Article 209(3) states that for risk mitigation techniques shorter than 12 months, "the risk-mitigation technique shall be fully taken into account" when the insurer intends to replace the hedge with a "similar arrangement". However, EIOPA Q&A 2064 suggests that if that 3-month hedge is rolled with a strike that is " fixed with regard to the spot price" (which presumably means the strike on the roll date is a fixed percentage of the spot price - eg 80% of spot, on each roll), then this hedge is not fully taken into account. If this is true, what are examples of "similar arrangements" referred to in article 209(3) where the risk mitigation strategy for a 3-month rolling equity put option would be fully taken into account?

This question has been rejected because the question falls outside of the scope of the Q&A process, which does not entail the possibility for EIOPA to suggest examples of investment strategies that would be compliant with the regulation. While Q&A 2064 clarified that a particular strategy cannot be fully recognised as a risk-mitigation technique, alternative strategies may be fully recognised, but they should be assessed on a case-by-case basis, subject to compliance with the requirements on risk-mitigation techniques set out in Title I, Chapter V, Section 10 of Commission Delegated Regulation (EU) 2015/35.