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["Comments resolutions on EIOPA-CP-21-001\nConsultation on the amendments and corrections to the Implementing Regulation (EU) 2015/2450 with regard to the templates for the submission of information to the supervisory authorities and to the Commission Implementing Regulation (EU) 2015/2452, laying down implementing technical standards with regard to the procedures, formats and templates of the SFCR"]
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["Main Reference","Sub Reference (only if applicable)","Solo/Group/Both","Comment","Public/Confidential","Company name:","Resolution"]
["Other",null,"Both","A general comment about the increasing inconsistency of the handling of the \"Code type\" field across the template set.\nThe annotated templates do not include a discrete \"Code type\" field as it is always combined with the Code itself as a single data item or dimension.\nHowever the business templates and the ITS have always detailed a separate \"Code type\" field.\n\nNew templates S.04.03, S.04.04 and S.04.05 do not detail separate \"Code type\" fields - nor do they indicate whether the Code type is required as part of the Code field.\nNew templates S.14.04 and S14.05 do not detail separate \"Code type\" fileds but follow the annotated templates.\nS.30.02 has had the \"Code type\" fields deleted and the \"Code\" field amended.\nS.31.02 has \"Code\" only field C0030 (no \"Code type\" field or indication whether the \"Code type\" is required as part of the \"Code\" field) but has identical field C0200 which does have a \"Code type\" field C0210.\nS.36.01 to S.36.05 have been extensively renumbered but have retained \"Code type\" fields - \"Code\" and \"Code type\" are now numbered C0030/C0031 etc.whereas previously were C0030/C0040.\n\nWE WOULD PREFER THAT THE CODE TYPE FIELDS BE RETAINED (as they have been on the majority of templates) BUT WITH A CONSISTENT APPROACH ACROSS ALL TEMPLATES - I.E. SEPARATE CODE AND CODE TYPE FIELDS IDEALLY NUMBERED WITH CONSECUTIVE REFERENCES (e.g. C0030/C0031) TO INDICATE THAT THESE FIELDS ARE NOT ON THE ANNOTATED TEMPLATES.","Public","FSAssist","Noted. The LOGs are amended and include information about code type where applicable. "]
["Reporting","S.01.01","Solo","C0010/R0105 S.04.04.01 - Activity by country - location of underwriting\n18 — Not reported as no direct insurance business\n\nTEMPLATE IS APPLICABLE TO BOTH DIRECT AND REINSURANCE BUSINESS","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Solo","C0010/R0106 S.04.05.01 - Activity by country - location of risk\n18 — Not reported as no direct insurance business\n\nTEMPLATE IS APPLICABLE TO BOTH DIRECT AND REINSURANCE BUSINESS","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Group","S.01.01 - C0010/R0150 S.06.03 - Collective investment undertakings - look-through approach\n\nOne of the options in the following closed list shall \nbe used:\n1 - Reported \n2 – Not reported as no Collective investment \nundertakings(only for branches not exempted under \nArticle 35 (6) to (8))\n6 — Exempted under Article 254(2) \n7 – Not due as no material changes since quarterly \nsubmission (this option is only applicable on annual \nsubmissions)\n0 - Not reported (in this case special justification is \nneeded)\n\nRE 2: groups are not exempted under Article 35 (6) to (8), but under Article 254(2) instead?\n\nNOTE THIS APPLIES TO MULTIPLE OTHER ROWS ON S.01.01","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Both","C0010/R0470 S.25.05 — Solvency Capital Requirement — for undertakings/groups using an internal model (partial or full)\n\nINCONSISTENT WORDING -\nSolo\n4— Reported due to use of partial internal model\n5— Reported due to use of full internal model\nGroup/3CB\n4 — Reported as use of partial internal model\n5 — Reported as use of full internal model\n\nNOTE - GROUP WORDING IS MORE CONSISTENT WITH OTHER OPTIONS","Public","FSAssist","Agree. Amended using everywhere \"due to use of\"."]
["Reporting","S.01.01","Solo","C0010/R0563 S.26.10 - Internal model - Credit event risk Portfolio view details\n\t10 — Not reported as use of standard formula\n\n\tINCONSISTENT LABELLING  (should it be \"Not reported as use of standard formula or PIM not covering these risks\"?)","Public","FSAssist","Agree. Amended."]
["Reporting","S.01.01","Group","C0010/R0563-R0569 \n\t10 — Not reported as use of standard formula\n\n\tINCONSISTENT LABELLING  (should it be \"Not reported as use of standard formula or PIM not covering these risks\"?)","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Solo","C0010/R0564 S.26.11 - Internal model - Credit event risk for financial instruments\n\t9 — Reported due to use of full internal model\n\n\tINCONSISTENT NUMBERING (should be \"5\"?)","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Both","C0010/R0570 S.27.01 — Solvency Capital Requirement — Non–Life and Health catastrophe risk\n2 — Risk not existent\n\nSHOULD BE 2 — Not reported as risk not existent FOR CONSISTENCY","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Both","C0010/R0760 S.36.03 — IGT — Off\u0002balance sheet and contingent \n\t2 — Not reported as no IGT on Internal reinsurance\n\n\tNOT UPDATED","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Both","C0010/R0770 S.36.04 — IGT — Insurance and Reinsurance\n\t2 — Not reported as no IGT on Cost Sharing, \n\tcontingent liabilities, off Balance Sheet (‘BS’) and \n\tother items\n\n\tNOT UPDATED","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Group","C0010/R0735 S.36.00 – IGT – Summary template\nC0010/R0775 S.36.05 – IGT – P&L\n\t12 — Not reported as no parent undertaking is a \n\tmixed–activity insurance holding company where \n\tthey are not part of a group as defined under Article \n\t213 (2) (a), (b) and (c) of Solvency II Directive\n\n\tNOT CONSISTENT WITH OTHER IGT ROWS WHICH DO NOT INCLUDE THIS OPTION (copied in error from solo?)","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Solo","C0010/R0855 SR.25.05 — Solvency Capital Requirement — for undertakings using the standard formula and partial internal model (partial or full)\n\nROW REFERENCE DOES NOT AGREE WITH ANNOTATED TEMPLATE (Should be R0850?)\n\n 5 — Not reported as use of full internal model\n\nSHOULD BE  Reported as use of full internal model","Public","FSAssist","Agree for R0855 and amended. Dsagree for 5  (should be kept 5-Not reported…). "]
["Reporting","S.01.01","Both","C0010/R0855 SR.25.05 — Solvency Capital Requirement — for undertakings using the standard formula and partial internal model (partial or full)\n\nINCONSISTENT WORDING -\nSolo\n4— Reported as use of partial internal model\n5 — Not reported as use of full internal model\nGroup\n4 — Reported due to use of partial internal model\n5 — Reported due to use of full internal model\n\nNOTE - SOLO WORDING IS MORE CONSISTENT WITH OTHER OPTIONS","Public","FSAssist","Agree. Amended"]
["Reporting","S.01.01","Solo","C0010/R0935 SR.26.08 - Solvency Capital Requirement - for undertakings using an internal model (partial or full)\n\n11 — Not reported as reported at RFF/MAP level\n\nNOT APPROPRIATE FOR RFF TEMPLATE","Public","FSAssist","Agree. Deleted"]
["Reporting","S.05.01","Solo","C0010 to C0120/R0210-R0240\n\tAmount of taxes or charges should be excluded from the written premiums.\n\n\tSHOULD BE \"premiums earned\"?","Public","FSAssist","Agree. Amended also at group level"]
["Reporting","S.05.02","Group","C0080 to C0140/R0410 Changes in other technical provisions — Gross — Direct business\n\nDELETED FROM ANNOTATED TEMPLATE - NOT STRUCK OUT IN I.T.S.","Public","FSAssist","Agree. Deleted"]
["Reporting","S.06.02","Both","C0070 Fund number\n\nINCONSISTENCY BETWEEN SOLO/GROUP - GROUP HAS \"Number or code\" - SOLO JUST HAS \"Number\"","Public","FSAssist","Agree. Amended."]
["Reporting","S.06.02","Both","C0141 Write\u0002offs/write\u0002downs\n\nINCONSISTENCY BETWEEN SOLO/GROUP - SOLO INCLUDES RELEVANT CIC CODES - GROUP DOES NOT","Public","FSAssist","Please note that following the comments received EIOPA decided to not introduce this change. As a result this proposal is not included in the final ITS package"]
["Reporting","S.06.02","Both","C0190 Item Title\n\nINCONSISTENCY BETWEEN SOLO/GROUP - GROUP HAS N/A CIC09 - SOLO DOES NOT","Public","FSAssist","Agree. Amended, making CIC 09 applicable for solo and group reporting"]
["Reporting","S.08.01","Both","C0070 Fund number\n\nINCONSISTENCY BETWEEN SOLO/GROUP - GROUP (SOMETIMES) HAS \"Number or code\" - SOLO JUST HAS \"Number\"","Public","FSAssist","Agree. Amended."]
