Question ID: 654
Regulation Reference: (EU) No 2015/2452 - procedures, formats and templates of the solvency and financial condition report
Article: 35, 336
Template: S.23.01
Status: Final
Date of submission: 20 Apr 2016
Question
Please confirm that the balance shown in QRT 25.02.04 ‘Solvency capital requirement for undertakings under consolidated method’ (R0220/C0100) is expected to include balances relating to Capital requirement for other financial sectors (Non-insurance capital requirements) (OFS).
However the Capital requirement for OFS will not be presented in the cells above (e. g. Total Undiversified Components R0110/C0100).
The EIOPA Validation Control BV344 requires that balances in the Own Funds QRT 23.01 (R0590/C0010) and SCR QRT 25.02 (R0220/C0100) are expected to be the same. Also the log file definition for QRT s23.02 (R0590/C0010) ‘Consolidated Group SCR’ states that the balance includes ‘Consolidated Group SCR calculated for the consolidated data in accordance with Article 336 (letter a-b-c-d) of Delegated Regulation (EU) 2015/35’.
Therefore to align with the definitions and validations above it is necessary for s25.02.04 ‘Solvency capital requirement for undertakings under consolidated method’ (R0220/C0100) to include OFS balances.
EIOPA answer
We confirm that the cell R0220 in S.25.02.04 should include all components of the consolidated SCR, including capital requirements of undertakings from other financial sectors.
In this context, S.25.02.04 R0220/C0100 should be the sum of the following: R0210/C0100 + R0200/C0100 + R0500/C0100 + R0540/C0100 + R0550/C0100. At the same time we confirm S.25.02.04 R0220/C0100 should be equal to S.23.01 R0590/C0010.
We confirm that the capital requirements of undertakings from OFS should not be included in the cell R0110/C0110.