Article 330 of Commission Delegated Regulation (EU) 2015/35 (DR) and Guidelines 12, 14 and 15 of EIOPA Guidelines on group solvency describe the calculation of an insurance or reinsurance subsidiary's contribution to the group solvency capital requirement.

Could you clarify whether contributions of insurance holding companies are included in the calculation of the contribution of a subsidiary, both in the numerator and the denominator?

The EIOPA Guidelines on group solvency specify in Technical Annex 1 the calculation of the contribution of the insurance and reinsurance subsidiary to the group SCR.

In Technical Annex 1, the numerator of the contribution SCR_diversified is the SCR calculated in accordance with Article 336(a) DR. When method 1 is used, Article 335(1)(a) and (c) DR requires a full or proportional (line by line) consolidation of any related IHC or MFHC that is a subsidiary of the group. This means that IHC and MFHC, both at the top and at intermediate level, contribute to the consolidated group SCR in accordance with Article 336(a) DR. Therefore, IHCs and MFHCs are included in the numerator SCR_diversified.

The denominator of the contribution ∑SCR_solo described in Technical Annex 1 is the sum of the SCRs at individual entity level of the participating undertaking and each related insurance or reinsurance undertaking and third-country insurance and reinsurance undertaking included in the calculation of the SCR_diversified. IHCs and MFHCs are not included in this sum.