["Reporting","S.08.01","Both","C0130 Notional amount of the derivative\nThe amount covered or exposed to the derivative, reported in the original currency.\n\nCAN YOU CONFIRM HOW THIS WILL BE ACHIEVED IN THE XBRL FILE? \nCURRENT FILING RULES STATE -\n\nIII.8 Reporting unit of measure\n3.1 – One explicit currency\ninconsistencyInCurrencies: An instance document MUST express all monetary facts using a single reporting currency, unless they are explicitly defined to be reported in the original currency.\nSuch facts are associated to the member \"Expressed in currency of denomination (not converted to reporting currency)\" of the dimension \"Currency Conversion Approach\".\nTemplates in Solvency II DPM and XBRL taxonomy 2.5.0 that could be reported in different currency than the reporting currency are S.16.01 and S.19.01.","Public","FSAssist","As this field should be reported in original currency, additional column is added to provide information about the orginal currency ISO code."]
["Reporting","S.08.01","Both","C0280 Type of counterparty code\n\nIdentification of the code used for the ‘Counterparty Code’ item. \nOne of the options in the following closed list shall be used:\n1 — LEI\n2 – CA (for codes attributed by the undertaking)\n\nUNCLEAR ON WHY \"CA\" IS USED HERE - SHOULD IT NOT BE \"Specific code\" AS ELSEWHERE ON THE ASSET TABLES (e.g. C0030)? OR MAYBE \"CAU\" IF A DISTINCTION IS BEING MADE (This would match the code for \"code attributed by the undertaking\" used elsewhere)","Public","FSAssist","Agree. Amended."]
["Reporting","S.08.01","Both","C0350 Type of counterparty group code\n\nSEE PREVIOUS","Public","FSAssist","Agree. Amended. Please note, that option \"9 - None\" was removed, as the Specific code has been added."]
["Reporting","S.08.01","Group","C0050 Fund number\n\nI.T.S. NOT UPDATED AS PER SOLO","Public","FSAssist","Agree, ammended incorporated in C0070: the solo to have \"number or code\", but didn't align the reference to S.14 as it is not applicable to groups"]
["Reporting","S.11.01","Both","C0190 Issuer Sector\n\nINSTRUCTIONS REGARDING NACE CODES HAVE NOT BEEN UPDATED AS PER S.06.02\n\nIS THIS INTENTIONAL?","Public","FSAssist","Agree. Amended."]
["LAC DT ","Other",null,"S.XX.02– Deferred taxes - Projections before the stress General comments:\n\"This template should only be reported if one of the two following conditions is met:\"\n\nTHREE CONDITIONS ARE LISTED","Public","FSAssist","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other",null,"S.XX.03– Deferred taxes - Projections after the stress\nC0120- C0220/R0560 Taxes paid \n\nAmount of taxes paid. For undertakings belonging to a tax group, the cell must include the share of taxes paid by the group attributable to the undertaking, considering the profits sharing described in cell R0520. R0560 = R0540 * R0100 + R0550\n\nFORMULA DOES NOT RELATE TO CELLS ON TEMPLATE (i.e there is no R0100, R0550 is a subset of R0540) ","Public","FSAssist","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Do you agree with the proposed threshold?","Both","It would be useful to understand the basis of the proposed threshold - is this based on an analysis to target a certain proportion of companies?\nWe propose to adjust the SCR for the impact of the LAC DT, ie, replace 10% * SCR with 10% * (SCR - LACDT). The SCR without LACDT would be a more natural measure to assess the relative impact of netDTA and netDTL                  ","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.13.01","Solo","C0130/R0010–R0330 Future cash–flows used in the Best estimate, Annuities stemming from non–life contracts (gross), Cash out–flows — Future guaranteed benefits\n\n\tThe cash–flows are the ones stemming from Future \n\tbenefits regarding lines of business, as defined in \n\tAnnex I to Delegated Regulation (EU) 2015/35, \n\tAnnuities stemming from non–life contracts relating \n\tto insurance obligations, including health insurance \n\tobligations.\n\n\tMISSING WORD \"guaranteed\"","Public","FSAssist","Agree. Amended"]
["Reporting","S.13.01","Solo","C0135/R0010–R0330 Future cash–flows used in the Best estimate, Annuities stemming from non–life contracts (gross), Cash out–flows — Future discretionary benefits\n\n\tThe cash–flows are the ones stemming from Future \n\tguaranteed benefits regarding line of business, as \n\tdefined in Annex I to Delegated Regulation (EU) \n\t2015/35, annuities stemming from non-life contracts \n\t(gross).\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION (should be \"discretionary\" not \"guaranteed\")","Public","FSAssist","Agree. Amended"]
["LAC DT ","Other","Both","Could you confirm why post-stress DTA and DTL figures are required in S.XX.01? Projections of future profits and tax positions as per the other LACDT templates are far more relevant when assessing LAC DT than quoting stressed balance sheet figures at a point in time. Furthermore, LAC DT will be required to reflect the net future DTA/DTL position post shock so why would each need to be assessed separately?      With regard to the scope: we seek clarification that the proposed templates are only applicable at solo level.","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","The main goal of LAC DT (recoverability test reporting) is to check whether, after a loss, sufficient taxable profits are available to offset the loss. The proposed QRTs ask for information that may go beyond this purpose. In many cases, the QRT asks for a level of detail that may not present a clear added value for LAC DT calculation","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.13.01","Solo","C0210/R0010–R0330 Future cash–flows used in the Best estimate, Health insurance (gross), Cash out–flows — Future guaranteed benefits\n\n\tThe cash–flows are the ones stemming from Future \n\tbenefits regarding line of business, as defined in \n\tAnnex I to Delegated Regulation (EU) 2015/35, \n\tHealth insurance.\n\n\tMISSING WORD \"guaranteed\"","Public","FSAssist","Agree. Amended"]
["Reporting","S.13.01","Solo","C0215/R0010–R0330 Future cash–flows used in the Best estimate, Health insurance (gross), Cash out–flows — Future discretionary benefits\n\n\tThe cash–flows are the ones stemming from Future \n\tbenefits regarding line of business, as defined in \n\tAnnex I to Delegated Regulation (EU) 2015/35, \n\tHealth insurance (gross).\n\n\tMISSING WORD \"discretionary\"","Public","FSAssist","Agree. Amended"]
["LAC DT ","Other","Both","S.25.XX.01.04: the split between post-stress temporary differences (R0400) vs. unused tax losses (R0410) may be merely theoretical. E.g. a market shock can lead to a temporary difference (e.g. shocked assets are held to maturity and the temporary difference reverses) or can lead to a tax loss (e.g. shocked assets are sold and an asset with a similar yield is bought, after which the tax loss recovers), in both cases the recoverability test is identical.","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.13.01","Solo","C0280/R0010–R0330 Future cash–flows used in the Best estimate,Health reinsurance (gross), Cash in–flows — Other cash in–flows\n\n\tThe future cash–flows undiscounted from amounts \n\trecoverables from reinsurance and SPVs/Finite Re, \n\tincluding ceded intra group reinsurance, including \n\tfuture reinsurance premiums. Amount shall be \n\treported net of adjustment for counterparty default \n\trisk.\n\n\tTHIS DOES NOT APPEAR TO RELATE TO OTHER CASH INFLOWS (decribes reinsurance recoverables)","Public","FSAssist","Agree. Deleted"]
["LAC DT ","Other","Both","S.XX.02.01.02 & S.XX.03.01.02: average investment return is not always useful as some parts of the investment return may not be taxed and therefore do not impact recoverability e.g. value gains of shares under Belgian fiscal legislation. Excess return on top of return recognized in SII BS would provide more insight next to the specific tax regimes","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.14.01","Solo","C0210 Fiscal treatment of the products\n\n\tEnnumerated list required?","Public","FSAssist","Agree. Amended. "]
["Reporting","S.14.01","Solo","C0142 Remaining contractual maturity\n\n\tConsistent ennumerated list required (i.e. not roman numerals)","Public","FSAssist","Agree. Amended. "]
["Reporting","S.17.02","Solo","C0020 to C0130/R0100 Gross TP calculated as a whole and Gross BE for different countries — Country 1 [one row for each country in the materiality threshold]\n\n\tAmount of gross technical provision calculated as a \n\twhole and gross best estimate, by country where the \n\trisk is situated or country where the contract was \n\tentered into, for each Line of Business, regarding \n\tdirect business only (or accepted proportional \n\treinsurance only depending on Z0020 (excluding \n\tnon-proportional accepted reinsurance).\n\n\tSTILL REFERENCES Z0020 WHICH HAS BEEN REMOVED","Public","FSAssist","Agree. "]
["Reporting","S.18.01","Solo","C0001 Lines of business included\n\n\tNOT INCLUDED ON ANNOTATED TEMPLATES","Public","FSAssist","Agree. Implemented as a separate template (below the original one)."]
