Scary parts of the EIOPA assessment:

49. EIOPA cannot positively conclude on the current valuation framework, given the variety of different valuation standards available, or on the proposed valuation standards, given the material uncertainties which remain around the economic balance sheet framework being developed.

Furthermore the lower capital requirement is not risk based and in practice can be very low for reinsurers with a high risk profile. For some risks, including currency, concentration and counterparty risks, the higher capital requirement lacks risk
sensitivity compared to the SCR.

56. We find the BMA not equivalent with regard to its requirements around changes
in business, management and qualifying holdings under Principle 11. Although
the Insurance Act (IA) requires that insurers’ shareholder controllers be
assessed, neither the IA nor any other law requires insurers to provide the BMA
with details of changes to their scheme of operation. Therefore only few critical
changes in business, including engaging in non insurance business, require BMA
approval.

To be equivalent, legally binding criteria would need to be developed to
achieve a clear set of business change situations which require BMA approval
rather than relying on internal and unpublished supervisory practice. In addition,
there is significant outsourcing in Bermuda, in particular for captives. For
equivalence the legally binding requirements around the notification process for
the outsourcing of key functions would need to be expanded. Furthermore,
publicly available guidance would also need to be introduced regarding the
documents and information required for an appropriate shareholder controller
assessment.