really makes it worthwhile to invest as much as we can into a growth in those segments. Altogether with that, international businesses are set to deliver the mid- to high single-digit growth in NN Group. Thank you for your attention. I hand over to Tjeerd, my colleague.
That is the most exciting introduction I've had in a long time. Good morning to you all. Thanks, Fabian. I'll be talking a bit about the bank and Non-life today. Last time, I talked about my passion for cycling and what it takes to win. It's always some hard work and efforts, teamwork, the right technology, using data.
Yeah, I stand here proud today that we've really delivered on that in recent years. I'll talk about that a bit later in the coming slides. When I look ahead, I indeed see again an exciting race, the usual hills. For the ones that love cycling, I think hills are fantastic but also unpredictable weather. When there is unpredictable weather, it's about being part of the right team, being fit, being prepared. That's, in a nutshell, the story that I have for you today. If I go to the first slide, we are the market leader in Non-life, of course, also the market leader in Life. Leon will talk about that later. We have a very good starting position.
We believe we can further benefit from the scale that we have in the Netherlands in both of these businesses. We have increased the target for Non-life to EUR 325 million. It came from EUR 250 million in the last Capital Markets Day. We've also increased the target for the bank from EUR 70 million-EUR 80 million. I'll explain how we get to that in the specific slides for the bank and for Non-life. Let's move to the track record. I'm very proud to say that Non-life has delivered all of its targets ahead of plan. Now, that may sound easy to some of you. When you do an integration of Vivat and Delta Lloyd, you're rationalizing part of portfolios, you're migrating systems, and you want to keep your talent in the midst of a war on talent.
You want to keep your brokers and your customers happy because you want to retain the volume that you have. Plus, you want to improve margin. That is actually quite a difficult task. I'm proud on what they achieved on the combined ratio, the admin expense ratio, completing Vivat integration ahead of plan, and also strategically extending the position both in distribution with Heinenoord but also on the HCS side, which is the services side of the D&A business, at the same time. Now, the bank is on track to deliver its ROE target for 2023. The C/I ratio of the bank is higher as was flagged in previous Capital Markets Day due to the investments we do in digitization but also in strengthening compliance. Now, I have two examples for you today on the strategy. The first one is about sustainability.
Now, sustainability, if you look at the theory, we follow, of course, the PCAF methodology, which is still under development. What we know of it today is what we follow. This typically starts with estimating your CO2 emissions of the Netherlands Life as related to underwriting portfolio of motor and the buildings that you insure. For the bank, it's, of course, very much related to the underlying mortgage book which is to deal with houses. You estimate, based on these model points, your CO2 emissions at a point in time. You set a target towards 2030 and 2050 with a concrete action plan of how you get to it. Now, you may think this is only theory, and this is a regulatory requirement. Actually, customers and society really demand this.
This is not just good for them, but it's also good for business. What we do on the Non-life business, for instance, on motor, already there, 65% of the business there in claims is through repair rather than replacing things. We also help our clients in electrifying car fleets. We also look at new risks that the energy transition brings such as recycling plants. We visit them. We look at what they have in place. These are, yeah, new risk opportunities that we can also add to the underwriting portfolio. Now, for the bank, it's, of course, about helping these clients to make their houses more sustainable. On average, we have a system of energy labels in the Dutch market. A is better than C.
So on average, we want the mortgage book to move from C to an A level. And we help clients by insulating their houses or by installing heat pumps. And that is, of course, good for clients because it lowers their energy bills. But it's also for a sustainable mortgage book to have, let's say, a much more greener, underlying house portfolio is also healthy for the business, healthy for the bank balance sheet, and, of course, also for the balance sheet of the other companies that carry mortgages. Now, the second example that I have is on digital transformation. so here, what we do typically is first and foremost, we invest in talent. it's people and talent that really make the difference in the digital transformation. it's, of course, having the right technology. And then it's about the use cases of how you apply it in your business.
Now, the example that I show here in the middle is an example of pet insurance where we process now 500,000 claims automatically through the use of smart OCR. You see here that the customer effort score is 1.5, which is extremely low. It's basically customers telling you this is almost effortless to do and undertake. That is extremely important because for broker satisfaction and for customer satisfaction, the effort that you need to take in order to do business with a partner is determining very much whether they want to continue to do business with you. Of course, it also helps in lowering cost.
If you do this, not just for pet insurance and our strategy, of course, to do this at scale in all of the different interactions that we have with customers and brokers, you see the increasing trend of broker satisfaction where already we are above market average in broker satisfaction. On the transactional NPS there, you see that you get continuously an increasing trend on the transactions that customers do with you. This is a strategy for all of the business lines that we have in the Netherlands. Moving to Non-life. You're aware, of course, of our Non-life business. We are the market leader. We have a strong distribution position. We have four out of the five largest banks in the Netherlands. We have a bank insurance partnership with very strong and broker number one.
We, of course, have our own direct franchise, OHRA. The pet example I just showed is indeed an example from OHRA. We added, of course, HCS and Heinenoord since last CMD to our portfolio. We have an attractive product mix. About 2/3 is P&C and 1/3 is D&A. On the right bottom side, you see the structural trend of lowering the combined ratio in line to what we also indicated last time to reach a 93.5% combined ratio in the full year of 2021. Now, going to the strategy of Non-life, so the strategy is to further invest in digitization, in digital to increase these, yeah, customer and broker journeys as I explained in the previous example. We'll continue to do that over the coming years. The other investment that we do there is in data.
Data is used, of course, for pricing monitoring, doing these improvements, differentiating the risks per client and per distribution channel. Of course, the underwriting criteria that you set but also the claims management. Continuously improving this underwriting cycle is the core business and, of course, also the core strategy that we have for investing in data in the Non-life business. With that, yeah, we come from a position where we were integrating Vivat. We're integrating Delta Lloyd. Now that you pull all the data, the key game will be to use the data to the benefit of improving the underwriting cycle for the coming period. Moving to the next slide, this is a bit more about the market position.
After the recent announcement, if the deal would close as was announced, you would see that, let's say the top three in the Netherlands have about 70% market share in the Dutch Non-life market where we are the market leader. We expect the Non-life market to grow slightly above GDP growth. We target selective growth in this market. We want to grow in SMEs and, of course, broker because all of the SME business is distributed via brokers, in direct, in bank insurance, and in further strengthening the non-insurance and fee business profile of this business. Now that we've completed these integrations and we've been focused on improving the margins, our aim is to stay at the level of, let's say, what you saw in 2021 in terms of combined ratio.
That's why we've increased our target to a best-in-class combined ratio of 93%-95% for the Non-life business and an OCG target of EUR 325 million. Now, if you compare that to 2021 and you would correct for some of the COVID-19 frequency benefits both in P&C and in D&A, you see that the main contributions toward 2025 come from a contribution of the insurance business where we target the selective growth that I explained on the previous slide and also growing the fee business or the non-insurance profile. Let me explain why this is ambitious to achieve. If you want to sustain a best-in-class combined ratio and selectively growing in a very competitive market, it means that you need all these improvements in your underwriting cycle, knowing where to grow, taking the right risks to grow the volume, and keeping the margin at a very high level.
