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With regard to the companies part of a group or sub-group according to item 46 to item 54 of Annex 6 from the Methodology for the review of the balance sheets of the insurers, the following shall be considered that those companies refer to the group level assessments which has to be performed in the current exercise in compliance with the applicable legal framework, and in particular the provisions of articles 232 and 234 of the Insurance Code which transpose art. 213 of the Solvency II Directive.

The provision of art. 239, para. 3 of the Insurance Code provides the obligation for an insurer/ reinsurer, part of a group, to ensure that eligible own funds available in the group are always at least equal to the Solvency Capital Requirement of the group.

The group level assessment does not imply that insurance holdings or mixed financial holding companies that are parent undertakings of insurance or reinsurance undertakings are required to contract an independent external reviewer to assess their individual balance sheets as those holdings taken individually are not subject to the review.

 It is however an obligation to the insurers listed in Annex 6 from the Methodology for the review of the balance sheets of the insurers to provide the relevant information to the already appointed Independent external reviewers allowing them to make group and sub-group level assessment according to items 46-54 of Annex 6 and in accordance with the adopted methodology.
FSC will send official letters to the insurance undertakings part of a group or sub-group clarifying that the appointed IERs should also perform the group level reviews.