["Reporting","S.23.01","Group","R0030/C0010 Share premium account related to ordinary share capital — total\n\nThe total share premium account related to \nordinary share capital that fully satisfies the \ncriteria for Tier 1 or Tier 2 items and has to \nbe deducted as per Article 330 of the \nDelegated Regulation.\n\nTHE FINAL PART OF THE SENTENCE DOES NOT SEEM RELATE TO THIS ITEM (cf R0030/C0020 etc) - COPIED ON FROM R0020 ENTRIES IN ERROR?","Public","FSAssist","Agree. Amended"]
["Reporting","S.23.01","Group","R0080/C0020 Non–available surplus funds to be deducted at group level) — tier 1 unrestricted\n\nThis is the amount of surplus funds that are \ndeemed non–available as defined in Article \n222(2)–(5) of the Directive 2009/138/EC that \nmeet the criteria for Tier 1 unrestricted items.\n\nTHIS SENTENCE DOES NOT HAVE THE ADDITIONAL TEXT \"and have to be deducted as per Article 330 of the Delegated Regulation\" (cf R0080/C0010)","Public","FSAssist","Agree. Amended"]
["Reporting","S.23.01","Group","R0820 Consolidated part of the Group SCR (, i.e excluding CR for other financial sectors and SCR for undertakings included via D&A method\n\nONLY C0010 APPEARS IN THE I.T.S. BUT C0020-C0050 APPEAR ON THE ANNOTATED TEMPLATE","Public","FSAssist","Agree. Amended"]
["Reporting","S.25.01","Group","TEMPLATE SR.25.01.04 WHICH WAS ADDED IN TAXONOMY 2.6.0 IS MISSING FROM THE ANNOTATED TEMPLATE FILE","Public","FSAssist","The 2.6.0 amendment was decided after closing the 2020 review. Based on the amendments in 2.6.0 we made changes to the SR.25.01"]
["Reporting","S.25.01","Group","REFERENCES TO SR.25.01 HAVE BEEN AMMENDED TO S.25.01 - HOWEVER SR.25.01 WOULD SEEM TO BE THE CORRECT REFERENCE FOR RFF TEMPLATES","Public","FSAssist","The SR.25.01 referencesin RFF were reinstated."]
["Reporting","S.25.01","Solo","R0210/C0100 of which, capital add–ons already set - Article 37 (1) Type d\n\n\tAmount of capital add–on that set by the NSA \n\tby the reporting reference date. It does not \n\tinclude capital add–ons set between that date \n\tand the submission of the data to the \n\tsupervisory authority.\n\n\tREDUNDANT WORD \"that\"","Public","FSAssist","Amended"]
["Reporting","S.25.01","Solo","R0211/C0100 of which, capital add–ons already set – Article 37 (1) Type a\n\nAmount of capital add–on set by the NSA by\nthe reporting reference date. It does include \ncapital add–ons set between that date and the \nsubmission of the data to the supervisory \nauthority.\n\nCONFIRM \"does\" IS CORRECT? - R0212-R0214 ALL SAY \"does not\"- IN GROUP VERSION R0211 says \"will not\"","Public","FSAssist","Agree. Amended"]
["Reporting","S.25.05","Group","General comments - paragraph 2 refers to \"opening\" submissions","Public","FSAssist","Amended. \"Opening\" deleted"]
["Reporting","S.25.05","Solo","R0211/C0100 of which, capital add–ons already set – Article 37 (1) Type a\n\nAmount of capital add–on set by the NSA by\nthe reporting reference date. It does include \ncapital add–ons set between that date and the \nsubmission of the data to the supervisory \nauthority.\n\nCONFIRM \"does\" IS CORRECT? - R0212-R0214 ALL SAY \"does not\"- IN GROUP VERSION R0211 says \"will not\"","Public","FSAssist","Agree. Amended"]
["Reporting","S.25.05","Group","THERE IS NO TEMPLATE SR.25.05.04 FOR GROUP REPORTING (ONLY SR.25.05.01)\n\nWOULD EXPECT SR.25.05.04 TO BE REQUIRED FOR GROUP ONLY R0470 (also title of template would be different (undertakings vs groups)","Public","FSAssist","Agree. Amended."]
["Reporting","S.25.05","Solo","We note that in the annotated templates SR.25.05.01 does not include the bottom rows from S.25.05.01 concerning DTAs (whereas SR.25.01.01 does include the equivalent bottom rows from S.25.01.01","Public","FSAssist","Considering amendments made for taxonomy 2.6.0 release, EIOPA amended SR.25.01 by introducing SR.25.01.04."]
["Reporting","S.26.08","Solo","ANNOTATED TEMPLATE INCLUDES Z0010 (not in ITS)","Public","FSAssist","Agree. Amended"]
["Reporting","S.26.08","Solo","C0010/R0080 Market & Credit risk - diversified\n\nS.43.09.01 C0010/R0070 minus part of total \ndiversification allocated to Market & Credit \nrisk by the undertaking’s algorithm.\n\nERRONEOUS REFERENCE TO S.43.09.01","Public","FSAssist","Agree. Amended."]
["Reporting","S.26.08","Group","R0700-R0820\n\nTHESE ROWS ARE IN THE I.T.S. BUT DO NOT APPEAR ON THE ANNOTATED TEMPLATE S.26.08.04","Public","FSAssist","Agree. Amended."]
["Reporting","S.26.09","Solo","C0020-C0060/R0090 Equity risk sum \n\n\tSum of the respective values of C0020-\n\tC0270/R0100 and C0020-C0270/R0110.\n\n\tINCONSISTENT FORMULA (should be R0110+R0120? cf R0040)","Public","FSAssist","Agree. Amended."]
["Reporting","S.26.08","Solo","C0010/R0310 Total Net Non-life risk\n\n\tSum of S.26.08.01 C0010/R0330-R0360, R0370.\n\n\tQUERY FORMULA - R00340 and R0350 are components of R0330? - should be R0330+R0360+R0370?","Public","FSAssist","Agree. Amended."]
["Reporting","S.26.13","Solo","C0390/R1600-R1630 Gross Annual Premium - Reinsurance\n\n\tThe insurance or reinsurance undertaking is \n\texpected to split their gross annual written \n\tpremium for direct business by geographical \n\tregion. Geographical regions to be used are \n\tEurope, North America and Rest of World. \n\tAny unallocated premium should be put in \n\tthe Unallocated bucket.\n\n\tERRONEOUS REFERENCE TO \"direct business\" INSTEAD OF \"reinsurance\"?","Public","FSAssist","Agree. Amended. "]
["Reporting","S.26.13","Solo","C0400/R1600-1630 Total Sum Insured - Reinsurance\n\n\tThe insurance or reinsurance undertaking is \n\texpected to split their total sum insured for \n\tdirect business by geographical region. \n\tGeographical regions to be used are Europe, \n\tNorth America and Rest of World. Any \n\tunallocated premium should be put in the \n\tUnallocated bucket.\n\n\tERRONEOUS REFERENCE TO \"direct business\" INSTEAD OF \"reinsurance\"?","Public","FSAssist","Agree. Amended. "]
["Reporting","S.26.13","Solo","C0420/R1670 Significant other perils \n\n\tThe insurance or reinsurance undertaking \n\tshould here indicate if their business \n\tcontains other significant perils not included \n\tin the NatCat or Man-made perils above \n\twith a Y, otherwise this cell should contain \n\ta N.\n\n\tSHOULD THIS BE \"Yes\" OR \"No\" FOR CONSISTENCY WITH OTHER FIELDS?","Public","FSAssist","Agree. Amended. "]
["Reporting","S.29.04","Solo","C0010/R0020 Claims and benefits — net of salvages and subrogations recovered\n\n\t\"net of salvages and subrogations recovered\" deleted from ITS but still on annotated template","Public","FSAssist","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.30.01","Solo","Inconsisitency in the instructions in terms of which words have been struck out. \n\tInstructions should be reviewed for clarity and to remove things such as \"20 largest biggest risks\".","Public","FSAssist","Agree. Amended - check the yellow parts."]
