Skip to main content
Logo
European Insurance and Occupational Pensions Authority
 

3333

Q&A

Question ID: 3333

Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision

Topic: Reporting Templates

Template: S.06.02, S.25.01

Status: Final

Date of submission: 24 Apr 2025

Question

In EU Regulation 2015/35, specifically in Article 180, paragraphs 13 and 16, beneficial capital treatment is granted to Qualified Infrastructure Investment and Qualified Infrastructure Corporate Investment. Notably, this regulation permits unrated assets to maintain a minimum CQS of 3, provided they are classified under Articles 164a and 164b. Our inquiry pertains specifically to unrated assets that meet the criteria outlined in Article 164a, Article 164b, Article 180, paragraphs 12(a) and 12(b), as well as Article 180, paragraphs 15(a) and 15(b). According to EIOPA Q&A 650, the CQS should accurately reflect the calibration used in the Solvency II Standard Formula (SF SCR) calculation. Given that regulatory requirements allow for beneficial treatment, Option 1 suggests that a CQS of 3 should be reported as this is the CQS feeds into SF SCR calculation. However, there is an opposing viewpoint that, since the asset is unrated, the capital beneficial treatment based on CQS 3 should be inferred rather than explicitly reported, leading to a Option 2 to report a CQS of 9, despite the SF SCR is calculated based on CQS 3. What is the regulator's expectation when a standard formula insurance firm submits CQS information for the unrated asset in question? Should the CQS be reported as CQS = 3 (Option 1) or CQS = 9 (Option 2)?

EIOPA answer

In the case described in S.06.02, C0340 shall be reported Option 2 - CQS 9 for such investments that qualify as infrastructure but do not have an external rating.