All our business is either Unit Linked or Unitised With Profits (internally reinsured). For both the business, investment risk either lies with the policyholder or is reinsured and therefore Technical Provision for these business does/should not have any impact on the Standard Formula Operational risk capital requirement. The R0110 (TPs for Unit Linked Business) captures the TP only for Unit Linked business and not Unitised With Profit business which is captured in R0100. This is because the cells are directly linked to S.12. Therefore, this results in positive Capital requirement for operational risk based on technical provisions for our business which should not be the case. A similar case is with the R0210 where it should capture the full New business premium and not just for Unit Linked.

We believe that the Unit Linked category R0110 should capture the total Technical Provisions (i.e UL and UWP) to validate zero Operational Risk capital requirement from Technical Provisions in R0130. Same with R0210 Gross premium for Unit Linked Premium to result in zero Operational risk capital requirement based on earned premiums.

We are facing issues with validation as it is not allowing us to upload the correct operational risk capital.

Could you please advise how to update and upload the template because the current structure is certainly not working for us?