["Reporting","S.30.02","Solo","Inconsisitency in the instructions in terms of which words have been struck out. \n\tInstructions should be reviewed for clarity and to remove things such as \"20 largest biggest risks\".","Public","FSAssist","Agree. Amended - check the yellow parts."]
["Reporting","S.30.04","Solo","C0300/C0310 in ITS but not on annotated template","Public","FSAssist","ITS amended, duplicate removed"]
["Reporting","S.36.01","Solo","General comments - \"This template relates to the information that groups are requested to provide at least annually.\" SHOULD REEFER TO \"Individual entities\"","Public","FSAssist","Agree. Amended"]
["Reporting","S.36.02","Solo","\"ID code and type of code of the instrument\" mislabelled on annotated template as C0080 (same as \"Indirect transactions\")","Public","FSAssist","Confirmed. Annotated Template amended with row code for \"ID code and type of code of the instrument\" changed to c0100."]
["Reporting","S.36.03","Solo","C0150-C0170\n\n\tReferences to group reporting","Public","FSAssist","Agree. Amended"]
["Reporting","S.37.01","Group","Information about S.37.01 appears twice in the ITS - once relating to the new template layout in the annotated templates and once as per the current template layout","Public","FSAssist","Agree: Amended"]
["Third countries branches GLs",null,null,"S.01.01 - C0010/R0120 S.05.02 - Premiums, claims and expenses by country\n\nREMOVED FROM I.T.S. BUT PRESENT ON ANNOTATED TEMPLATE","Public","FSAssist","Agree.To be removed from the annotated template"]
["Third countries branches GLs","S.01.01",null,"S.01.01 - C0010/R0140 S.06.02 - List of assets \nOne of the options in the following closed list shall \nbe used:\n1 - Reported \n6 – Exempted under Guideline 48\n7 – Not due as no material changes since quarterly submission (this option is only applicable on annual submissions)\n0- Not reported (in this case special justification is needed)\n\nOPTION 7 NOT CONSISTENT WITH SOLO/GROUP - 7 — Not due annually as reported for Quarter 4 (this option is only applicable on annual submissions)\nALSO APPLIES TO R0150/R0170","Public","FSAssist","Agree. Amended."]
["Third countries branches GLs","S.01.01",null,"S.01.01 - C0010/R0150 S.06.03 - Collective investment undertakings - look-through approach\n\nOne of the options in the following closed list shall \nbe used:\n1 - Reported \n2 – Not reported as no Collective investment \nundertakings(only for branches not exempted under \nArticle 35 (6) to (8))\n6 – Exempted under Guideline 48\n7 – Not due as no material changes since quarterly \nsubmission (this option is only applicable on annual \nsubmissions)\n0 - Not reported (in this case special justification is \nneeded)\n\nRE 2: branches are not exempted under Article 35 (6) to (8), but under Guideline 48 instead?\n\nNOTE THIS APPLIES TO MULTIPLE OTHER ROWS ON S.01.01","Public","FSAssist","Agree. Amended"]
["Third countries branches GLs","S.01.01",null,"S.01.01 - C0010/R0160 S.07.01 - Structured products \nOne of the options in the following closed list shall \nbe used:\n1 - Reported \n2 - Not reported as no structured products (only for branches not exempted under Article 35 (6) to (8))\n6 – Exempted under Guideline 48\n0 - Not reported other reason (in this case special justification is needed)\n\nMISSING OPTION 3 — Not due in accordance with instructions of the template\nALSO APPLIES TO R0200\nNOTE THIS OPTION IS IN THE 2.6.0 TAXONOMY FOR THESE FIELDS","Public","FSAssist","Agree. Amended"]
["Third countries branches GLs","S.01.01",null,"S.01.01 - C0010/R0330 S.20.01 - Development of the distribution of the claims incurred \nOne of the options in the following closed list shall be used: \n1 - Reported \n2 - Not reported as no non-life business \n3 — Not due in accordance with instructions of the template \n0 - Not reported other reason (in this case special justification is needed)\n\nMISSING OPTION 18 — Not reported as no direct insurance business\nCF SOLO TEMPLATES AND 2.6.0 TAXONOMY\nALSO APPLIES TO R0340-R0360","Public","FSAssist","Agree. Amended"]
["Third countries branches GLs","S.01.01",null,"S.01.01 - C0010/R0500 S.26.01 - Solvency Capital Requirement - Market risk \nOne of the options in the following closed list shall be used: \n1 - Reported \n2 - Not reported as risk not existent \n8 - Not reported as use of partial internal model \n9 - Not reported as use of full internal model \n11 - Not reported as reported at RFF/MAP level \n0 - Not reported other reason (in this case special justification is needed)\n\nMISSING OPTIONS - 16 — Reported due to request of Article 112 of Directive 2009/138/EC\n                                       17 — Reported for SF sub-modules\nCF SOLO TEMPLATES AND 2.6.0 TAXONOMY\nALSO APPLIES TO R0510-R0550","Public","FSAssist","Agree. Amended."]
["Third countries branches GLs","S.01.01",null,"S.01.01 - C0010/R0564 S.26.11 - Internal model - Credit event risk for financial instruments\n\t9 — Reported due to use of full internal model\n\n\tINCONSISTENT NUMBERING (should be \"5\"?)","Public","FSAssist","Agree. Amended"]
["Third countries branches GLs",null,null,"S.01.02 R0250-R0290 PRESENT ON TEMPLATE BUT MISSING FROM I.T.S.","Public","FSAssist","R0250 is kept.\nUpdate: Not necessary for third country branches. R0250 is not to be deleted."]
["Third countries branches GLs",null,null,"S.02.01 - C0010–C0020/R0140 Government Bonds\n\nGovernment Bonds shall be shown as such \nregardless of the SCR treatment.\n\nTHIS TEXT IS STRUCK OUT IN THE SOLO INSTRUCTIONS","Public","FSAssist","Agree. Amended"]
["Disclosure","S.25.05",null,"S.25.05 - C0140 and C0150 ITS entries are incorrect (repeat C0160 and C0170 following)","Public","FSAssist","Agree. To be amended"]
["Disclosure","S.25.05",null,"S.25.05 - R0010-R0030/C0090 on Annotated template but not included in ITS","Public","FSAssist","Agree. Amended"]
["Financial stability guidelines",null,null,"Technical Annex A states -\n\nThe following templates are deleted: \n S.01.01.10/12/14\n S.01.02.01/04/07\n S.14.01.10\n S.38.01.10\n S.40.01.10\n\nyet para (1), (2)a and (3) all refer to template S.38.01.10 as an addition\n\nannotated templates include S.38.01.10\n\nannotated template S.01.01.11 lists the template as S.38.01.11\nannotated templates S.01.01.13 and  S.01.01.15 list the template as S.38.01.10 \n\nWE ASSUME THE TEMPLATE SHOULD BE LABELLED AND REFERED TO AS S.38.01.11 THROUGHOUT","Public","FSAssist","Agreed. The right reference of the template is S.38.01.11, as S.38.01.10 has been removed from the deleted templates list. "]
["LAC DT ","Other","Both","S.XX.02.01.04 & S.XX.03.01.04: \no\tThe distinction between carry-forward (R0500) vs. fiscal losses (R0530) may be merely theoretical (cf. comment made on S.25.XX.01.04)\no\tThe formula provided in the instructions may need to be corrected to R0560 = R0530 * R0100 + R0540","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","The paragraphs above only provide some examples of data which may not be directly needed for the purposes of understanding LAC DT. In order to obtain a useful reporting – if additional tables are required at all – the focus could be on (post-stress) taxable P&L projections, e.g. split in 2-3 lines between life & non-life (+ investment returns). This would provide a shorter reporting with useful insights on the recoverability test, leaving out information that is not directly related to LAC DT. It could be interesting to think about reportings aiming at strenghtening harmonisation across EU, considering relevant national specifics. The LAC DT is indeed one major difference between countries (beyond local tax regulation)","Public","Actuarial Association of Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?","Both","We do not consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments. From our point of view the effort arises at the time when checking the exposure for exceeding the threshold. After this there is no point for not reporting the KPI at all. ","Public","Deutsche Rückversicherung Aktiengesellschaft ","Noted. Also conside the the sustainable investments ratio is not included in the final package."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ","Both","We do not consider relevant to introduce a materiality threshold for the reporting requirement on the share of investments exposed to climate change-related transition risk. From our point of view the effort arises at the time when one would check the exposure for exceeding the threshold. After this there is no point for not reporting the KPI at all.\nWe are critical regarding the extension of the NACE codes to four digits, which entails considerable additional work for us, for two reasons: Firstly, in our opinion, such an allocation is only very rarely possible, as companies usually pursue a broad spectrum of activities. Secondly, we are of the opinion that such a detailed allocation is not necessary for the measurement of transition risks. Common factor-based climate scenarios - for example those of Bank of England - use a much coarser sector breakdown than four-digit NACEs.\n","Public","Deutsche Rückversicherung Aktiengesellschaft ","Noted. While we recognise that detailed NACE reporting is not available for all activities and the NACE classification has its limits to asssess climate risk, we note the emergence of supporting tools and the use of 4-digit NACE code reporting to identify sustainable economic activities in a standardised manner, also as part of the EU taxonomy, to contribute to the assessment of transition risk. Tools such as the EU Taxonomy Compass, or the EU Patform on Sustainable Finance's NACE classification mapping:\nhttps://ec.europa.eu/info/files/sustainable-finance-taxonomy-nace-alternate-classification-mapping_en can help in identifying investments at the 4-digit level. \n"]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?","Both","We do not consider relevant to introduce a materiality threshold for the reporting requirement on the share of  investments exposed to climate change-related risk. From our point of view the effort arises at the time when one would check the exposure for exceeding the threshold. After this there is no point for not reporting the KPI at all. ","Public","Deutsche Rückversicherung Aktiengesellschaft ","Noted. Also conside the the sustainable investments ratio is not included in the final package."]
