Own Funds (OF), Solvency Capital Requirement (SCR), Internal Models (IMs)

We have a question regarding the discounting of assets and liabilities when calculating the Solvency Capital Requirement for a non-life undertaking using an internal model with uncentred risk measure and short average asset and liability durations (significantly under 5 years). In our opinion, end-period own funds (t=1) should be discounted to the period start (t=0) when comparing them with initial own funds, or alternatively, initial own funds should be inflated to period end with a corresponding factor. This is in order to take into account the time value of money effect for the period from t=0 to t=1 when calculating the SCR. According to our understanding, article 121(2) first subparagraph of Directive 2009/138/EC, requiring adequate, applicable and relevant actuarial and statistical techniques, confirms this. Does EIOPA have any objections to this interpretation?