I have found that during Q&A process which was carried out during preparatory phase there was the following Q&A. Q: Do we have to calculate capital requirements for balance sheet items such as tangible assets (e.g. office and other equipment, vehicles, stocks)? If so, what capital requirements should apply? Answer from EIOPA: The intention is that under the SCR equity risk module the calculation for type 2 equities applies to all assets other than those already covered in the interest rate risk sub-module, the property risk sub-module or the spread risk sub-module, including the assets and indirect exposures where a look-through approach was not possible. Therefore the SCR for tangible assets such as equipment, vehicles or invetory stock should be calculated using the type 2 equities as in SCR.5.41 and using the stress factor as in SCR.5.43. As for property investments for the own use of the insurance undertaking, these are subject to the property risk sub-module as in SCR.5.55. I checked that in the current process there are two Q regarding tangible assets but rather as investments not tangible assets as such (Q no. 1656 and 1948).

The SCR equity risk module calculation for type 2 equities applies also to all assets other than those already covered in the interest rate risk sub-module, the property risk sub-module or the spread risk sub-module, including the assets and indirect exposures where a look-through approach was not possible and the undertaking does not use the provison of Article 84(3).
Therefore tangible assets such as equipment, vehicles or inventory stock should be included in the calculation of the capital requirement for type 2 equities.