["Reporting","S.02.01","Both","We are referring to the balance sheet QRT, S.02.01, item C0010-C0020/R0270. There the new wording explaining the reinsurance recoverables says: “It includes expected payments from reinsurers for claims not yet settled between the undertaking and the policyholder, while expected payments from reinsurers for claims already settled are included in reinsurance receivables.”\n\nThe wording seems to say quite clearly that the criterion is whether a claim, i.e. the entire claim, has been settled in relation to the policyholder. If it has been settled then all expected future payments expected from the reinsurer should be included in the receivables. If it has not been settled then all expected future payments from the reinsurer should be included in the recoverables.\n\nIn our opinion it would be very challenging to complete the balance sheet QRT on this basis, since the question of the entire claim being settled or not is not a view that is usually available in the data flow between cedent and reinsurer (bordereaux). To us as non-life actuaries, it would seem much more natural instead to distinguish between payments to the policyholder made vs. not yet made, i.e. expected reinsurance payments corresponding to future gross claim payments would be reported as recoverables, those corresponding to existing payments as receivables. In this case the quotation might be clarified as follows: “It includes expected payments from reinsurers corresponding to payments not yet made by the undertaking to the policyholder, while expected payments from reinsurers corresponding to payments already made are included in reinsurance receivables.”\n\nThe comment covering R0370 would have to be changed accordingly.\n\nThe same question arises for payables, C0010-C0020/R0830.","Public","Beltios","Agreed. The explanation regarding item C0010/R0270 (Reinsurance recoverables) was amended to the following: \nFor Solvency II column (C0010) this cell in particular should include all expected payments from reinsurers to the undertaking (or vice versa) corresponding to payments not yet made by the undertaking to policyholders (or by policyholders to the undertaking).\nWhile, all expected payments from reinsurers to the undertaking (or vice versa) corresponding to payments already made by the undertaking to policyholders (or by policyholders to the undertaking) should be included in reinsurance receivables (or reinsurance payables). "]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?","Both","The requirement to identify and report on exposures to sustainable investments is new and could therefore prove to be quite onerous for firms who do not currently have access to such information. Therefore a materiality threshold would be welcome. Ideally this threshold would exempt smaller firms who may struggle most to obtain the required information. The threshold for Financial Stability Reporting might serve as a useful starting point. Over time, as insurance companies and fund managers develop their asset information to identify such exposures, the scope could be extended to cover more companies. Another threshold may be to exempt certain lines of business such as unit-linked business where insurers do not invest directly in sustainable investments but only have second order exposures via charges on funds. Another option might be to align requirements and thresholds with other EU requirements in this space e.g. Corporate Sustainability Reporting Directive. Generally, it should be taken into account that excessive reporting requirements will lead to additionnal costs and then to counter-productive incentives for policyholders.","Public","Actuarial Association of Europe","Noted. EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ","Both","The requirement to identify and report on exposures to transition risks is new and could therefore prove to be quite onerous for firms who do not currently have access to such information. Therefore a materiality threshold would be welcome. Ideally this threshold would exempt smaller firms who may struggle most to obtain the required information. The threshold for Financial Stability Reporting might serve as a useful starting point. Another threshold may be to exempt certain lines of business such as unit-linked business where insurers do not invest directly in sustainable investments but only have second order exposures via charges on funds. Over time, as insurance companies and fund managers develop their asset information to identify such exposures, the scope could be extended to cover more companies.                                                                                                           ","Public","Actuarial Association of Europe","Noted. We do not propose a materiality threshold nor propose to exempt certain lines of business, as this would not serve a risk-based prudential assessment. We propose instead a gradual introduction of the reporting requirement to allow undertakings to seek to obtain the relevant information: the KPI will need to be reported only from 2024 (FY2023 information). EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for hte risk assessment. "]
["Sustainable finance questions","3. What could be a methodology for standardised reporting of climate change-related physical risk exposure for other investments than property?","Both","Having insurers report on climate related physical risk exposures for all assets recognises that a risk exposure exists. It also allows better comparability between insurers than simply reporting on property exposures alone. Therefore while we are broadly supportive of reporting these exposures we note that if this reporting is not standardised then it will have limited use to regulators or other users of the data. Indeed there may be a disincentive to insurers who make the most effort to look-through and understand their exposures to climate change related physical risks.\n\nFor emerging and sometimes complex risk exposures it can be particularly difficult to develop a comprehensive standardised approach to reporting on risk exposures. Therefore while an impact could be estimated using VAR methodologies, or estimated based on a pathway with low levels of mitigation (e.g. over 3 degree global warming), it may be more appropriate to band the risk exposures together using a qualitative risk assessment approach. For example, large bands, whereby assets with particular sensitivities (e.g. businesses based on low-lying islands where the value may fall to zero) are easily distinguished from those of more typical, well diversified exposures.\nHowever adequate guidance should be given to ensure consistent application across insurers, and a simplified approach should be allowed for life insurers with extensive investment exposures.","Public","Actuarial Association of Europe","Noted. As to the standardisation: good practices are starting to emerge and will consolidate over time. The ORSA and the KPI will inform supervisors' risk assessesment before it allows comparison with other undertakings. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for hte risk assessment.  \nAs part of the ORSA, EIOPA expects undertakings to identify the materiality of exposures to climate change risks through a combination of qualitative and quantitative analyses. This should support the reporting of the KPI."]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?","Both","The requirement to identify and report on exposures to climate risks is new and could therefore prove to be quite onerous for firms who do not currently have access to such information. Therefore a materiality threshold would be welcome. Ideally this threshold would exempt smaller firms who may struggle most to obtain the required information. The threshold for Financial Stability Reporting might serve as a useful starting point. Another threshold may be to exempt certain lines of business such as unit-linked business where insurers do not invest directly in sustainable investments but only have second order exposures via charges on funds.Over time, as insurance companies and fund managers develop their asset information to identify such exposures, the scope could be extended to cover more companies.","Public","Actuarial Association of Europe","Noted. We do not propose a materiality threshold nor propose to exempt certain lines of business, as this would not serve a risk-based prudential assessment. We propose instead a gradual introduction of the reporting requirement to allow undertakings to seek to obtain the relevant information: the KPIs will need to be reported only from 2024 (FY2023 information). EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for hte risk assessment. "]
["Sustainable finance questions",null,"Both","Investments exposed to physical risk\n- Requires reporting of latitude & longitude or country ISO Alpha 1 +postal code + city + streetname and number.  Sourcing this data may be a challenge (especially for unit-linked insurers or investments in property funds).\n- Report the share of investments exposed to physical risk as % total investments.  Not limited to properties however; how would non-property investments exposed to physical risk be identified?","Public","Actuarial Association of Europe","Noted. Undertakings are invited, as part of their ORSA to explore and explain if and how they have assessed the physical risk exposure of their non-property investments. The EIOPA draft application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA, currently under consultation, provides an opportunity to test and further discuss good practices."]
["Sustainable finance questions",null,null,"More guidance on how to identify climate risks and sustainable investments and how to identify the proportion of individual investments that may only have some degree of sustainability/climate risk exposure is needed. As things stand, the proposals seem to be quite vague and could result in inconsistent treatment of the same asset across firms.","Public","Actuarial Association of Europe","Noted. The reporting of the KPI will inform supervisors' risk assessesment before it allows comparison with other undertakings. Good practices are starting to emerge and will consolidate over time. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for hte risk assessment. The consultation and pilot exercise on the guidance (March 2022) are an opportunity to test and further discuss good practices."]
