Question ID: 3561
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: 165
Status: Rejected
Date of submission: 04 May 2026
Question
I have a few questions regarding the interest rate risk sub-module. 1. In case of money market instruments where the company has borrowed from an institution, should it be stressed under assets with negative market value or should it be stressed under liabilities? My client has considered it under assets as a negative market value for these assets and consequently it has a negative duration. The client has taken the risk free rates and shock factors for all assets with duration less than 1 to be equal to the rates corresponding to maturity time period 1.So, if an asset has duration of -22 (lets say it has maturity of 24), the risk free rate and shock should be taken corresponding to maturity period ~24 rather than maturity period 1.Can you please confirm if my understanding is correct? 2.My client is using a simplified approach using modified duration to calculate the effect of changes to the risk-free rate structure on the market values of the financial assets rather than a full calculation, which involves discounting all of the future cashflows associated with the financial asset. Is a simplified approach acceptable for the purpose of determining the risk charge because it is not mentioned anywhere in the delegated acts?
EIOPA answer
The question has been rejected because the issue it deals with is already explained or addressed in Q&A 1230.
We understand that both sub-questions concern a simplified calculation of the interest rate risk capital requirement.
As clarified by Q&A 1230, simplified calculations of the interest rate risk can only be performed in accordance with Article 103 of Commission Delegated Regulation (EU) 2015/35 (DR), provided that the captive insurance or reinsurance undertakings complies with Articles 88 and 89 DR. In this case, the calculation of the duration is specified in Article 103(4) DR.