Own Risk and Solvency Assessment (ORSA)

CDR 2020/442 states that with regards to CDR 2015/35 the flood risk weights in ANNEX X should be replaced by those given in CDR 2020/442. However the flood risk weights given in CDR 2020/442 are identical to those in CDR 2015/35. We therefor wonder if new flood risk weights are the correct ones. The risk weights for flood risk for Hungary have been changed by Commission Delegated Regulation (EU) 2019/981* as of 1 January 2020 but the amendments introduced by Commission Delegated Regulation (EU) 2020/442 don’t concern the updated risk weights. * EIOPA’s second set of advice to the European Commission on specific items in the Solvency II Delegated Regulation (EIOPA, 2018) where flood risk weights were recalibrated for Hungary, was implemented with the Commission Delegated Regulation (EU) 2019/981, which amends Commission Delegated Regulation (EU) 2015/35. Furthermore the flood risk weights for Bulgaria include zone 29, according to CDR 2015/35 ANNEX IX Bulgaria should only have zones 1-28. Those risk weights have not changed since the initial adoption of Delegated Regulation (EU) 2015/35. EIOPA has shared your observation with the European Commission.