["LAC DT ",null,"Both","Another set of three templates has been added to the reporting package. The industry was not previously consulted or even informed that such a template was upcoming. \n\nRecommendation: These templates should be gathered and evaluated only on ad-hoc basis by the national supervisor, not as an increased reporting with these very burdensome new templates for many undertakings. \nShould EIOPA decide to introduce these templates, all loss absorbing capacity of deferred taxes (LACDT) templates should be subject to very high thresholds. ","Public","Insurance Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ",null,null,"The template is not part of the annotated template file.  \n\nIt is assumed that XX.01 replaces templates 25.01.01.03-05 and 25.05.01.03-05. EIOPA is requested to confirm this.\n\nThe industry strongly opposes the introduction of the new deferred tax templates, as the current information reported in S.25 is sufficient. The requested information should be gathered and evaluated on an ad-hoc basis only by the national supervisor, not as an increased reporting with these very burdensome new templates for many undertakings. \n\nThe main goal of LAC DT (recoverability test reporting) is to check whether, after a loss, sufficient taxable profits are available to offset the loss. The proposed QRTs ask for information that may go beyond this purpose. In many cases, the QRT asks for a level of detail that may not present a clear added value for LAC DT calculation.\n\nComments per template:\nS.25.XX.01.04: The split between post-stress temporary differences (R0400) vs unused tax losses (R0410) may be merely theoretical: eg a market shock can lead to a temporary difference (eg shocked assets are held to maturity and the temporary difference reverses) or can lead to a tax loss (eg shocked assets are sold and an asset with a similar yield is bought, after which the tax loss recovers), and in both cases the recoverability test is identical.\nS.XX.02.01.02 & S.XX.03.01.02: The average investment return is not always useful as some parts of the investment return may not be taxed and therefore do not impact recoverability: eg value gains of shares under Belgian fiscal legislation.\nS.XX.02.01.03 & S.XX.03.01.03: Many data items may not be relevant for the recoverability test calculation, amongst which:\n \tWritten premiums (within contract boundaries).\n \tThe distinction between renewals vs new contracts.\n \tThe distinction between “Taxable profit before temporary differences” vs changes in temporary differences (cf. comment made on S.25.XX.01.04).\nS.XX.02.01.04 & S.XX.03.01.04:\n \tThe distinction between carry-forward (R0500) vs fiscal losses (R0530) may be merely theoretical (cf. comment made on S.25.XX.01.04). \n \tThe formula provided in the instructions may need to be corrected to R0560 = R0530 * R0100 + R0540. \n \tThe paragraphs above only provide some examples of data which may not be directly needed for the purposes of understanding LAC DT. In order to obtain a useful reporting — if additional tables are required at all — the focus could be on (post-stress) taxable P&L projections: eg split in 2-3 lines between life & non-life (+ investment returns). This would provide a shorter reporting with useful insights on the recoverability test, leaving out information that is not directly related to LAC DT.\nIn S.XX:01, this information is deemed mostly a repetition of the one already introduced in 2021 in the main SCR related QRTs at solo and group level. Furthermore, this level of detail is not available in post stress conditions where a full market value balance sheet (MVBS) is not produced.\nIn S.XX.02 and S.XX.03, the information requested seems to refer to recoverability assessment over future profits. EIOPA should confirm whether the use of these QRT templates is limited to entities that have used a recoverability assessment. The extension to entities not using that leverage for capital absorption is strongly opposed by insurers, as the requested input is complex to provide and the possible use uncertain.\n\n\nIf EIOPA proceeds with the implementation of these templates, the industry suggest that:\nS.02.01.01:\nThe proposed threshold for 02.01.01 is plausible on solo level. The industry would propose to adjust the SCR for the impact of the LACDT: ie, replace 10% * SCR with 10% * (SCR - LACDT). The SCR without LACDT would be a more natural measure to assess the relative impact of netDTA and netDTL.\nC0030/C0040:\nThe proposed columns seem to be intended to assess the impact of DTA and DTL on the LACDT on solo level. On group level, the calculation of deferred taxes is very complex as the local tax regulations and the local tax books are very different within the group. So, it would be very complex and time consuming for the groups to calculate a consolidated group tax book. This would not bring any meaningful information for the control authorities, as it would be a mix of different tax rules and tax books. Furthermore, most groups take their IFRS balance sheet as a basis for the calculation of deferred taxes. The IFRS balance sheet does not have the same structure of balance sheet as the economic balance sheet. Groups would therefore have to report deferred taxes from their solo companies twice – once according to the IFRS balance sheet structure and a second time according to the economic balance sheet structure. This would lead to high and unnecessary costs and would be very time consuming. EIOPA is requested to confirm that the proposed columns are not applicable for groups.\n\nXX.01\nGeneral remarks:\nRows R0500 and R0510 are inconsistently labelled when compared to the proposed ITS (R0430 and R0440). For the purpose of further comments, the notation from the LACDT templates is used.\nThere is a typo in row 18: Justification of _deferred_ tax asset.\nThere is a typo in row 27: _Unused_ tax credit\n\nR0200-R0230/C0020-C0030: EIOPA is requested to provide further explanation as to how these cells should be filled for approaches based on average tax rate.\nR0300/C0020-C0030: It would be appreciated if the thresholds for XX.02 and XX.03 would be applicable to R0300/C0020 and R0300/C0030, respectively.\n\nXX.02/XX.03\n The proposed templates seem to be intended to assess the impact of DTA and probable future taxable profits on the LACDT at solo level. For groups, generating this information would be even more burdensome and does not provide any further useful insights for supervisors. EIOPA is invited to confirm that the proposed templates are not applicable for groups.\nThe proposed thresholds for XX.02 and XX.03 seem plausible. The industry would propose to adjust the SCR for the impact of the LACDT in the thresholds not related to the SCR breaches: ie replace 10% * SCR with 10% * (SCR - LACDT). The SCR without LACDT would be a more natural measure to assess the relative impact of taxes on future profits and DTA.\n\nProposed thresholds:\n \tS.02.01 Balance sheet: The industry takes note of the threshold of ‘DTL > 10% of the SCR’ proposed for C0030 and C0040\n \tS.XX.01 Deferred taxes: No threshold is foreseen \n \tS.XX.02 Deferred taxes – Projections before the stress: A threshold is foreseen \n \tS.XX.03 Deferred taxes – Projections after the stress: A threshold is foreseen\n\nQuestion - Do you agree with the proposed threshold? \n\nThe industry strongly opposes the introduction of the new deferred tax templates. The current information reported in S.25 is sufficient. Alternatively, high thresholds should be introduced for all the proposed LAC DT templates. Furthermore, the thresholds should apply to all the new LAC DT templates, some in the current package do not have a threshold, eg XX.01. ","Public","Insurance Europe","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","We assume that these new templates only are relevant at Solo level. Furthermore, detailled information (log-files in Annex II) would be very helpful to better understand the expectations to the three new templates. .","Public","GDV","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","S.XX.01 / S.25.XX.01.04: We do not understand why unsused probable future taxable profits should be reported. If an undertaking does not not apply DTA justified by probable future taxable profits at all, this requirement does not make sense but only leads to substantial pointless effort. In particular for small undertakings, this would be a high burden.\n\nMoreover, the – probably undesired – incentive effect should be considered: If all undertaking are forced to do the difficult calculation of probable future taxable profits, more undertakings will use this figures afterwards and apply additonal DTA.","Public","GDV","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","S.02.01.01.01:We do not consider the reporting of columns C0030 and C0040 to be useful:\n\nWe would like to make sure that the two new columns regarding deferred taxes will not be subject of auditing. We assume that still only the „Solvency II“ column will be audited. Reporting to the public seems to us to be inappropriate and oversized. Furthermore, the uniformity of reporting in S.02.01 between the individual companies is no longer given as soon as the defined threshold for the additional disclosures is exceeded for one company.\n \nWith regard to the reporting of table S.02.01.01 and the reporting of fields R0510, R0520 and R0600, it is not possible to split the corresponding tax balance sheet values or tax bases between the items non-life, health (similiar to non-life) and life without major effort. This is due in particular to the fact that this breakdown is not yet required for tax purposes or for group purposes. \n \nEffort: \nThe tax balance sheets should be sufficiently known to the supervisors - a double query represents unnecessary effort for the companies. Originally, the mandate to EIOPA was to simplify the QRTs - the current proposal is more than counterproductive. For the initial implementation, we estimate an effort of several person-months for the specialist experts and an IT effort of a comparable amount; in the ongoing operation, these new fields lead to a significant burden for the supplying entities. Numerous special regulations under Solvency II lead to reclassifications in the solvency overview (e.g., special regulations in the reserves by type of life insurance, IFRS 16, reinsurance special regulations, etc.). ) - if balance sheet items have to be reported, these reclassifications would have to be correctly followed up in the tax balance sheet. Up to now, this has only been done to a limited extent, as these have a neutral effect on the overall result.