Question ID: 3650
Regulation Reference: (EU) No 2009/138 - Solvency II Directive (Insurance and Reinsurance)
Topic: Technical Provisions (TPs)
Status: Question forwarded to the European Commission
Date of submission: 17 Sep 2026
Question
For the calculation of consolidated technical provisions at group level under method 1, how should intra-group transactions be reflected in the calculation of the volatility adjustment (VA), in particular where such transactions affect the assets and liabilities considered for the calculation of the credit spread sensitivity ratio (CSSR)?
More specifically, where an undertaking holds an intra-group loan that is included in its portfolio of bonds, loans and securitisations used for the CSSR calculation, should this intra-group loan be eliminated or replaced for the calculation of the consolidated best estimate, with the consequence that the CSSR and the resulting VA would need to be recalculated at group level?
The same question arises with respect to group-internal reinsurance, especially from the perspective of the group-internal reinsurer.