Now, heading into a mild recession period, I mean, it's always hard to predict where this goes. In a competitive market, where this is going, this is what we aim to do, let's say, on a combined ratio level. Now, another question that we get on the Non-life business is with regard to inflation. The key message there is twofold. The first message is, and I think it was David where he highlighted that, is that we are, for 50% of the portfolio, we have quite a low sensitivity to inflation. Let me give you a couple of examples. For instance, in fire and motor, we do a lot of cash settlements on repair rather than that this is a, let's say, immediately an increase in prices from what repair shops bring. Legal aid, for instance, is fully reinsured.
For bodily injury, we use a long-term inflation assumption on what we do in that business. For the SME liability business, we use premium settlements that are linked to wages directly so that it is automatically corrected. In accident, for instance, we use fixed benefits. If we add that all up, we have 50% of the Non-life portfolio that has a low sensitivity to inflation. Now, for the other 50% of the business, what we do is we have typically 12-month renewable contracts. We monitor inflation. We look where it's going. We look at each of the specific items on expenses on what we see. We price that in like we've also done this year. In that, we don't think we are immune to inflation. I think nobody is. We do think that inflation is very manageable for our Non-life business.
The summary on Non-life, market leader, strong delivery over the past years, low sensitivity to inflation, and we believe that we can further benefit from the scale and the position that we have. That's why we've also increased the targets to 93%-95% and the EUR 325 million. Now, let me move to the bank. The bank, you know, is the number five retail bank in the Netherlands, about 1 million customers, strong CET1 ratio of 14.6% at the first half of 2022. We have at the bank a hybrid business model. On the one hand, we originate or distribute, and we earn a fee income.
On the other hand, we produce mortgages to put them on the balance sheet of bank where we have, of course, the savings where we fund together, the sort of savings mortgage bank, where we have the net interest margin that we earn there for the bank. Now, the strategy is to be an efficient digital retail bank. What does that mean? What is an efficient digital retail bank? It means retail only, so no SME or that type of business. It's the savings products, it's mortgages, and the retail products and services that you expect with a retail proposition. It's focused on digital. Really digital first, mobile first for a bank, no branches, and automating all these interaction points with brokers and with customers to achieve the low customer effort scores that you've also seen in the previous example.
And with that, you have a high customer satisfaction. You're able to attract and retain clients. you're efficient, of course, if you use, digital throughout, the bank. And you, earn on the cross-sell that you generate in the retail propositions that you that you have. That is the efficient digital retail bank strategy that we have. Now, looking to the mortgage market, maybe first starting with the portfolio that we have. the current portfolio is a, at an LTV ratio of about 54%, which is very low. we also made an analysis of our client, portfolio, and we looked at how many clients still have a fixed interest rate for, let's say, six years.
More than 90% of the clients in the existing book have a fixed-year interest that they fixed, of course, in a very low interest rate environment, for more than six years, which means that even if prices move up and down on mortgages, these clients just continue paying the bill that they locked in at the time that they had their mortgage. Bernhard Kaufmann also mentioned the historically low risk costs that come with mortgages. Underlying, of course, house prices increased massively in 2021. When you're at an LTV of 54%, even if that comes down a bit and housing supply is very short in the Netherlands, most estimates are that there could be a milder decline. At an LTV of 54%, we think that the mortgage book has a very strong profile. Now, the dynamics have, of course, shifted.
In 2021, we had long tenors, a lot of prepayment, a lot of new business, and a lot of wholesale appetite from long-term investors, both externally but also internally. That has now shifted over the recent sort of six months into an increase in the interest rates. We've seen less wholesale appetite, less, also, prepayments compared to 2021. We see a shift. This is the advantage that the bank has that in a time where the interest rates are low, you earn the income in a balance between fee and interest income. When it fully shifts, you see that fee income comes down a bit, but you can compensate that over time with the interest margins that we see now, on growing the bank moderately, with mortgages and savings accounts. That, we already see in the current figures.
There is a bit of a dip in this year, which you've also seen in the first half figures where OCG is lower because we're also growing the balance sheet of the bank. OCG is impacted because you grow the RWA. In the second half, we'll also try to grow more into NHG mortgages. Over time, you earn the interest income from the bank. Therefore, we also believe that we can offset the slight decrease in fee income with the growth of net interest income and increase the target to EUR 80 million. Now, that is also the story that is reflected here on the slide but then more in numbers. We've corrected the 2021 numbers for the sharp increase in house prices.
If you would take that as a starting point, you see, that towards 2025, growing the net interest income, with the reduction of fee income compared to 2021 where there were a lot of prepayment penalties and high fee income from wholesale investors, that we can grow the target to EUR 80 million. The ROE stays above 12%, which is very healthy. The C/I ratio, we continue to have the target to be below 55% where in the coming year, we continue to invest in digitization. That will still stay at a higher level than the 55%. The target for 2025 is to be below the 55% cost-income ratio. Let me try to summarize. I talked a bit about cycling, about the exciting race that we have had.
I hope that with the story that you've heard here, you also see that we are fit and prepared for that race. We have a strong track record. We have a leading position in the Netherlands. We can further benefit from our scale. That's why we've increased our targets for Non-life to a best-in-class combined ratio of 93%-95%, the OCG to EUR 325 million, and for the bank, an increase to EUR 80 million in 2025. I hope you enjoyed the story. I now hand the floor to my other favorite colleague in the Netherlands. We're only with the two of us, I know. Leon will have an even more exciting story to bring for you than myself. I look forward to receive your questions and answers later. Leon, take it away.
Thank you for the introduction, Tjeerd. Thank you for raising the bar.
Yeah, good morning, everyone. Last time, when I presented the Capital Markets Day targets for 2020 and I presented the life strategy, I was just appointed in my new role. Today, two years later, I'm really proud to present the results we have achieved so far. During my presentation, I will explain how Netherlands Life will generate sustainable operating capital generation from the in-force book and from growth in defined contribution pensions. Let me start with my key messages. We have delivered on our operating capital generation target of EUR 900 million from the last Capital Markets Day and raised our operating capital generation targets to EUR 1.15 billion for 2025. We have taken action to actively manage our balance sheet to secure our solid track record of free cash flow generation. We are a leading investor with a strong focus on ESG.
On top of the already growing DC market, the Dutch pension reform provides attractive opportunities for buyouts and to further grow our strong position in the defined contribution market. Now, let me start with our position in the Dutch market. NN Group is the market leader in the Dutch life and pension market with a consistent 40% market share. With more than 3 million customers, we have the largest in-force customer base and the broadest distribution capacity in the Netherlands. This is an important asset as scale is very important in the life and pension market and will drive future profitability. With my team of more than 2,000 motivated life and pension experts, we target to generate EUR 1.15 billion of operating capital generation in 2025. Now, let me first look back at the strong delivery on the targets that we set at the 2020 Capital Markets Day.
Like I said in my introduction, I'm very proud to present the results we have achieved so far. We are on schedule to achieve the EUR 900 million operating capital generation target for 2023. The optimization of our asset portfolio has significantly contributed to this, supported by positive market developments. On expense reduction, we are focused to continue to reduce the structural run rates of our costs, and we have clear plans in place to do so. We have made good progress to achieve the EUR 32 billion target for the assets under management in DC that we set for 2025. With a consistent net, annual inflow of EUR 2 billion per year, I'm confident that we are able to achieve the targets we have set for 2025. Last but not least, we have increased our footprint with the acquisition of the portfolio of ABN AMRO Life.