\n\nLegal basis: \nThe purpose is obviously an analysis of the origin of deferred taxes. The DVO does not yet provide for reporting of deferred taxes per balance sheet item - what is the legal basis for requesting this additional data?\n\nRegulatory objective: \nThe additional columns do not achieve the supervisory objective (support an initial assessment by supervisors on the adequacy of LAC DT), but on the contrary lead to misleading findings. The tax calculation for certain balance sheet items is not based on the deltas (e.g. investment funds) or is based on legal requirements with different tax rates (e.g. shares in partnerships). Consequently, the additional columns provide arbitrary results unrelated to deferred taxes.\n\nFinally, it should be confirmed that QRTs S.XX.01-03 are to be reported only by solo companies and not by the group which is not atax subject. Rather, the Group's deferred tax assets and liabilities arise by summing up the deferred taxes (from a Group perspective) of the separate financial statements. Therefore, in our opinion, the additional disclosures on deferred taxes in S.02.01 are only relevant for the solo companies. In particular, their application is not apparent from ITS_cons._AnnexIII with regard to group instructions. ","Public","GDV","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Do you agree with the proposed threshold?","Both","We do not agree with the mentioned thresholds as they are too low from our point of view.\n\nS.02.01.01, S.XX.02: Reporting should not be triggered by Net DTL > 10%*SCR or Net DTA > 10%*SCR. Such a threshold would not be risk sensitive as a small / decreasing SCR triggers reporting requirements even if the surplus of own funds over SCR and the SCR ratio are very high / increasing. \n\nIf, however, there is a Net DTA related trigger, it should a) be at least 15%*SCR, consistent with the threshold for eligible tier 3 capital, and b) be asscociated with an important impact of Net DTA, e.g.: „The amount of net DTA is higher than 15% of the SCR AND the undertaking would fall below a SCR-coverage of [e. g.] 150% without the amount of DTA justified with future profits“. \n\nWith regard to Net DTL, we do not understand why there is a Net DTL related trigger at all.\n\nS.XX.02, S.XX.03: We do not understand why these templates are always to be reported if there is an SCR breach - even when LAC DT is zero or LAC DT is completely justified with Net DTL. Instead, reporting should only be triggered if the deletion of LAC DT justified with future profits would be the reason for an SCR breach.  The formula should be adjusted accordingly.","Public","GDV","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","Presentation of deductible and taxable temporary differences columns broken down by Solvency II balance sheet headings will be very costly in terms of time required to produce the data as similar disclosures presented in statutory financial statements are usually more general. In our view such disclosure will also be of limited use as Solvency II balance-sheet headings aggregate data with quite different liquidity, maturity and tax profiles. \n\nTherefore, we propose to remove this requirement or to limit the disclosure to general titles e.g.: \n\n1.       all intangibles (including goodwill, DAC and other intangibles) presented in one line;\n2.       property, plant and equipment, investments, assets held for index-linked and unit-linked contracts and loans and mortgages presented in one line;\n3.       holdings in related undertakings, including participations (being a component of amount 2 above) presented additionally (these assets are usually not subject to deferred taxation according to IAS 12);\n4.       reinsurance recoverables disaggregated into life and non-life (as in the draft);\n5.       all other assets aggregated in one line as these items are mostly short-term and with only small temporary differences;\n6.       technical provisions disaggregated into life, non-life and index-linked/unit-linked (as in the draft);\n7.       all other liabilities aggregated in one line – these items result in small temporary differences in most cases.\n","Public","PZU","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Group reporting questions",null,"Both","In relation to the options set out for S.37.01 in connection with reporting risk concentrations, we agree that there is an issue that needs to be addressed. However, each of the options has some drawbacks as called out by EIOPA. Option 2 may be the most appropriate method if EIOPA were to specify the simulations/scenarios to test. ","Public","Actuarial Association of Europe","Noted. Based on the inputs received, the selected option for S.37.01 is option 1 with some changes: „proportional or otherwise justifiable break-down agreed with the group supervisor“"]
["Financial stability guidelines",null,"Both","In terms of the duration to be reported in S.38.01, there is a general view that reporting both effective and modified duration may be unnecessary (and time consuming) and that only the most relevant duration calculation should be reported for each group of liabilities.","Public","Actuarial Association of Europe","Noted. From the feedback received, Option 1 will be implemented. Therefore, effective duration will only be required to be calculated in addition to the modified duration when material optionalities are present in the technical provisions."]
["Reporting","S.05.01","Both","In the reports S.04 and S.05 there is a new requiment for them item 'Premiums written' -  Amount of taxes or charges should be excluded from the written premiums. Could you elaborate on what kind of charges should be excluded? Risk charges? Administration? If all possible charges are excluded from premium, the sum could not be classified as insurance premium under IFRS 17 anymore resulting in blank report.(proposal: cancel text in italic)","Public","Actuarial Association of Europe","Definition of insurance premium taxes and charges should be provided. Do you agree to the following amendment: \"Amount of taxes or charges levied with premiums should be excluded from the written premiums.\" (Insurance Accounting Directive (Directive 91/674/EEC), Article 35 states “The above amounts shall not include the amounts of taxes or charges levied with premiums.”)"]
["Reporting","S.05.01","Both","Item 'Premiums earned': This template shall be reported from an accounting perspective. Future IFRS17 accounting standard will not have the notions as unearned premium provision or gross written premium. How directive 91/674/EEC is connected with IFRS17 standard in the mean of unearned premiums TP. ","Public","Actuarial Association of Europe","EIOPA recognizes that IFRS17 will bring material changes in the recognition, valuation, presentation, disclosure of insurance contracts. However, the template S.05.01 will be kept as it is now even if IFRS insurers don´t report the written and earned premius in their accounting P&L. The main reason is to maintain consistent basis of reporting for all insurers (IFRS and local gaap users). Further reasons:\n1) Although linked to accounting, S.05.01 is not a P&L but simply requires some P&L related items to collect some volume measures to measure the performance trend and for market wide analysis;\n2) This approach is already in place today with regard to insurance contracts with no significant insurance risk, whose written premiums/claims paid are not accounted for in the IFRS P&L (according to IFRS 4) but are still to be reported in S.05.01;\n3) The mandatory disclosure of IFRS 17 on premiums/claims paid would allow undertakings to fill in S.05.01 following the current approach;\n4) Re(insurance) undertakings will have to keep track of written/earned premiums for MCR/SCR calculation.\n\nFor IFRS17 users: Written premius/claims paid will be reported in the notes to the financial statements. "]
["Reporting","S.14.02","Both","More guidance on how to populate the climate risk information may be required to ensure this is being treated consistently across the market as there are some areas which are open to interpretation. For example, is the intention that products should be recorded if they cover direct losses to these perils (i.e. property damage losses) or should products which may be subject to ancillary losses as a result of climate change risks also be included?","Public","Actuarial Association of Europe","Many thanks for the useful comment. This guidance has been included. "]
["Reporting","S.14.03","Both","Similar issues to S.14.02 in respect of the onerousness of gathering the required information; whilst an understanding of Cyber exposure would be valuable, the format of the template may require a significant workload in order to collect the information in the desired format and to determine the level of coverage for each product group.","Public","Actuarial Association of Europe","Noted, but the level of granularity has been already calibrated in an aggregated way, which should help in reducing the work associated with the delivery of the requested data. Nevertheless EIOPA believes that even more granular information should already be available to undertakings for their internal risk management purposes."]
["Reporting","S.14.03","Both","As with S.14.03, this template may require substantial additional guidance to ensure consistency across the market. Whilst the example provided is useful, there are many more possible scenarios which may need to be clarified individually. Furthermore, the design of the template raises a number of questions, particularly where products include cyber coverage amongs other perils. Reporting premium and technical provisions information at this level may not be possible with current processes and may lead to challenges for some entities to accurately capture this information. ","Public","Actuarial Association of Europe","EIOPA disagrees. Information on Technical Provisions and Premiums should be known to the undertaking to properly run the required risk management processes. EIOPA notes however that in case of unbundling of cyber in the case of cyber not being the main risk being covered (therefore playing a minor role in the overall product structure), the information to be reported could only be a best effort estimation as far as premiums and technical provisions are concerned. Nevertheless, a proper unbundling effort, if duable, can help the undertaking in enhancing proper risk management processes."]
