BETTER FINANCE feedback on the review by the ESAs of Solvency II

BF agrees that divergence in the supervision and approval of internal models for Solvency Capital Requirement (SCR) leads to inconsistencies and can create both an uneven level playing field for market participants, and an inconsistent protection of EU citizens as insured persons. Actually, BETTER FINANCE believes that the use of “internal models” is an advantage given to the larger insurance institutions over smaller ones, and even more importantly is a barrier to a fair, clear and not misleading information to the customers, as it is almost impossible for them to evaluate those “internal models”.

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