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We would like to request clarification on the application of Article 68 of Commission Delegated Regulation (EU) 2015/35 regarding the treatment of participations for the determination of basic own funds of insurance and reinsurance undertakings.

Paragraph 5 of article 3 states that "financial entities, other than microenterprises, shall establish a role in order to monitor the arrangements concluded with ICT third-party service providers on the use of ICT services, or shall designate a member of senior management as responsible for overseeing the related risk exposure and relevant documentation". Given the Article 3, paragraph 5, of Delegated Regulation 2024/1773, what are the roles and responsabilities that are expected to be covered by the role/member of senior management?

I would like to clarify whether this regulation applies to ICT suppliers in Hong Kong and China, as well as to branches located outside of Europe.

Pursuant to IDD art. 24 nr. 3, first sentence, it follows that: “Where an insurance product is ancillary to a good or a service which is not insurance, as part of a package or the same agreement, the insurance distributor shall offer the customer the possibility of buying the good or service separately.” Is the phrase “insurance product is ancillary to a good or service which is not insurance”, and specifically the use of the word ancillary, meant as a reference to the definition of ancillary insurance intermediary in art. 2 nr. 1 (4) (b)? Is it thusly a requirement that the insurance product is sold as both compulsory and as a complementary product to the “main product” in order for the sale to be within the scope of the cross sales prohibition In art. 24 nr. 3?

Can one take account of the off-setting effect of inflation linked bonds and swaps on the asset side when calculating the SCR for life expense risk?

Should the volatility adjustment to the relevant risk-free interest rate term structure - and by extension, the dynamic volatility adjustment in internal models - be used exclusively for liability discounting, or also for projecting asset returns in the context of future simulated reinvestments?

We have a question regarding the discounting of assets and liabilities when calculating the Solvency Capital Requirement for a non-life undertaking using an internal model with uncentred risk measure and short average asset and liability durations (significantly under 5 years). In our opinion, end-period own funds (t=1) should be discounted to the period start (t=0) when comparing them with initial own funds, or alternatively, initial own funds should be inflated to period end with a corresponding factor.

Because Article 36 explicitly says that it concerns Annual submission of IGT and RC, my assumption would be that Article 38 concerns Ad-hoc submissions of the same (this could be written out explicitly to clear any doubts). In this article, you explicitly list all 5 of the new S.36 IGT QRTs: '... using, as appropriate, ...'. This would indicate that S.36.05 should be included in an Ad-hoc reporting.

A new NACE classification (2.1) has been officially published in February 2023. For statistical purposes it will come into effect as per Jan 1st, 2025. Will it also be mandatory to use this revised classification scheme as per that date for regulatory reporting purposes, like the Solvency II QRTs?