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European Insurance and Occupational Pensions Authority
 

3577

Q&A

Question ID: 3577

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

Article: 171

Status: Question forwarded to the European Commission

Date of submission: 26 May 2026

Question

In 2026/269 amending 2015/35 the following has been added on the definition of strategic investments: 

"equity investments of a strategic nature shall mean equity investments to which the look-through approach does not apply" 

What exactly does it mean that the look-through approach does not apply. 

1) Does it mean that an asset A in a fund B cannot be strategic? 

2) Does it mean in case fund B cannot be looked-through, that the fund B itself cannot be strategic? 

3) Or is "the look-through approach does not apply" equivalent to "the fund B cannot be looked-through" such that the fund B is allowed to be strategic?