Question ID: 2579
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: Annex XVII.B(2)(c) of Delegated Regulation (EU) 2015/35; Article 218(1)(a)
Status: Final
Date of submission: 13 Feb 2023
Question
We kindly request your clarification on the following point of Delegated Regulation (EU) 2015/35 in relation to the use of undertaking-specific parameters:
Article 218, paragraph 1. letter a) subparagraph ii) standard deviation of gross premium risk in non-life insurance, does it refer exclusively to gross of proportional reinsurance, that is, net of non-proportional?
Background of the question
At the end of section 1 of article 218, it is specified that "Insurance and reinsurance undertakings will not simultaneously substitute the general parameters referred to in letter a), paragraphs ii) and iii), of the same segment"
With this, we understand that the standard deviation of the gross premium risk, item ii), and the non-proportional adjustment factor, item iii) cannot be substituted at the same time, but as item iii) refers exclusively to non-proportional reinsurance, it arises the doubt as to whether subparagraph ii) refers to the gross premium risk of proportional reinsurance and net of non-proportional or gross of proportional and non-proportional reinsurance.
EIOPA answer
According to Annex XVII.B(2)(c) of Delegated Regulation (EU) 2015/35, the premiums are gross of proportional and non-proportional reinsurance.