Group-wide supervision: Although BaFin’s supervision of insurance entities is – in the first
instance – focused on the solo entities in insurance groups, some enhancements have been
made to the supervision of large insurers at a group-level, including:
• For international groups, including one global systemically important insurer (G-
SII) 38 for which BaFin is the home supervisor, BaFin has taken measures to enhance
the organisation and/or attendance of meetings of colleges of supervisors. Moreover,
amendments to the German Insurance Supervision Act are being proposed to address
legal constraints that prevent BaFin from sharing information with other supervisors,
especially concerning internal models.
• Expansion of the risk classification approach to include a high-level risk assessment at
group-level on an annual basis from 2011 (first pilot) onwards. Group solvency
assessment is already an important part of the Solvency I group risk classification.
• Increase of actuarial expertise (by 19 full-time equivalents) in 2011 and 2012, as well
as continuous efforts to increase actuarial qualifications among existing staff, thereby
strengthening the supervision of complex liability structures.
• BaFin actively participates in the preparation of the 2014 EIOPA stress test where the
major component (“core stress test”) is performed at a group-wide level. BaFin will
implement this framework once it is approved at the EU level. In any case, more
stringent requirements for group-wide supervision will come into place with the
introduction of Solvency II.