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European Insurance and Occupational Pensions Authority
 

3545

Q&A

Question ID: 3545

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: 120

Status: Rejected

Date of submission: 27 Mar 2026

Question

Question: Would it be possible for an insurance or reinsurance undertaking to apply the decided changes to the calculation of the Nat Cat SCR in the standard formula on the 31/12/2026 instead of 30/1/2027?

Background of the question

The vast majority of annual reinsurance contracts that cover Nat Cat (Natural Catastrophes) risks are renewed on the 1st of January without generally the possibility to change the reinsurance cover during the year. So the insurance undertaking will have a reinsurance cover that is not optimal according to its strategic objectives at some parts of the year (be it January 2027 or from February 2027). This is not due to a change in the view of risk, but just to the choice of the date of application of a long-discussed topic. Furthermore, the change of the SCR Nat Cat scenarios at 30/1/2027 without the corresponding adaptation of the reinsurance coverage could lead to a material change of the SCR and hence a burdensome process for insurers that do not correspond to any change in the view of risks or any occurred event. Allowing an insurer to apply the changes to the calculation of the NAT CAT SCR at end 2026 would make the life of insurers much easier with a better choice of the reinsurance cover to buy for these risks. 

EIOPA answer

This question has been rejected because the answer is clear from the legal text. It is not possible to anticipate the changes to the calculation of the natural catastrophe risk sub-module of the standard formula.