CRO Forum's response to CEIOPS Consultation Paper no. 17: draft advice to the European Commission in the framework of the Solvency II project on Pillar 2 capital add-ons for solo and group undertakings We welcome this Consultation Paper from CEIOPS. The CRO Forum supports the inclusion of powers for a capital add-on in the Solvency II framework directive. However, we must emphasise that capital add-ons should be seen as a last resort as expressed, for example, in article 136(2) of the EU's Capital Requirements Directive.
This study shall provide a benchmark and guidelines towards Solvency II for the insurance regulators to assess internal models. The results of the study are a contribution of the CRO Forum to the Solvency II project. It should foster the discussion about the application of internal risk capital models for legal solvency – both Pillar 1 and 2 – purposes.