Now, let's move on to the targets for 2025. We have increased our OCG targets from EUR 900 million-EUR 1.15 billion for 2025. This is based on the second quarter market environment. In the past year, we have significantly reduced our government bonds allocation and optimized the investment portfolio. This has led to a strong increase of our OCG. Going forward, we will be more focused on refinement of our portfolio. Opportunities that we see are in investing in private loans and in corporate bonds at attractive spreads. We will invest in green bonds. We are committed to achieve the net-zero targets for the general account in 2050 in line with the Paris Agreement. As part of our strategy, we will further grow scale in defined contribution and buyouts, which will support overall business volumes and future profitability.
Finally, we will continue to reduce our expenses in line with the runoff of our portfolio. Now, let's move on to the next topic, our balance sheet management. Over the past years, Netherlands Life has a very strong track record of cash flow generation whilst the balance sheet stayed resilient. Due to the exceptional volatility in the financial markets and especially the treatment of mortgages, our solvency ratio stood at 187% in the first half of this year. The adverse impacts to our solvency versus previous levels are non-economic in nature, and the reduced solvency is compensated by higher OCG. Despite this volatility, we have remitted our quarterly dividend both in the second and in the third quarter of this year. A resilient balance sheet is an important priority.
Therefore, we are actively on top of managing our balance sheet via our risk management and investment approach, as Bernhard explained this morning. This is even more so important in current highly turbulent markets. We have been paying stable dividends over the last years. Going forward, we expect to maintain a stable and sustainable remittance pattern. Moving on to the topic of expense reduction. We have made good progress in reducing expenses. Since 2016, we have reduced the insurance expenses with 32%. We see good opportunities for further expense reduction, especially via the further simplification of our IT infrastructure and our products, as our Ops and IT expenses account for 60% of our total administrative expense base. We will deliver on our ambitious decommissioning targets of more than 20 large systems for this year and next year.
We also have plans in place for further reduction of the number of IT systems in 2024 and onwards. This is not an easy task to achieve. We need to reduce expenses whilst, at the same time, we have to absorb increasing costs related to inflation, investments in IT, investments in security, technology, but also investments in new regulation like IFRS 17, SFDR, and the recently announced new regulation for the Dutch pension market. Based on my personal experience, substantial potential is present to absorb this expense pressure. As mentioned earlier, the cost reduction may not be linear, as we need to invest to generate further cost reductions. Our target, therefore, remains to reduce expenses in line with the runoff of our portfolio. Now, let's move on to the growth opportunities and start with the explanation of the Dutch pension system. The Dutch pension system consists of three pillars.
Pillar 1 includes the state retirement pension, which offers a minimum pension income for all Dutch citizens. Pillar 3 contains the voluntary individual savings, which is a relatively modest market in the Netherlands. Pillar 2 consists of the employer pension plans. This is a large market with over EUR 2 trillion assets under management. In short, three different types of parties are active in the second pension pillar, industry-wide pension funds with mandatory participation for employers in certain industries, secondly, corporate pension funds without the mandatory participation, and thirdly, the insurers. The corporate pension funds and the insurers both hold roughly 15% of the market, and the remaining 70% of the market is serviced by the industry-wide pension funds. Pension funds are under pressure to increase scale and to reduce expenses.
Over the past 20 years, the number of pension funds has reduced in the Netherlands from more than 1,000 to currently around 200. We expect this trend to continue. The new pension legislation that we expect to come into force in the course of next year could accelerate this trend. Now, let's move on to the opportunities we see in the pension markets. The pension market is changing due to several dynamics. Firstly, there's the ongoing trend of the shift from defined benefit to defined contribution. There is also the recent consolidation of the PPI market. Secondly, the market for corporate pension funds and insurers will move closer because all pension plans will become defined contribution-based. For pension funds, DC is a new market where we have 15 years of extensive experience.
This will provide opportunities for us during the five-year transition period to the new pension system. This also means that the additional benefits from the pension reform will mostly come in after 2025. Thirdly, smaller pension funds will be in search for a solution for the accrued pension rights. The assets under management related to this are expected to be around EUR 75 billion. A number of these pension funds might decide to reinsure their existing liabilities via pension buyouts. We are active in the market for pension buyouts and have a solid track record. Of course, we remain disciplined when it comes to pricing for buyouts and capital allocation. NN Group is on pole position to capture all these opportunities I explained before. NN Group is the only company that offers the full spectrum of pension solutions in the Netherlands.
The ability to offer all these solutions is an important asset. In conversations with employers and brokers, I notice how much they appreciate that we can offer integrated solutions to their pension plans and for their pension plans. We are also increasing satisfaction scores both from brokers as well as from customers. I'm particularly proud that in this year we achieved, year to date, the highest satisfaction score from brokers in the pension market. It's very rewarding that all the efforts that my team and I have put into this are bearing fruit. For customers, we also see high satisfaction scores resulting from our improving customer service and our investments in digitalization. Finally, we expect to further increase satisfaction scores by offering additional services to our customers. Let me explain this further on the next slide.
Our strategy is to offer specialized services to increase the satisfaction scores for employers, participants, and advisors. We offer a range of various services, all currently available via the NN Group platform. Based on industry pension data, advisors can benchmark employer pension contracts, and we provide them with clear insights, which helps them as an advisor to increase their relevance to their customers. Another example is that we offer employers active tools to support them in being a caring employer, for example, via active monitoring of their workforce and via employee well-being services. Participants can get clear insights in the current and the future pension accumulation. This eases pension communication and facilitates participants in choosing their investment profile, additional pension accrual, earlier or later retirement, and many other topics they need to decide upon. Finally, for NN Group, this also creates additional value.
Our customer satisfaction scores increase, and this also increases the retention rates. Digital servicing also helps us to serve customers at a lower cost. Finally, these services also become a new source of fee-based revenues. This brings me to how we increase the profitability of defined contribution pensions. Defined contribution is a true scale game. Our strong position in the Dutch pension market is built upon two different propositions. One proposition via the NN label and one via BeFrank, our PPI. Both propositions have comparable features, but they target different market segments. Our strong position is built upon our high retention scores of more than 90%, a unique combination of products and additional services I mentioned before, and our solid investment performance of our DC lifecycle funds. Also, ESG is an integral part of our pension offering.
Most of our defined contribution investment funds are light green. In addition, BeFrank offers a dark green lifecycle with impact investment funds. I expect that the new partnership with GSAM will broaden the range of high-quality fund offering to participants. With the increasing scale, we expect to achieve our targeted operating margin of 15 basis points-20 basis points over the assets under management in 2025, which is targeted at EUR 32 billion. The growth of the assets under management in DC will continue also after 2025 to a comparable level as our current defined benefit portfolio. Before wrapping up, I want to share one more topic with you. Earlier this year, we acquired the life insurance portfolio from ABN AMRO Verzekeringen. The rationale of this transaction was clear. The transaction adds additional volume, resulting in economies of scale.
We have the ability to realize capital and expense synergies. We can increase the return of their existing asset portfolio by migrating them to the NN Strategic Asset Allocation. Combined, this will result in an attractive double-digit IRR. From the experience that NN Group have gained from doing similar transactions, such as the integration of Delta Lloyd and VIVAT Non-life, I'm confident that we will complete this integration swiftly and successfully within one and a half years. Now, to wrap up my presentation. Today, I've explained how I expect that NN Life will continue to generate sustainable operating capital generation in the long term. We have increased our operating capital generation target for 2025 to EUR 1.15 billion. With our risk management and investment capabilities, we actively manage the balance sheet to secure our solid track record of free cash flow generation.
