We have identified an issue that has appeared after brexit and lack of update of ECAI list in the ITS 2015/2450 in 2020. After brexit some of ECAI that were used by undertakings should not be chosen from list, but new that approved their rating and are on ESMA’s list were not added to the list (e.g. Fitch Ratings Ireland Limited (kod LEI: 213800BTXUQP1JZRO283). In our opinion in case of new ECAI on ESMA’s list that is a part of Fitch group or Moody’s group undertakings should report “Fitch” or “Moody’s” not "Other nominated ECAI".
Background of the questionAccording to Q&A 1404 (https://www.eiopa.europa.eu/content/1404_en?source=search; 03 Apr 2018) the option "Other nominated ECAI" is to be used only for situations where an CRA was introduced in ESMA's list and for as long as the closed list is not updated. Sentence “(to be used where the split below is not available)” after option “Fitch” and “Moody’s” was deleted by ITS 2015/2450 amendment in 2019.
EIOPA agrees that in case of new ECAI on ESMA’s list that is a part of Fitch group or Moody’s group undertakings should report “Fitch” or “Moody’s” not "Other nominated ECAI.