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European Insurance and Occupational Pensions Authority
 

3546

Q&A

Question ID: 3546

Regulation Reference: (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII), (EU) No 2009/138 - Solvency II Directive (Insurance and Reinsurance)

Topic: Narrative Reporting

Article: Article 297(2)(b)); Article 51(1b)(d)(iii)

Status: Question forwarded to the European Commission

Date of submission: 01 Apr 2026

Question

We have recently been made aware that the Commission has – through workshops – provided useful help in the form of answers to questions received from Member States regarding the transposition of Directive (EU) 2025/2. We are in particular interested in the answer provided with regard to future disclosures in the solvency and financial condition report in respect of risk sensitivities. In this answer, the Commission appears to link Article 51(1b)(d)(iii) directly with Article 297(2), stating that, concerning risk sensitivity, Article 297(2) of the revised Delegated Regulation specifies the information that must be disclosed in the SFCR (“a description of the methods used, the assumptions made and the outcome of the sensitivity analysis for material risks and events”). Against that background, we would be grateful for EIOPA’s (or the Commission’s) clarification on the following points: 1. If – as the above clarification seems to suggest - Article 297(2)(b) is to be read as implementing the specific requirement in Article 51(1b)(d)(iii) (i.e. limited to undertakings/groups relevant for the stability of the financial system), does any explicit Union level risk sensitivity disclosure requirement remain in the SFCR for undertakings/groups that are not relevant for financial stability? Or should Article 297(2)(b) of the Delegated Regulation be interpreted as laying down a general SFCR disclosure requirement on risk sensitivities that applies to all solo undertakings (and, mutatis mutandis, to all groups preparing an SFCR), regardless of whether such undertakings are “relevant for the stability of the financial systems in the Union” within the meaning of Article 51(1b)(d)(iii)? 2. If Article 297(2)(b) applies generally to all undertakings/groups - then what is the additional or specific disclosure that is required only from undertakings/groups that are relevant for the stability of the financial system under Article 51(1b)(d)(iii)? In other words, how should the level 1 provision that expressly refers only to such undertakings be reconciled with the apparently very general level 2 wording in Article 297(2)(b)? Any guidance from EIOPA (or the Commission) on the intended scope of the risk sensitivity disclosure requirements in the amended SFCR framework for both solo undertakings and groups would be highly appreciated.

Background of the question

In the amended Solvency II Directive, Article 51(1b)(d)(iii) provides that the part of the solvency and financial condition report (SFCR) targeted at market professionals shall contain, “for insurance and reinsurance undertakings relevant for the stability of the financial systems in the Union, information on risk sensitivity.” Recital 39 in particular refers to EIOPA’s Guidelines on reporting for financial stability purposes as already laying down criteria to identify such undertakings. Similar wording applies at group level. At the same time, the revised Delegated Regulation (EU) 2026/269, in Article 297(2)(b), provides that the SFCR shall contain, with regard to the Solvency Capital Requirement and the Minimum Capital Requirement, “with regard to risk sensitivity, a description of the methods used, the assumptions made and the outcome of the sensitivity analysis for material risks and events.” This provision is drafted as a general requirement and does not, in its wording, seem to limit its scope to undertakings (or groups) that are relevant for the stability of the financial system.