Question ID: 2406
Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Topic: Solvency Capital Requirement (SCR)
Article: 188(1)
Status: Final
Date of submission: 20 Mar 2022
Question
According to Article 188 when calculating SCR for currency risk "Immovable property shall be assumed to be sensitive to the currency of the country in which it is located." In Polish market real estate assets are usually in EUR while local currency is PLN. The currency risk can be hedged by FX contracts thus economically company would be not exposed to that risk. What exactly Article 188 states for? Should SCR for currency risk be calculated assuming that a real estate asset is in PLN instead of EUR? How to treat FX contract which hedge that currency risk within SCR calculation? Changing currency of real estate asset to PLN while leaving FX contract as it is could lead to SCR for currency risk although the risk in reality is hedged.
EIOPA answer
As per Article 188(1) the SCR for currency risk should be calculated assuming that a real estate asset located in Poland is sensitive to PLN.
Where an undertaking holds FX hedges between EUR and PLN these need to be stressed in the currency risk sub-module.