Solvency Capital Requirement (SCR)

According to Article 174 of Commission Delegated Regulation(EU) 2015/35: The capital requirement for property risk referred to in point (c) of the second subparagraph of Article 105(5) of Directive 2009/138/EC shall be equal to the loss in the basic own funds that would result from an instantaneous decrease of 25 % in the value of immovable property. In the answer for Q&A 1922 it is stated that: if the leased asset is a building, the lessee would recognize the right of use as a building. Therefore, property risk module would be the relevant risk module for SCR calculation. On this basis I would like to confirm that if a lessee measures the IFRS 16 right-of-use asset (the leased asset is a building) applying a cost model, which is insensitive to the change of property value, the exposure to the property risk equals the value of the right-of-use, however the solvency requirement equals 0. The reason for this is the loss in the basic own funds which is zero, as the value of the right-of-use does not change by more than accumulated depreciation and accumulated impairment losses. There could be an adjustment for any remeasurement of the lease liability, however it does not meet the conditions to do this because there is no option to purchase the underlying asset. Summarising: Is it correct approach to expose the ROU value to the property risk, but the SCR would be 0?