Contractual confidentiality provisions between insurers and suppliers of models cannot be used to justify refusing to provide this information to national supervisors, the authority added. The warning was contained within an 'opinion' from EIOPA – the first to be issued by the authority – designed to promote unified supervisory approaches between supervisors.
The opinion was part of EIOPA's own initiative work on internal model pre-application, and was the result of discussions with vendors, insurance companies and other relevant stakeholders on the use of external models and data.
National supervisory authorities, EIOPA said, may request any additional information from insurance companies using external models or data in order to assess whether they comply with Solvency II requirements for capital. If a company fails to provide all the information necessary for the appropriate assessment of the model, the supervisor should reject its internal model application.
The authority said it was aware this view had raised concerns among vendors of external models and data that the specifics of their models will not be confidentially treated during the supervisory review process. But it stressed that even if there were confidentiality provisions in place, the company will still be obliged to provide all the necessary information about its external data and models to the supervisor.
The authority said that consultation on standards and guidelines, which will provide detailed technical guidance on all aspects of the rules, will not begin until the third or fourth quarter of 2012. The consultation had previously been scheduled to commence this month.
As a result, the the submission of final proposals for standards to the European Commission and the finalisation of the guidelines is now expected in the first or second quarter of 2013, EIOPA said. EIOPA stressed that this did not indicate a delay to the January 1, 2014 application date of Solvency II.
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