NN Life is a leading investor with a strong focus on ESG, and we are well placed to capture the opportunities in the pension market. With that, I would like to conclude my presentation. Thank you for your attention. I now hand over to Ruben for the next Q&A round, I think.
Yes, correct, Leon. Thank you very much. Also, thank you, Fabian and Tjeerd, on these insights on your businesses and the opportunities you see going forward. Indeed, now it's time to move over to the second Q&A. I see already a lot of questions intended to be asked, so that's very good. Maybe we can start with where we almost left the first Q&A. Maybe, Jason, you could start this round. Please wait for the microphone and, if you can also please limit your questions to two, that would be much appreciated.
Take it away.
Okay. Jason Kalamboussis, ING. The first one is on Insurance Europe. The growth is 9%. If you look at it, if you take out MetLife, it's a bit of a more of a pedestrian, if you want, 5%. Do you think that this is a reflection of the growth that, potentially, you have in Insurance Europe? How much cautiousness do you put in there for the current macro situation? If you go a little bit beyond, do you find that, you know, this 5% is cautious and that could be expanded? The second thing is on Japan. I was just looking, what is the number for the morbidity effects, etc., on the OCG as non-recurring? That's a generic question also for Non-life and Bank.
Can we have the numbers, the adjustment numbers on 2021 so that we know at least from which basis we are starting from? Thank you.
Okay. Thank you for your question. Insurance Europe, we guide to a mid to high single-digit growth. When you speak about the 5%, which is actually 6%, but that is, you know, at the lower range of what we would expect in the medium to long term. That's how we see it. Of course, we reflect the current recession in our plan. That is reflected. I think it's, nevertheless, the best estimate of how we look forward.
On the Japanese normalization of 2021, I think if you start with a base of around EUR 103 million, EUR 105 million, that's a good base to start with. Yeah,
I'm sorry. Maybe we can go off to Benoît Pétrarque.
Yeah, Benoît Pétrarque from Kepler Cheuvreux. Well, actually, three questions. On Europe, how much cash upstream do you expect in percentage of OCG, yeah, over 2022-2025 on average? That would be question number one. Number two is on M&A. Where do you see M&A opportunities potentially in Europe? The third one is actually on the bank. Yeah, a couple of questions here. I mean, how do you see the pricing of deposits going forward in the Netherlands?
The pass-through rate, do you expect discipline or maybe a bit of competition on that side? How much loan growth do you expect going forward? I was wondering why the fee is down. I was expecting the originate-to-distribute model to be kind of sticky, kind of management fees sticky, and not dropping over years. I'm just wondering there. Thank you.
Yeah, maybe Tjeerd, you can start with the answers on the bank, and then Fabian, you can take the questions on Europe cash conversion and M&A.
Thank you. Yep. Yeah, we indeed target to grow the savings base. Yeah, what we've seen over the past months is that we've seen slight increases by the larger banks and then followed by the others again. I would expect that to be sort of disciplined.
There will always be a few players, typically smaller players who, yeah, go out with more aggressive savings rate. For the overall market, the top three banks in the Dutch market are very disciplined players, I would think so. We target moderate growth for the bank. Also in 2022, some of the mortgage origination that didn't go to wholesale investors, we've put on the bank balance sheet. That's why you also saw the slight decrease in the OCG figures for the first half of this year. Towards 2025, we project to continue that moderate growth where the chart you saw on the interest income is indeed compensating for the fee income, which brings me to my last question.
Yeah, for wholesale investors, for instance, there is a fund, previously NNIP, that's now with Goldman Sachs where we originate for their appetite. In those types of funds are typically more long-term investors. You get that fee income as a one-off within the year that you distribute, right? It's not spread over a year. For that fund, you take sort of a one-time fee for that what you distribute. That's why that is a bit more depressed. We do expect, yeah, when, you know, the volatility in the rates is a bit more stabilized, that wholesale investors and long-term investors may come back to the market. Yeah, we'll just take benefit of every opportunity we see to distribute for investors and for wholesale and are also on the lookout for those.
It's kind of hard to project when they do come in, how the macro environment will play out. With a hybrid model, we think we're well positioned if the fee income growth is there again to participate in it and to compensate at least the loss of fee income that we see now through the interest income that we have on the bank. Maybe a long answer, but, sorry.
Okay.
Yeah, on cash upstream and remittances in Europe, Annemiek explained before already. Yeah, there is a difference between our OCG and remittances. We expect over time a similar growth of OCG and remittances. Just as a reminder, that comes from the fact that our remittance capacity is determined by local GAAP in most markets. Local GAAP does not reflect the value of new business, huh?
That's where that difference comes from. That difference is just if you have a business unit like Europe where we are strongly growing, of course, this new business impact is particularly strong, no? That is where it comes from. On M&A, in our projection, in our OCG target for 2025, what is reflected is organic growth, and that's our base case. Beyond that, you know, we always are open to look at opportunities that might come. As David said, we have quite strict financial and strategic guidelines which determine what we do. I think a good example is how we approach MetLife, huh? It made strategically a lot of sense.
It brought us in Greece to the number one as health insurer, which is a very important, you know, position to have. In Poland, it allowed us to defend our third position. At the same time, it has a double-digit IRR in terms of return. That's, you know, an example of how we look at M&A transactions.
All right. Thank you, Fabian. Maybe we can move over to Nasib.
Thank you, Nasib. I'm from UBS. First question on Insurance International and Non-life. You talk about investment in digital, investment in distribution as well. Is there anything that's funded from the Group or the holding company?
The reason why I ask is because if I add up all the OCG targets for the business units, and compare it to the EUR 1.8 billion, it seems like your holding cost is actually increasing versus where you're running at the moment. Second question on Life. The buyout market, how competitive is it? With higher rates, you'd expect more volumes, but you expect more entrants to come in or a re-entry of previous players that have stopped writing this business? Thanks.
Yeah, maybe I can start with a comment on the investment. In the segment order, we have reflected the EUR -300 million as part of the EUR 1.8 billion target. That is slightly higher than currently the EUR 250 million. That is basically because we expect some higher debt costs.
Maybe, Tjeerd, you can elaborate on investments. Leon, you take the question on the buyouts. Yeah.
Now, it would be great if the group would fund my investments, but unfortunately, I'm held accountable to, of course, invest through the expense line into digitization and have also the benefits in the operating result and the combined ratio. It's included within my own business. There's no projected M&A in the target of the insurance business, huh? We don't project that as part of the plan. It's an organic base case.
Yeah. Same for me. No preferential treatment, yeah.
Yeah, Nasib, your question on the buyout market. Buyouts are by nature, very price competitive. It's indeed a competitive market. Main competitor currently is Athora, their label, Zwitserleven.
The consolidation trend I explained currently at 200 pension funds in the Netherlands, general expectation that it will be lower than 100 pension funds, somewhere between 50 and 100 pension funds remaining. There is consolidation going on. We expect also in the next few years, with the development of higher interest rates, that buyouts will become, and already has become more attractive. It's also depending on inflation rates, huh? Because with high inflation rates, they also expect indexation. There might be a window of opportunity in a couple of years when interest rates are still at current levels and inflation rates come down. That might be a very promising window for buyouts, which may go coincidence with and go along with the planning for the new pension legislation.
