This webpage sets out the Regulatory Board鈥檚 proposals to introduce a revised APS X2, together with revised non-mandatory guidance, and the rationale for the proposed changes.
Deadline for responses: 15 September 2025
I invite you to participate in this consultation by the IFoA鈥檚 Regulatory Board (the Board) seeking your feedback on:
APS X2 sets out the duties and responsibilities of all IFoA members in relation to the application of work review, which may include independent peer review, to promote the quality of actuarial work.
Following a review of APS X2, including a member survey in 2024, the Board agreed that there were no significant drivers for a substantive revision of APS X2. However, there are proposed changes to reflect the new IFoA Disciplinary Scheme and other minor amendments
In addition, we are seeking the views of members and organisations on the existing guidance and case studies to help inform our review of those documents.
This webpage sets out the Board鈥檚 proposals and rationale for the changes to APS X2.
The Board welcomes comments from individual members, the organisations for which they work, other regulators and anyone else with an interest in the standards which the IFoA sets for its members.
We thank you for taking the time to consider these proposals and look forward to receiving your comments.
Neil Buckley, Regulatory Board Chair
APS X2 sets out the IFoA鈥檚 requirements for work review and independent peer review. It came into force in 2015 and applies to all actuarial work conducted by IFoA members in all practices and jurisdictions.
For each piece of actuarial work for which they are responsible, APS X2 requires members to consider whether work review or independent peer review is required and outlines what should be considered in making such determinations. APS X2 is published along with supporting materials, such as non-mandatory guidance and case studies, to help members in making these determinations.
The requirements are designed to be substantially consistent with the relevant provisions in the model standards of the International Actuarial Association (IAA) and the Actuarial Association of Europe (AAE).
In May 2024, the Board approved the use of a survey to review APS X2 and its non-mandatory guidance. On 19 August 2024, the survey launched and aimed to help understand how confident members were in determining whether a piece of actuarial work requires review, whether the support material for understanding and applying APS X2 is helpful, and whether additional supporting materials would be useful. The survey closed for feedback on 16 October 2024.
We are proposing minor amendments to APS X2, in particular that references to the IFoA Disciplinary Scheme are brought up to date. No substantive changes to the underlying content of APS X2 are proposed.
Download tracked proposed revisions to APS X2 (version 1.1) (PDF, 210 KB)
Thank you to those members who provided feedback on the existing guidance through the 2024 member survey. While we are not publishing draft revised guidance with this consultation, we are actively seeking further views from members, and the organisations for which they work, on the existing guidance and case studies.
The aim of the consultation is to ensure APS X2 and its accompanying guidance remain up to date and reflect the needs of members.
The amendments to APS X2 follow the introduction of the new IFoA Disciplinary Scheme and there is no intention to change the obligations of members.
The proposed changes are considered by the IFoA鈥檚 Regulatory Board to be proportionate, consistent, transparent, and targeted, and have been developed in a way that is principles-based, and outcomes focused.
IFoA standards and guidance are designed to help the IFoA meet its Royal Charter objective of protecting the public interest.
APS X2, and its associated guidance, are principles-based and high-level in nature. However, if there are specific areas or scenarios where you feel you would benefit from additional guidance or case studies, please let us know by responding to the consultation.
In addition to standards and guidance published by the IFoA, you can access additional support through our Professional Regulatory Support Helpdesk. The Helpdesk is available to all IFoA members across the globe and provides a confidential space to ask questions on the application of professional and technical standards. By submitting a query to the Helpdesk, members benefit from a tailored response to their query incorporating the views of our experienced panel members.
You can respond on behalf of an organisation or provide a personal response.
Download questionnaire for organisations (DOCX, 130 KB)
Or scan the QR code:
The deadline for responses is Monday 15 September 2025.
Once the consultation has closed, the IFoA will reflect upon the feedback and publish more specific details of any changes. There will also be a period allowed before the changes come into effect so that those affected can take steps to ensure they are able to comply with the new requirements