Regulatory Alerts2023-04-19 | Circular 11/2017 (VA)Guidance on Investing Guarantee Assets of Small Primary Insurance Undertakings, Pensionskassen and Pensionsfonds
The Federal Financial Supervisory Authority (BaFin) issues this circular to define administrative practice for investing the guarantee assets of primary insurance undertakings, Pensionskassen, and Pensionsfonds subject to small undertaking provisions. Regulated entities must implement qualified investment management, strategic and tactical policies, and robust risk control procedures covering market, credit, concentration, liquidity, and legal risks while maintaining asset-liability alignment. The guidance mandates detailed internal investment rules, quarterly stress testing, transparent front- and back-office coordination, and strict compliance with the German Insurance Supervision Act to ensure sustainable coverage of policyholder obligations.