Question ID: 3470
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)
Article: 118
Status: Rejected
Date of submission: 28 Nov 2025
Question
Question 2433 clarifies that the non-life lapse risk shall be based on "policies for which discontinuance would result in an increase of technical provisions" (directive text) "before the payments caused by the discontinuance are made" (Q&A clarification). With this clarification, discontinuance of any profitable contract will result in a (short term) increase in the provisions and are thus within scope of the Lapse risk calculation. The directive further states that “the undertaking shall base the calculation on the type of discontinuance which most negatively affects the basic own funds of the undertaking on a per policy basis”. Can you confirm that this means that the calculation shall be based on the policies with the highest absolute expected profit (that can be cancelled) – representing 40% of the number of policies?
EIOPA answer
This question has been rejected because the issue it deals with is already explained in the previous Q&A 2290.