On September 20, 2023, the IIF responded to the IAIS’s consultations on the Insurance Capital Standard (ICS) as a prescribed capital requirement and on related Insurance Core Principles (ICPs) on valuation and capital adequacy. The IIF response notes that the lengthy process of the developing the ICS and the related ICPs has been valuable in terms of extensive dialogue among IAIS supervisors on the fundamental components of a framework for insurance prudential capital and has promoted the understanding of different jurisdictional approaches to insurance prudential capital frameworks. However, it is important to acknowledge that a single global capital standard based on a uniform methodology is aspirational and not necessary to promote sound group supervision. The IIF believes that the ICPs are the appropriate vehicle for adopting the needed flexible, principles-based approach to an insurance prudential capital framework.