According to Article 189 relating to the capital requirement for counterparty default risk, Type 2 exposures include receivables from intermediaries.

Having reviewed the official Solvency II texts, along with available guidelines and EIOPA Q&As to date, it is not clear what the exact definition of an intermediary in this context is.

I expect that the definition of an intermediary would include insurance intermediaries, and for example a receivable would be commission clawback from brokers. Another example of a credit exposure which is not as straightforward to define in terms of the type of exposure, is when employers pay premiums on behalf of their employees (the policyholders), for example for short term medical insurance. Would the payment of such premiums by employers on behalf of an employee be more appropriately considered a Policyholder Debtor exposure (Article 189, Paragraph 3 (b))?