EIOPA on external models as part of IMAP

Nice of EIOPA to wait for a UK bank holiday to publish their news on External Models and Data and how one should anticipate vigour from their friendly local regulator around obtaining details on their integration into internal model applications.

Post-lobbying, EIOPA have come out fighting on a couple of corners in the context of External Models and Data:

• That by not supplying the "specific information or documentation required" by your regulator, EIOPA expect applications to be rejected
• Compliance with "all the requirements for internal model approval...including those related to tests and standards and model changes" - second bit is my emphasis, as I suspect some companies may have tried to scope their model change policies with a caveat for external model changes (which certainly makes life easier).
• "Proper adaptation" of external models and data to both the risk profile and an undertaking's specificities to demonstrate requirement compliance - sounds likely to entail high quality documentation and/or evidence retention.
• That vendors and applicants should/should have dealt with the details around provision of data to supervisors in their contractual arrangements - too late to revisit this with existing relationships without ultimately introducing non-contracted expenses to at least one party?
• That external data providers (whether they be asset, liability or ESG-type input/tool providers) cannot play the secrecy card when it comes to providing applicants with whatever is required to approve the application, as it is covered in both Solvency I and Solvency II! 

Clarity appreciated, but feels instinctively like some strained customer/provider relationships will emerge once the FSA come knocking!

Late Post Script - Hyperlink was wrong yesterday, apologies