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D1 LOG file guidance requires external ratings by external rating agency but also that which is used internally for SCR purposes.  Some assets within our bonds, structured securities and collateralised securities portfolios are not rated by the External Credit Assessment Institutions (ECAI) approved by the PRA under the BIPRU rules implementing the Banking Consolidation Directive (BCD). However, most of those assets have ratings issued by other rating agencies (e.g. assets held by our Asian business have ratings issued by local rating agencies). Also, certain assets within those portfolios do not have a rating (i.e. especially assets which are not listed). As such, our internal model considers internal ratings for those assets that are unrated or rated by non-ECAIs.  Consequently, the guidance in the LOG file gives us an inconsistency between our internal model SCR calculation and ratings disclosed in the D1 template (i.e. while D1 reports certain assets as unrated, internal model uses internal ratings for SCR calculation).  Q1) Our preference would be to align the credit ratings reported in D1 template to that are used by our internal model SCR calculation. Would this be acceptable? or, is external rating the primary requirement? Q2) If the proposal in Q1 is not acceptable to EIOPA, can you confirm if we can report the rating issued by any external rating agency irrespective of whether the rating agency is an ECAI (rating agency approved by the PRA, in our case)?