An insur
ance group should perform its ORSA to assess the adequacy of the group’s risk management and current, and likely future, solvency position. The nature of the assessment should be appropriate to the nature, scale and complexity of the risks at insurance group level. The risks should include all reasonably foreseeable and relevant material risks arising from every member of the insurance group and from the widest group of which the insurance group is part. The insurance group’s ORSA should make sure that there are no material risks of the group that are not captured, that the fungibility of capital and the transferability of assets within the group is taken into account and that capital is not double counted. It is likely to be appropriate to the nature, scale and complexity of their risks for particular care to be given to these aspects for large complex groups.