The underlying assumptions for the expense risk submodule are described in EIOPA’s document EIOPA-14-322 “The underlying assumptions in the standard formula for the Solvency Capital Requirement calculation” as follows: Undertakings are exposed to the risk of the change of expenses arising predominantly from: staff costs, cost of commissions to sales intermediaries (on the basis of the contractual terms of the arrangements), cost of IT infrastructure, cost of land and buildings occupied. And further in the same document: Expense risk arises from the variation in the expenses incurred in servicing insurance or reinsurance contracts. It is likely to be applicable for all insurance obligations. That can be read as the following: cost of commissions on the basis of the contractual terms of the arrangements which are not varying in time according to the underlying contractual agreements with sales intermediaries should not be stressed during the calculation of SCR expense risk. That would be a contradiction to EIOPA’s Q&A 1788 according to which all expenses taken into account in the valuation of the best estimate should be included in life expense risk. Our question is: Should or should not commissions on the basis of the contractual terms of the arrangements, which are not a subject to the variation risk, be stressed in accordance to article 140 of Solvency II Delegated act?