Question ID: 528
Regulation Reference: Guidelines on reporting for financial stability purposes
Article: 35
Template: S.25.04
Status: Final
Date of submission: 05 Feb 2016
Question
Having been contacted by one of the German insurers, we realized the following issue:
In template S.25.04.13 (for groups) the item name for C0010/R0020 requires the use of the standard formula, whereas S.25.04.11 (for solos) does not.
The respective group prefers to also make use of their (partial) internal model data. Therefore:
1) Do the instructions for solos and groups need to be aligned - to prevent that groups report standard formula and solos report SF or (P)IM data?
2) If an alignment of instructions for solos and groups is desired, we propose to allow for the use of SF or (P)IM for solos as well for groups, as this would lower the burden for the insurers and provide us with data which are closer the data used in prudential supervision (where (P)IM data is predominant, if an internal model has been applied for successfully).
EIOPA answer
Indeed, the words “standard formula” may be slightly misleading in this cell.
In line with the LOG-file, the reporting cell should contain the minimum of the consolidated group Solvency Capital Requirement as defined in Article 230 of the Solvency II directive:
“The consolidated group Solvency Capital Requirement shall have as a minimum the sum of the following:
a) the Minimum Capital Requirement as referred to in Article 129 of the participating insurance or reinsurance undertaking;
b) the proportional share of the Minimum Capital Requirement of the related insurance and reinsurance undertakings.”
In this regard, the floor and the cap of the Minimum Capital Requirement of the participating insurance or reinsurance undertaking defined in Article 129, Section 3 is based on the undertaking’s Solvency Capital Requirement, calculated in accordance with Chapter VI, Section 4, Subsections 2 (standard formula) or 3 (full and partial internal models).