Therefore, very, very interested in the buyout market.
All right. Thanks, Leon. Move over to Cor.
Yeah, Cor Kluis, ABN AMRO ODDO BHF. Although, two questions. First of all, about the Non-life, especially the disability insurance market. We've seen some competitors, one competitor already, announcing that there will be a charge in the second half of this year due to the minimum wage, which has been increased by 10% on January 1st. Could you give some indication, might it be a negative charge for Non-life, for disability, or how do you look at it? Second question is on the pension buyouts. Of course, a big market, big opportunity going forward. You have 100% or you had 187% solvency. It's improved now above 200%, of course, at the Life business at Q3.
are there any restrictions, for, yeah, this solvency ratio in accepting, pension buyouts and that also in relation to, yeah, the sustainable or the flat-ish dividend upstreaming that you want to bring to the holding going forward?
All ri ght. Thank you, Cor. maybe, Tjeerd, you can take the D&A question and then afterwards, Leon, on the buyouts.
Yeah, so, we took in the first half, the normal, wage inflation. So that was already reflected in the first half. in Q3, we indeed take the announcement of the Dutch government where they increase the minimum wage with ten percent, huh, which is quite a significant upstep in the that the Dutch government took into the, assumptions for our book. So you will see that in the final result of this year. So we don't disclose today the exact number.
Yeah, we believe still the overall impact is manageable. Important to note, huh, that these types of model and assumption changes are not reflected in OCG, but you will see it in the combined ratio and the operating result. You will see that all in the year-end figures.
Cor, on the buyouts, huh, it is a price-sensitive market. We focus on disciplined pricing. We target for an IRR of high single digit for the buyouts. Basically at our current solvency levels, no constraint for buyouts. If you compare it, huh, the buyouts with our current balance sheet size, it is good to absorb if there are opportunities.
All right. Maybe, Michael? Could we maybe please hand over the microphone to Michael?
Thanks a lot. Thank you very much. Only two brief questions.
The implication was that life new business in Japan dips. I was hoping that you'll say, "We'll get a lot more cash." On disability, I think ASR is structurally more profitable than you. I still don't understand why. I think you have more kind of medical profession, and that seems to have been a drag. I just wondered when will that drag disappear, as it were? Maybe on Japan, if you can indicate, you say the IRR, but just remind us the payback period. Thank you.
All right. Maybe, Tjeerd, you can start on D&A, and then Fabian, take the question on Japan.
Yep. Yeah, we announced a combined ratio of 93%-95%, which is best in class, huh?
With that, we expect the drag to disappear over the coming years. I guess the main difference between a.s.r. and us is on individual disability where indeed we have the Movir portfolio of medical professionals, where we've taken structural interventions, launched a new product, increased prices with 10%. The rest of the D&A business is a lot more comparable.
Okay. On Japan. Payback seven years. IRR, you know, we discussed. In terms of remittances, we gave you an OCG guidance towards EUR 100 million-EUR 125 million. OCG and remittances go always very, very close, no? Because OCG there is basically a reflection of local GAAP.
You know that this figure can vary if there is volatility in sales. A good example is when you look at 2020, where sales dropped and then OCG in 2021 was higher, no? That is what we showed in the past.
All right. Thank you. Maybe move over to Farooq.
Hi there. Thanks very much. Just going back to Japan, you segmented the products slightly differently from what I recall. You obviously have the COLI product. Is COLI basically segmented into protection and then financial solutions? Can you give us an example of what a financial solution is versus protection in that context? You know, why short-term financial solution is going to, you know, be falling as a share.
Secondly, going back to the Netherlands. Obviously, this pension reform comes into full on January 21st, 2027, I think. Can you give us some numbers around the size of opportunity? Obviously, you're saying 15% of the market is corporate pension schemes. Some of that will come through the DC space to you. You've got 40% market share. In the buyout as well, I mean, a lot of those guys will think, well, why do I need to hold this now? Can you give a sense of what proportion of those numbers can come to you in those two forms? Thanks.
Yeah, thanks, Farooq. Maybe, Fabian, you can start with the Japan product examples, and then, Leon, take the question on the pension reform.
Yeah, yeah.
The only reason why we changed the name is because we found COLI is a very technical name, and at the end, SME life insurance better reflects it. That's all what's behind that. Protection products, you know, an example is any type of classical product. It can be a mortality product or it can be a morbidity product, where we think that there's more, you know, room forward. Short-term versus long-term, you know, there were in the past very strong tax incentives for short-term products that have been taken back more and more versus on the long-term side, nothing really has changed. We think that the driver for that is as well that we see that the younger generation is more interested into long-term than into short-term.
That's where we see the drive happening. We find it attractive, and we didn't find it that attractive in the past because there's more room for variable products, which is more the thing we do than traditional profit-sharing products, which are done by mutuals. That is not our space. That's the answer a little bit to Japan.
Yeah, Farooq, on your question on the pension reform, I think good that I can clarify some topics, huh? First and for all, we're talking about a trend which is already going on for many years, huh? There is a trend for consolidation and a trend towards DC. You already see for many years small and mid-sized corporate pension funds liquidating and moving over to insurance companies.
The existing liabilities, they, in some cases, bring over to buyouts. In other cases, they merge or they hand it over to a general pension fund. The trend is already there for many years. We think that the new pension legislation, which is currently being discussed in the Dutch Parliament, it's planned to become into practice during the course of next year. It will be implemented in a five-year period. It's a huge transition connected to the new legislation. Companies and pension funds need some time to once the legislation is final to decide upon their future direction. That will not all happen immediately. It will be somewhere in the middle or maybe somewhat more in the back end of the five-year transition period.
Yeah, there the opportunities will arise if you take the buyouts, huh? A general expectation is that the limit of pension funds which are too small to continue themselves is around EUR 4 billion assets under management. If you take all the pension funds which are below that EUR 4 billion, you have roughly EUR 75 billion, which will probably come to the markets on average, yeah, 20%, 30% will choose for buyouts. That's a rough indication, but it's all depending on, of course, interest rates at the moment and also the inflation expectation. This is, I think, an indication to give for the buyouts and for the DC market. Yeah, the trend is already there, and it might be accelerated with the new pension legislation.
All right. Thanks, Leon. Another question from Andrew? Hadley.
Please go ahead.
Hi, thanks very much. Hadley Cohen, Deutsche Bank. A couple of questions on Non-life, please. I mean, you've talked about best-in-class combined ratios in the sort of 93%-95% range. Just in light of rising bond yields, improving investment returns, and what have you, can you talk about how comfortable you are running at the higher end of that range at the moment to be a bit more competitive on pricing, so as to get overall higher volumes, higher investment returns to overall bottom line, higher earnings picture, in that context? Secondly, can you talk about the scale of the opportunity for further bolt-ons and what have you similar to the Heinenoord transaction? Are there many potential deals out there in that sort of very, like, low triple-digit million sort of range? Is that pretty much it now?
Thanks.
Yeah, thanks, Hadley. Tjeerd, both of you? Yep, no, yeah.
