First of all, it should be pointed out that a clear differentiation has to be made between the calculation of SCR-figures and the reporting in the asset templates with regards to investment funds. 

SCR-figures shall be reported in template S.26.01 (old SCR-B3A) during the preparatory phase and calculation have to be performed according to the Technical Specifications. Look-through of investment funds is required and the rules to do it are clarified in the Technical specifications to be published on the 30 April. Despite this requirement for the calculation of the SCR, for submission of information purposes the template on look-through (S.06.03 - old AS-D4) which gives an overview of composition of the investment funds with regard to geographical area, currency and asset category will not be required during the preparatory phase.

As simplifications in the calculation of the SCR for market risk are allowed, the NCAs have to decide whether and to what extent undertakings may make use of it during the preparatory phase. As soon as Solvency II enters into force, only a closed list of simplifications will be available when calculation the SCR. Where a scenario-based calculation requires recalculation of Technical provisions, undertakings may use the same methods (or where applicable simplifications) that they used for the valuation. 

As far as the proportionality principle is concerned, all undertakings have to adhere to the technical specifications and the general proportionality principle applies. Where undertakings apply one of the simplifications available under Solvency II for the calculation of the SCR, a proportionality assessment will be required.