Question ID: 3575
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: 4
Status: Rejected
Date of submission: 22 May 2026
Question
We use the services of a rating agention that is registered in ECAI. That agention doesn't issue an offical rating for a bank in which we have some deposits, but provides a tool that uses the same financial data that is used for ratings calculation to get an unofficial rating. This unofficial rating is very consistent with official ratings for the banks that are rated by that agention (over 99%). Can we use this unofficial rating in SCR calculation in the same way as official ratings?
EIOPA answer
This question has been rejected because the issue it deals with is already explained in Article 4(1) of Commission Delegated Regulation (EU) 2015/35, read together with Articles 2(1) and 3(1)(a) of Regulation (EC) No 1060/2009.
Articles 2(1) and 3(1)(a) of Regulation (EC) No 1060/2009 define a credit rating as an opinion regarding the creditworthiness of an entity, issued by a credit rating agency and published or distributed by subscription in accordance with the applicable rules. Hence, an output generated by a scoring tool does not constitute a credit rating within the meaning of Articles 2(1) and 3(1)(a) of Regulation (EC) No 1060/2009 and cannot be used as such for SCR calculation purposes under Article 4(1) of Regulation (EU) 2015/35.
This is also consistent with EIOPA Q&A 2288, which clarified that private credit ratings referred to in Article 2(2)(a) of Regulation (EC) No 1060/2009 cannot be used for the calculation of the SCR under the standard formula.