I don't think Leon will be talking about Non-life today. Yeah, we target selective growth. Growing market share in Non-life is, of course, very easy. It's always the trick how you properly price the right risk, the right client, and ensure that in the areas where you want to grow, you're very disciplined, looking at margin, but still be so competitive that the brokers will advise your SME proposition over others, which also has to do with, of course, broker and customer satisfaction. There's a lot of things that come into play. We have a strong distribution position. We have very high broker satisfaction. Yeah, am I comfortable to target more at the range of 95% or 94% or 93% to target selective growth?
I don't think we typically look at that in that way. We really do it per product, per distribution channel. We want to optimize the growth. We do want to moderately grow, but to stay within that range. It's not aggressive growth to really outpace the competition and then, let's say go way over your margins. It's trying to do both at the same time. Moderately growing whilst staying within the target range.
Sorry, just to come back on that. Are you, when you're looking at the pricing, you're only looking at it from an underwriting income perspective? You're not thinking about the overall operating income that you can earn from the premiums coming in?
Yeah, of course, in OCG, there is also the SAA and the investment return and the optimization we can take there. There is a few opportunities that we see there, but similar to what was shared before, those are more smaller items in the SAA that we move there than, let's say, the re-risking that we've done over the past two years. Yeah, on any bolt-ons? Oh, yeah, which goes to the second question. Yeah, the second question on Heinenoord. When we announced the transaction, we did announce that we also want to target further growth.
Those would typically be smaller acquisitions, only at the right price in the right case to further grow the distribution proposition that we have with Heinenoord, Zicht. The 11 transactions that we announced was a total price of below EUR 25 million to give you an indication of what is a smaller transaction, huh? It's more immaterial to the group.
Yeah, maybe with an eye on time, maybe last question from Andrew. Please go ahead.
Great. Thank you. Andrew Baker, Citi. I guess one's to follow up to Hadley's question on the Non-life side. By keeping the combined ratio where it is, you're implicitly saying that you're going to keep all the benefit of the higher investment yield.
Do you think competitors will take the same view, or do you think the market will be willing to give away more on the underwriting margin side because of the high yields? Secondly, on Insurance Europe, can you just remind me the VNB mix between tied agents, bank insurance, and broker? If the products sold are different within those channels and essentially what the VNB margin is by channel and if there's any material differences. Thank you.
Yeah, thanks, Andrew. Maybe, Tjeerd, you can start, and then Fabian on the VNB, please.
Yeah, you know, I'm not responsible, of course, for the competitors, so difficult to answer.
I would from what I've seen in market practice, how we price, how we compete, especially with the large players, we tend to take quite similar views on how we're pricing the investment yield, the combined ratio, how we look disciplinedly at portfolio. The market is hard, so we still see price increases in line with inflation, properly pricing the risk, and of course, taking that benefit. It's also a mature market, huh, where it's not coming from a huge increase from underpenetration in insurance, but it's really, yeah, competing for the same clients, the same business. In that context, I would say those disciplined pricing approaches and how you look to the yield that you get are quite similar across the large players. In Non-life, there are always smaller players that take a different approach, huh?
There, I could see some aggressive players as we have seen in recent years, but those would be more the exception.
Yeah. On the distribution mix, what's for us really favorable is the fact that it's very balanced. You know, if you take a normalized year, I would say it's probably 1/3, 1/3, 1/3. That's the diversification. That means that, for example, in 2021, banks were a little bit stronger. Going forward, we expect them with decreasing mortgage sales to be a little bit less strong. In that sense, the good thing is the diversification, and we're really diversified with 1/3, 1/3, 1/3 overall.
In terms of products, we are in some markets where we have only brokers. There's just one probably in the few markets where we actually broker and agent relationships. Typically, we tend to have the same products.
All right. Thank you, Fabian, Leon, Tjeerd. Also thank you for all your questions. With that, we can move on to the last section of today, which is on IFRS 17. For that purpose, I would like to invite on the stage Annemiek, our CFO, as well as Harm van de Meerendonk. He is our Head of Financial Accounting. The floor is yours.
Thanks, everyone. Welcome again.
We've been thinking a bit on how to structure this session, and our guess was that given that we started at 8:30 A.M. and you already had some tutorials, you may not want a three-hour full tutorial on IFRS 17. If you do, let us know. We have the expert here. For now, we try and keep it a bit condensed and focus on, you know, what is really affecting us and what are the main choices that we have taken. I will give briefly the key messages where we stand now, and I will hand over after that to Harm, who is the Head of our accounting and reporting team and, you know, who has been very active in the CFO Forum, also related to the IFRS 17 topics and many others. Key takeaways is that we do not expect any impact on strategy.
We expect limited financial impact, and we're on track for the implementation. If you look at it from a strategic point of view on the next slide, so far, we don't really see any impact there. I think we're now on slide G3. We don't see any impact there on the strategy. It will not impact the OCG target. It will also not impact solvency nor our capital returns. The financial impact, overall, we would expect equity to become more stable, more aligned with Solvency II, and also with our current adjusted equity, which is adjusted for revaluations. The actual impact on equity is very dependent on interest rates, but if you would look at it from a June 30 level, we don't expect that to be significant. We expect operating result and leverage ratio to improve slightly.
Lastly, we are on track for the implementation and for disclosing the transitional impact and the comparative figures both before we present the 2023 half-year results. With that, I leave you in the capable hands of Harm.
Thank you, Annemiek. Good afternoon by now to all of you. As Annemiek said, I want to take you through, mainly, our approach to the key choices and methodologies in IFRS 17, so our choices on that and the highlights of the impact it has on our financials at the transition. If we look at this first slide, it summarizes the key accounting options. As you probably know, both IFRS 9 and IFRS 17 are quite principle-based regulations that require us to take decisions on various options and assumptions.
In taking these decisions, we have mainly focused on underlying economics, stability of earnings, and also alignment with Solvency II, as much as possible. Firstly, as you can see on the left of this slide, IFRS 9 and IFRS 17 allow changes in financial assumptions, so that's mainly market interest rates and spreads, to be either reflected directly in the profit and loss account or to be deferred in equity, also referred to as other comprehensive income or OCI, which is comparable to what we call currently the revaluation reserves. We will be applying the OCI option for most of our assets and liabilities in the general account. That means that the net impact of interest rate and spread movements will be reflected in equity.
This provides a maximum alignment between the accounting for assets and liabilities under IFRS 9 and IFRS 17, and it ensures that the net volatility is absorbed in OCI where possible, resulting in more stable earnings under IFRS. Secondly, there are three different accounting models in IFRS 17. We will be using each of the three where that best fits to the underlying portfolios. The default model is the General Measurement Model, which we will use for the more traditional life portfolios. The variable fee approach is designed for participating business and investment type of contracts, and we will use that for most of the unit-linked type of products. Finally, there is the simplified premium allocation approach, which is designed for the more simple short-term contracts, and we will use that for mostly the P&C business in the Non-life segment.
Finally, on this slide, let me spend a few words on the three transition approaches that exist in IFRS 17. First, there is the fully retrospective transitioning approach, which requires a full recalculation of the contractual service margin, the CSM, at the transition date as if IFRS 17 would always have been applied. We will use that approach, but it will be limited to mostly some portfolios in the international segment. Secondly, there is a modified retrospective approach, which is still a retrospective transition, but it allows for some simplifications in estimating the cash flows historically and the discount curves. Again, we will use that approach where it's possible, but it will be limited mostly, again, in the international businesses.
