The pre-application process concerning internal models - Komisja Nadzoru Finansowego

Solvency II

The pre-application process concerning internal models

Modification date:

In response to the published opinion of EIOPA, as part the applications for the use of internal models to calculate the Solvency Capital Requirement submitted to the Polish Financial Supervision Authority, the KNF recommends insurance and reinsurance undertakings to use a common application package to organize documentation confirming compliance with the requirements of the Solvency II regulations on internal models. The common application package form (MS Excel with macros) and an explanatory note has been translated (the EIOPA Common Application Package for Internal Models is available on the EIOPA website) and adapted to the needs of the KNF.

In case of application, the completed form should be submitted in electronic form, along with other documents attached to the application for approval of internal models.

Common Application Package for Internal Models: Explanatory Note
Common Application Package for Internal Models: Form


In 2015 the KNF Office has published the list of critical errors in internal models of insurance undertakings. The list is not exhaustive and may be updated. Not committing any of the errors
indicated on the list is not equivalent to the model’s acceptance, but committing any of these errors will prevent the KNF from granting a positive decision or opinion on internal mode

List of critical errors in internal models of insurance undertakings PL
List of critical errors in internal models of insurance undertakings EN


The KNF Office presents a list of issues which will be addressed during meetings with Members of Management Boards organised as part of the pre-application process for the needs of testing the utility test. 

List of issues at meetings of Members of Management Board

During work on preparing the pre-application package, insurance and reinsurance companies drew attention to difficulties in interpreting the provisions of the Solvency II directive and to the content of KNF Office guidelines concerning the pre-application process and the content of the pre-application package. In this connection, the KNF Office presents a document containing answers to the most frequently asked questions.

Answers to the most frequently asked questions concerning internal models for the needs of Solvency II and the pre-application process (September 2011)