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European Insurance and Occupational Pensions Authority

2244

Q&A

Question ID: 2244

Regulation Reference: Guidelines on group solvency

Topic: Group Own funds

Article: 233(1)

Status: Final

Date of submission: 28 Jan 2021

Question

Tier-limits at Group level (Method 2)

Background of the question

Can you please confirm, that when calculating the Tier 2-limit at Group level, when the SCR is calculated by method 2, you may "pass on" unused capacity from a daughter to the Group SCR. That is: Assume a group (Mother and Daugther) with combined SCR = 1000 (method 2). Mother-undertaking solo-SCR (without daugther) = 200 Mother-undertaking OF: Tier 1 =200 Daughter-undertaking solo-SCR = 800 Daughter-undertaking OF: Tier 1 = 500 and Tier-2 = 300 Then the max Tier 2-capacity available at Group-level (OF) will be: Max Tier-2= 50% of 1000 = 500 and NOT Eligble Tier-2 (daughter) + Tier 2-capacity (mother) = 300 + 50% of 200 = 400 thank you

EIOPA answer

Method 2 is an alternative method and the group eligible own funds (EOF) are calculated as a simple summation of all solo EOF of the related undertakings after the following adjustments: (i) deduction of the excess of non-available OF at group level, in comparison to the solo SCR; (ii) the elimination of any relevant IGTs.
Where certain own funds eligible for the SCR of a related undertaking cannot effectively be made available to cover the SCR of the participating undertaking for which the group solvency is calculated, those own funds may be included in the calculation only in so far as they are eligible for covering the SCR of the related undertaking (Article 222 of the SII Directive, and Article 330 of the Delegated Regulation). Furthermore, the eligible own funds of the related third country insurance or reinsurance undertaking should be assessed for their availability to cover the group SCR by the group supervisor.
There is no retreatment of solo tiering at group level for entities encompassed by method 2. The tiering limits are taken as those were applied to the solo undertakings. However, consideration should be made to whether one of the related undertakings belong to a third country (equivalent or provisionally equivalent). Please refer to the EIOPA Opinion on the group solvency calculation in the context of equivalence (EIOPA BoS 15/201).