Finally, there is the fair value approach, which is not a retrospective approach but allows for a simplification at the transition date when historical data to do retrospective implementation is limited. We will use the fair value approach for a large part of the Life businesses in the Netherlands, which reflects the relatively older in-force portfolios there and the limited historical data. If we move to the next slide, then in addition to some of the key accounting model choices, there are also various assumptions where we need to set our own methodology and parameters under IFRS 17.
Our approach on setting these is to align with Solvency II as much as possible in the methodologies, but for certain, specific parameters, we deviate from Solvency II, for example, because we have either taken a more economic approach, or we have aligned to other practices that exist already within the group, or sometimes IFRS 17 simply requires us to set the parameters differently. The key relevant assumptions are summarized on this slide. First, if we look at the best estimate of expected cash flows, actually, under IFRS 17, those are very similar to Solvency II. We only deviate in a number of areas where that's required by IFRS 17, which mainly relates to requirements on contract boundaries and some of the expense allocations. Secondly, on discounting, for determining the discount curve under IFRS 17, we use the same principle as we do in Solvency II.
That means that we apply a risk-free curve with a last liquid point, an Ultimate Forward Rate, and on top of that, an illiquidity premium. However, here we have set some of the parameters differently from Solvency II. The differences mainly relate to the last liquid point, which where we use 30 years for IFRS 17 compared to the 20 years last liquid point in the Solvency II curve. Another important difference is the illiquidity premium, which in IFRS 17, we base on our own asset portfolios, whereas in Solvency II, we have the volatility adjustment, which is based on a reference portfolio, and not on our own actual assets. Thirdly, on the risk adjustment, also here we apply a methodology which is very similar to Solvency II based on the cost of capital method. Again, there are some important differences in the actual parameters.
First, under IFRS 17, we use a 4% cost of capital rate compared to the 6% that is mandatory in Solvency II because we think that better reflects the economics under the risk adjustment. On top of that, the risk adjustment in IFRS 17 will have higher diversification benefits in it, for example, because we reflect also diversification between entities in the group, the so-called group diversification, which is not allowed in Solvency II. As you can see on the right-hand side of this slide in the graph, the impact of these differences and also some other further differences between the risk adjustment in IFRS 17 and the risk margin in Solvency II means that the resulting IFRS 17 risk adjustment will be significantly lower than the risk margin in the Solvency II balance sheet.
If you take the IFRS 17 risk adjustment and the CSM together, then we expect that to be somewhat higher than what we currently have as risk margin in Solvency II. If we look at the next slide, there we have summarized some of the key impacts of the transition to IFRS 9 and IFRS 17 on our equity. As you may know, the transition date in IFRS to IFRS 9 and IFRS 17 is January 1, 2022 because when we report the 2023 results, we will be restating the 2022 comparative. That's on the left-hand side. You see the impact summarized on January 1, 2022.
Because on that date, the market interest rates were well below the historical rates on our assets and liabilities, you can see in this waterfall that, first, we have a positive impact on equity for the asset side where under IFRS 9, we will be changing the accounting for the loans, so mainly our mortgage loan portfolio, from currently amortized cost to fair value under IFRS 9. In that low interest rate, at the transition date, you see a positive revaluation on the asset side. You also see that then for the insurance liabilities, there is a negative impact on equity, which is the consequence of remeasuring the insurance liabilities to current assumptions, which includes a current market discount rate. Furthermore, here you see that, under IFRS 17, there are no assets for deferred acquisition costs, so the DAC and for VOBA.
In we do have explicit liabilities for the risk adjustment and the CSM. Overall, you see that that adds to a negative impact on equity at the January 1, 2022 transition date. There are two important items to note in this context, which we have illustrated in the middle section of this slide. First of all, our current IFRS equity reflects the revaluation on the asset side of the balance sheet but not for liabilities. That asymmetric accounting approach no longer exists under IFRS 9 and IFRS 17. Actually, the lower equity under IFRS 9 and IFRS 17 is more economical and it's more in line with the adjusted equity excluding the revaluations that we use today. It's more in line with Solvency II.
It also means that the equity under IFRS 9 and IFRS 17 will be much more stable because it reflects the revaluations on both sides of the balance sheet. Secondly, the impact from IFRS 9 and IFRS 17 is very dependent on the level of the market interest rates at the date that we are looking at the impact. As you've seen in our first half-year disclosures for 2022, the revaluations in equity on the asset side have decreased quite significantly given the increasing market interest rates. If you compare that lower equity under the current IFRS at June 30, 2022, the difference with IFRS 9 and IFRS 17 is much less significant because we already have that lower current equity starting point.
You can see those comparisons at the dates and a bit the order of magnitude in the graph on the middle of the slide. Finally, on this slide, on the right-hand side, we show you the impact on the leverage ratio. You can see that the leverage ratio under IFRS 9 and IFRS 17 would have been slightly better than the current leverage ratio on, again, the 1st of January transition date. This mainly reflects the higher equity base, where we include the net revaluations on assets and liabilities in equity where currently the revaluations are excluded. We include the after-tax amount of the CSM into the equity base for the leverage ratio.
If I then move to the final slide, here we have summarized some insights in the way we will determine and present the operating results under IFRS 9 and IFRS 17. You see the revised format of the margin analysis and the operating results in the table on the left side of this slide. It includes what we'll call a profit margin, which is mainly the release of the CSM in the P&L, a technical result, which is mainly the release of the risk adjustment, and the result from the P&C business in the premium allocation approach. These three we aggregate together in the insurance result in the table on the left. In addition, we will show there the investment result, which is then the difference between the investment income and the unwind of the discounting in the liabilities.
The other components of the margin analysis, also including the non-operating items, they will be quite similar to the presentation as we currently have it. For the level of the operating results, we can indicate that we expect it to be marginally higher than the current operating result, which is mainly reflecting an expected higher investment margin for the Dutch Life segment, where because of the transitioning, some of the liabilities will unwind at the lower market rates at the transition date compared to the higher historical rates in the locked-in liabilities. Final comment on this slide.
It's good to note that, also after the implementation of IFRS 9 and IFRS 17, there will still be significant differences between operating results under IFRS and the OCG, where the amount of the OCG and the disclosures around that will not change because of the implementation of IFRS 9 and IFRS 17. To conclude on this session, let me just repeat the key takeaways that Annemiek set out in the beginning. There will be no impact from IFRS 9 and IFRS 17 on the strategy and the targets that we discussed today. We expect the financial impact in the current market environment to be relatively limited. We are well on track for the implementation in 2023 and the disclosure of the impact and the comparatives in advance of our 2023 results. With that, let me pass it back, Ruben, for Q&A. Yes.
Thank you, Harm and Annemiek. Indeed, let's move over to the final Q&A session of today. Yeah, on IFRS 17, all the questions you would like to ask, the opportunity is now. Maybe start with Nasib on the right. Please go ahead.
Thanks. Firstly, on Dutch tax implications, are there any from move to IFRS 17? Secondly, with the Solvency II review, you said that IFRS 17 is moving closer to Solvency II. Does it move even closer to Solvency II post the review just because looking at the assumptions you made on the risk discount rate? Thanks.
Well, on tax, we don't expect it to have any implications, and maybe on alignment with the EIOPA Solvency II review. Yeah.
