Question regarding adjustment for pegged currencies in currency risk sub-module. According to the article 188 (5) of the Delegated act 2015/35 we would like to know why Bosnian Convertible Mark (BAM) is not recognized as pegged to euro and with respect to that do not have the lower adjustment in currency risk sub-module, although they have in their article 32 of the Law of the Central Bank of Bosnia and Herzegovina written: “the official exchange rate for the currency of Bosnia and Herzegovina shall be one Convertible Marka per Deutsche Mark”, and so they fulfill the criteria written in the paragraph 5 (b) of article 188 (Delegated act 2015/35). Additionally we would like to know more about the recognition process for currencies pegged to euro and how often do you perform this process, as in the near future also the Croatian Kuna (HKN) could be recognized as pegged to euro, if Croatia joins the ERM II.

According to Article 111(1) (p) of Directive 2009/138/EC (Solvency II) the European Commission shall adopt implementing measures for the detailed criteria for the adjustments for currencies pegged to the euro.
The current version of these implementing measures can be found here: https://eur-lex.europa.eu/eli/reg_impl/2015/2017/oj
EIOPA provided advice on this to the European Commission: https://register.eiopa.europa.eu/Publications/Reports/EIOPA-BoS-15-121_Final_report_ITS_Adjust_pegged_currencies.pdf
 
The analysis underlying the advice can be found in the following document: https://register.eiopa.europa.eu/Publications/Consultations/EIOPA_EIOPA-CP-14-059_ITS_Adjust_pegged_curr.pdf
Please be aware that provided the Bosnian Convertible Mark meets the requirements of Article 188(5)(b) of the Commission Delegated Regulation (EU) 2015/35 it has also to meet the condition in (a) of this paragraph. The last mentioned document outlines the analyisis EIOPA performed in this respect for its advice.