Article 262 of the Solvency II Directive states that in the absence of equivalence Member States are required to apply Articles 218 to 235  and Articles 244  to 258 mutatis mutandis, or one of the methods included in the same Article. The Directive states that the general principles and methods set out in Articles 218 to 258 shall apply at the level of the insurance holding company, mixed financial holding company, third country insurance or reinsurance undertaking. We therefore understand that this includes also the requirement for group solvency.
 
The guidelines on the Group Solvency Calculation state that where the parent insurance or reinsurance undertaking, the insurance holding company or the mixed financial holding company is headquartered outside the EEA and is not subject to an equivalent third country supervision, group solvency supervision should be applied only at the level of the ultimate parent undertaking in the European Union.
 
There therefore appears to be a contradiction between the Solvency II Directive and the guidelines on the Group Solvency Calculation and would appreciate if you would clarify.