1) Commission Implementing Regulation (EU) 2015/2015 laying down implementing technical standards on the procedures for assessing external credit assessments was adopted based on the draft ITS submitted by EIOPA in accordance with Article 44 (4)(a) of the Solvency II Directive. Considering the desirable flexibility in application of the proportionality principle and the extent of the minimum requirements already stated in the referred ITS (e.g. requirements on the tasks of the risk management function, the information used or the documentation of those additional assessments) at this stage no additional guidance is planned.

2) ITS 2015/2015 provides that the manner in which the additional assessments are carried out (including the assumptions on which they are based) shall be included by insurance and reinsurance undertakings in their risk management policy. Consequently undertakings are expected to decide for themselves what approach to additional assessments is appropriate considering their risk profile, subject to supervisory challenge. The appropriateness of the scope, frequency and methodology applied by the undertaking can be subject to assessment made by the supervisor considering the characteristics of that undertaking and its portfolio. The term "additional assessments" does not necessarily require the undertaking to duplicate the assessment performed by the rating agency; undertakings can also challenge that assessment based on information that can be observed in the market. While insurance and reinsurance undertakings should aim at having their own credit assessment on all their exposures, in view of the proportionality principle and also according to Article 4(5) of Commission Delegated Regulation (EU) 2015/35 supplementing Solvency II Directive, undertakings should only be required to have own credit assessments on their larger or more complex exposures.

 3) Article 44(4a) states that those additional assessments only need to be performed "wherever practicably possible". It should be noted that all undertakings are however required to have internal procedures in place to assess the appropriateness of the external credit assessment taking into account the nature, scale and complexity of the risks inherent in the business. "Wherever practicably possible" does not imply that there are undertakings that do not have to perform any kind of additional assessments. Possible issues to be considered in this regard are the nature, scale and complexity of the undertaking, the asset class of instruments concerned and the materiality of the exposure.