Question ID: 3325
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), Internal Models (IMs)
Article: 171(a)
Status: Final
Date of submission: 16 Apr 2025
Question
For the assessment of the Solvency Capital Requirement (SCR) using a partial internal model, is it permissible for a solo insurance entity and for an insurance group to model underwriting risks through the partial internal model, while simultaneously applying the standard formula equity shock of 22% for long-term equity investments, provided that all the conditions set out in Article 171a of the Commission Delegated Regulation (EU) 2015/35 of 10 October 2014 are fulfilled?
EIOPA answer
Yes, provided that all the conditions set out in Article 171a of the Commission Delegated Regulation (EU) 2015/35 of 10 October 2014 are fulfilled. It needs to be clarified that to apply the shock of 22% for long-term equity investments there must be no partial internal model covering equity risk or if there is, it has sufficiently been substantiated that part of the equity portfolio considered as long term equity investments cannot be included in the scope of the internal model. Also, the requirement to separately manage the insurance obligations may have an impact on the partial internal model for insurance risk e.g. in the diversification between the assigned portfolio and the rest of the business.