On the one hand, article 3 of COMMISSION IMPLEMENTING REGULATION (EU) 2015/2450 of 2 December 2015 (concerning the Solvency II templates) indicates at its article 3(3) that “When expressing the value of any asset or liability denominated in a currency other than the reporting currency, the value shall be converted into the reporting currency as if the conversion had taken place at the closing rate on the last day for which the appropriate rate is available in the reporting period to which the asset or liability relates.”

On the other hand, article 299 of the Solvency II directive indicates, at article 299, that “Where this Directive makes reference to the euro, the exchange value in national currencies to be used with effect from 31 December of each year shall be the value which applies on the last day of the preceding October for which exchange values for the euro are available in all Community currencies.”

Therefore, hard monetary references present within the Solvency II directive (as in article 129 for instance) may use a different currency exchange rate reference date as other elements reported in the templates for the submission of information to the supervisory authorities
Different currency exchange rate reference dates can be used for the same currency within the same risk submodule. This is not deemed as being a discrepancy having the potential to have any significant impact on the prudential situation of insurance or reinsurance undertakings. Therefore, different exchange rates can indeed be used.