That's, of course, largely dependent on the actual outcome of the solvency review, which is still ongoing, but especially on the area after risk adjustment, where, as I said, we have taken already a lower cost of capital rate for IFRS 17. If the outcome of the Solvency II review is moving in the same direction, then, yes, IFRS 17 and Solvency II will be even more closer together.
Next question, maybe from Farooq. Please go ahead.
Hi there. I've got a question and a request, please.
The request is, and I'm sure you're probably gonna do this anyway, but if we could have a really detailed reconciliation between the own funds movement and OCG and this profit, that would just make our, you know, first time in 20 years we suddenly have a model that, you know, aligns between capital and, well, hopefully a little bit aligns between capital and earnings. That would be, like, superb for us all. I think it would help the market to accept OCG. I don't think it does currently. Obviously, it doesn't. Second, on the question, can you just describe the philosophy behind your illiquidity premium? You say it's based on your current assets. Clearly, it's gonna be bigger than the VA. How much bigger and what's the principles behind that? Thanks.
Yeah. Farooq, on the detailed reconciliation, noted.
We'll take that definitely on board. Maybe on the theory behind the illiquidity premium, maybe, Harm, you can elaborate on that a bit further.
Yeah. In short, how we set the illiquidity premium is that we take the actual asset portfolio, which is backing the insurance liabilities, and then we take the overall market yield from that portfolio, and then we adjust that for the credit element. We take expected losses and an adjustment for unexpected credit loss. The adjusted spread that is left, after those adjustments, that we use as the spread in the discount rate for the liabilities as well, where, of course, the level of that is dependent on the point in time in the market and the level of the spreads.
It does mean that we have more stability in the revaluation of the assets and the liabilities because we have the maximum alignment between the two.
If I just do a rough calculate, I mean, I don't know the numbers, but that sounds like 4-5 times bigger than the current VA or 3-4 times.
It is currently higher than the VA. I think, again, the exact how much higher is very dependent on the point in time. It is a higher illiquidity premium than we have in Solvency II. Yeah.
All right. Thank you, Farooq. Michael, please wait for the microphone.
Thank you. Two questions. One is insights, and the other one is theoretical. There's something in onerous contracts. You probably don't have them, or maybe you do. I don't know.
What insights did you gain from doing all this quite expensive work, I think, IFRS 17? The other one is the theoretical question. If I look at slide G6, it doesn't really apply to you now, but it would have done in December. If I take the December figure for IFRS is EUR 33 billion, and you show a kind of figure for the IFRS 17, call it a bit above EUR 20 billion, there's a big difference, EUR 10 billion. Now, if I put my long-gone accounting hat on, that would mean that the profits, that's the retained earnings that would be in December in 2000 in the old balance sheet, would effectively now be in CSM, and they'd be recycled.
Now, I'm expressing it in an aggressive way, and it doesn't apply 'cause really, if you use your June figures, they're very similar. Is my thinking correct that if the equity from old IFRS to new IFRS drops and it reappears somewhere in CSM, it means that we're recycling old earnings or we recognize old earnings too quickly or something? I don't know.
Now, maybe first on the onerous contracts. I think the comments you made is correct that if you look at the transition date, that is not really relevant. There will be some, but so in the overall context, the level of onerous contracts is insignificant. Of course, going forward, depending on, there can be two areas where onerous contracts could emerge.
One, of course, is on the existing in-force business where the CSM absorbs the assumption changes, sort of the level of transition, I think, is quite comfortable that it can absorb that. If the impact, the negative impact of assumption changes would at some point be higher than the existing CSM, you could get into the situation of onerous contracts. Similarly for new business, the expectation is that the new business is such that also under IFRS 17, that leads to a positive CSM. Again, that's where, in theory, onerous contracts could emerge. If you look at the situation today, it's not significant.
Yeah, on equity, I mean, maybe as I tried to explain earlier, the key element you need to keep in mind if you compare the current equity at January 1 to IFRS 9 and IFRS 17 is that in the current equity at that date, there was a very significant revaluation amount on the assets, which still exists under IFRS 9 and IFRS 17, but is then largely compensated by revaluation on the liabilities. You basically see that asymmetric positive revaluation at that date being removed. That also explains why in June at June 30, the impact is much smaller because that asymmetry didn't exist on that date because of the different interest rate environment.
Thank you. Maybe question from Andrew. Please go ahead.
Great. Thank you. I guess just quick question on the parameters for discounting.
When you come up with those, is that done completely internally, or is there, I guess, consultation with peers or a CFO Forum? How much deviation do you think there will be from yours versus peers just in how you come up with those? I'm not obviously expecting you to speak for peers there.
Yeah. I think difficult to comment on peers, but I think sort of high level, what you will see is that the approach on setting the rate will be quite similar. In the buildup of the components. I would also expect that in setting the parameters, there will be differences partly depending on different businesses or different portfolios or other reasons. I would say, methodologies are quite aligned, but parameters, there will be differences.
I guess just to follow up. If it's still on. If, let's say, hopefully, that's not the case, but your assumptions or parameters are way off where the market comes out, will there be an opportunity to rebase everything, let's say, in a year's time or once it's locked in, it's locked in?
Yeah. In principle, these methodologies are locked in because that's our starting basis for IFRS 17. I would expect with sort of the magnitude of this change that some of the market practices may emerge in the years to follow. Depending on what is seen there might be some movements in the market. Yeah.
Yeah. Maybe some conversion then. I think it also really depends on the business you have and on the discussions you also have with your auditor as to the choices that you've made if they really reflect your business.
You know, there's such a wide variety also within Life on how long contracts last. That will be taken on board as well. Yeah.
All right. Thanks, Andrew. Maybe we're light on time. Any last questions? One more for you.
I think your peers give an unwind rate on the CSM. They say it unwinds at 8% or 10%. What would be your figure?
Yeah. The unwind of the CSM will, in the end, be quite visible in the actual disclosures because there we will be showing, sort of a runoff pattern of the CSM. I would say sort of big picture, you need to keep in mind that, relatively speaking, a big part of the CSM comes from the businesses in International.
As a sort of a high-level direction, if you take the sort of the average life, those portfolios, that is mainly driving the release of the CSM.
All right. That concludes our final Q&A on IFRS 17. Thank you very much, Harm and Annemiek. I'm sure it won't be the last occasion that we will be discussing IFRS 17 with each other. That will be probably continuing for, well, I guess, definitely next year and probably the years after as well. It has been a good start. Before we have lunch, I would like to invite David to stage to wrap up the day. Thanks, David.
Yep. Thanks, Ruben.
In very short term, after, I think, a very intense morning, we commit to an attractive and growing dividend in line with the guidance that we have given of free cash flow of mid-single-digit. As the CEO's explained, this free cash flow is also based on really underlying business developments. On top of that, a recurring share buyback as a, you know, commitment to our shareholders. Yeah. With that, we are at the end of this morning. I'd like to thank very much everybody on the webcast who made it all the way to the end. Thank you very much for attending. Obviously, everybody here in the room, thank you very much for the engagement, for all the questions, the discussion that we had.
We will be around, of course, today, but also in the coming period to, you know, interact with you and deal with all of your questions today, but also in the coming period. Yeah. Given also the all the sharpness of the questions that you asked, we also concluded that all of you have earned your lunch. Therefore, we will be serving that outside here and look forward to seeing you this afternoon and later on in the rest of the period. Thank you very much.