["Reporting","S.14.03","Both","Could you clarify under what circumstances this template should be reported? There is a requirement to report technical provisions; therefore, does this mean that this template will be required until all cyber exposures are fully eliminated, even in run-off situations? As for S.14.02, no materiality threshold is referenced. Is the proposal that this template be reported in case of any exposure to cyber risks, even if this is an immaterial portion of the overall book?","Public","Actuarial Association of Europe","Noted. Thresholds are indicated in the 2020 review opinion but will be inserted also in the ITS text. There are indeed some materiality thresholds that require the reporting of this template (i.e. The template shall be subject to the application of a threshold based \non the following:\n- The sum of exposures of standalone cyber and policies with cyber \nas add-on coverage is greater than 25% of the overall non-life \nbusiness pursued by the undertaking \n OR \n- Number of policies that include cyber (i.e standalone cyber and/or \ncyber ad add-on policy) represent more than 3% of the total \nnumber of policies sold for the non-life busines). The template will need to be reported until cyber policies (in the agregated form of product category) are in the portfolio."]
["Reporting","S.29.05","Both","We note the extent of guidance which was produced in respect of the original Variation Analysis templates. The changes to these templates may necessitate similar guidance with worked examples to avoid inconsistencies in how this template is populated.","Public","Actuarial Association of Europe","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Other",null,"Both","Some general comments on the proposals are outlined below:\n\n1.\tThe current burden of regulatory reporting is already heavy, as evidenced by the growth in regulatory reporting teams in undertakings. Reporting is also very complex in places, as evidenced by the continued presence of errors and omissions in QRTs, inconsistency in approach and the need for clarifications in EIOPA QAs. Therefore, regulatory reporting already presents a non-trivial overhead for undertakings. \n\n2.\tWith this in mind, any expansion of reporting should address a specific, relevant and material regulatory need, as opposed to being a “nice to have”. The requirements in relation to LACDT would seem to be a “nice to have” as regulators will engage directly with undertakings where there is a specific concern about LACDT calculations (which have scope for subjectivity). \n\n3.\tThe utility and reliability of regulatory reporting relies on undertakings taking a consistent approach. With this in mind, any reporting that relies on an element of subjectivity should be avoided, unless guidance can be provided to ensure consistency of approach between undertakings. Any requirement to allocate data to cyber or climate change might fall into this category.\n\n4.\tPerhaps there is a risk of “regulatory reporting inflation” whereby the burden of reporting increases unconstrained over time. We acknowledge the need for the regulatory reporting requirements to evolve over time to reflect emerging issues and risks such as climate change and cyber. However, it might be prudent for the regulatory review process to also consider the decommissioning of any QRTs that are not currently being materially relied upon by regulators or other stakeholders, particularly where those QRTs are particularly data intensive, complex or subjective. Examples of some QRTs which create a disproportionate workload for undertakings include S.20.01, S.21.01 and S.21.03.\n\n5. In the context of the above comments regarding increasing regulatory reporting requirements, we note the increasing number of ad-hoc exercises and impact assessments which require the provision of significant data to EIOPA. A recent example of such an exercise is the Non-Life Underwriting Risk Comparative Study in Internal Models. Whilst such exercises may only affect some undertakings, we note that the comments regarding increasing regulatory reporting requirements also extend to such data collection exercises given the resources they consume.\n\n6.\tRelated to this, we strongly support the concept of unambiguously defined reporting thresholds. We would initially recommend higher thresholds rather than low thresholds, on the basis that thresholds may be lowered later, thereby providing somewhat of a transitional measure.\n\n7. In this regard, we note the references to proportionality in the documentation and the reduced requirements for captive undertakings in the ITS. Whilst this reduction in the level of reporting would be welcomed by smaller undertakings, we note that the definition included in the ITS is quite narrow in this regard, and on this basis there would remain a significant number of smaller entities who are subject to disproportionate resources and expenditure to meet the reporting requirements. Additional metrics for smaller entities to be excluded from more data intensive QRTs should be considered, such as the volume of premium, technical  provisions or assets.","Public","Actuarial Association of Europe","EIOPA acknowledges the comments received and further analysed the proposed amendments. As a result some changes have been introduced e.g. dropped out of the LAC DT templates, reverse to the initial S.29s templates etc. Please consult the final proposal. The proposed amendments are fit for purpose, reflecting current supervisory needs while at the same time consider the industry's implementation costs. To allow enough implementation time the implementation date has been also postponed. Regarding the comment on the increasing number of ad-hoc exercises EIOPA is of the view that with the newly introduced templates the information that will be received there will cause the decrease in the requested ad-hoc requests.Considering the proposed thresholds please note that EIOPA further analysed them and some new thresholds have been introduced. The thresholds proposed are based on the impact assessment analysis. In addition the extension period of the annual thresholds has been also extended reflecting on the stakeholders' comments and suggestions. \nOn the last comment please note that as part of the SII Review EIOPA also proposed introduction of the low risk profile undertakings with number of different criteria for categorisation of such undertakings."]
["Reporting","S.03.01","Both","S.03.01 It is good to know that there is a threshold of 2% of total assets, but difficult to implement. The decision is retrospectively after all subsidiaries/parent company's figures are consolidated. This does not really bring a relief.\nFor unlimited guarantees there is the possibility \"1\" ... entities with same group and \"2\" ...entities not with same group. What should we report if there are companies which have items for \"1\" and  \"2\". Do we report only \"2\" and leave out the \"1\" or is there the additional option \"1 and 2\". For the parent company we assume, that only \"2\" and not\"1\" ist to report","Public","Munich Re","EIOPA has re-analysed the impact of the proposed threshold based on solo insurer reporting S.03.01 in 2020. The impact assessment shows that if the threshold was to be implemented, 45% of solo insurers would have benefited from it (ie. 45% of solo insurers would not report S.03.01 template). \nTherefore, EIOPA believes that the implementation of the treshold in S.03.01 template will bring relief to insurers and does not see the reason to change the scope of this treshold. In addition, EIOPA has extended the observation period of the annual thresholds to release the reporting burden. Furthermore, it should be noted that the application of the threshold is not mandatory, ie. insurer may or may not use it.\nRegarding your last question, please note that an additional option was added for unlimited guarantees received/provided from/to entities of the same group and entities not belonging to the same group in S.03.01.01.03 for solo undertakings (appropriate changes for S.03.01.04.03 - groups). "]
["Reporting","S.05.01","Both","QRT S.05.01 (and S.05.02 where affected) (all QRTs Fin. Stability quarterly and annualy) : Please define \"Amount of taxes or charges \" more precisely, e.g. premium tax.\nIs the information of  the deleted line items \"change in other tecnical provisions\" completely eliminated or should the information now be reported in the new defined position  \"Balance - other technical/expense\"","Public","Munich Re","Definition of insurance premium taxes and charges should be provided. Do you agree to the following amendment: \"Amount of taxes or charges levied with premiums should be excluded from the written premiums.\" (Insurance Accounting Directive (Directive 91/674/EEC), Article 35 states “The above amounts shall not include the amounts of taxes or charges levied with premiums.”)\n\nThe change in other technical provisions is not included in the item \"Balance - other technical expense/income\". The instruction of the item is amended accordingly.   "]
["Other",null,"Both","In General, we see that the implementation effort/cost of the proposed changes is high. The implementation deadline will be tight if the actual ITS will only be published in Q1 2022, especially as there are other big changes in the insurance industry as the implementation of IFRS 17 and 9 have to finalized during the same time span.","Public","Munich Re","Noted. As a result EIOPA further extended the application date."]
["Reporting","S.06.02","Both","The new requirements will lead to high effort/cost for implementation but also in the daily doing. \nIn detail:\n• Field C0141 (write-offs/write downs): The amount depends on the accounting framework: e.g. under IFRS 9 it is unclear to us what should be inserted.\n• Field C0230 (NACE): We expect here quite an implementation and administration effort as the 4-digit NACE sectors have to be procured for and need to be quality checked. This effort only seems proportional if no additional figures like the climate risks are asked for. \n• Field C0240 (issuer group): This filling had already been requested by a Q&A.\n• Field C0292 (SCR calculation approach for CIU): Already requested as a taxonomie update.\n• Field C0295: (crypto assets): We wonder if crypto assets already play such a big role compared to other investments to introduce a new attribute for them.\n• Field C0296/0297 (property type / property location): \n• Field C0301 (Long-term equity investments - LTE) : Please clarify that this should only be filled if the entity actually makes use of Art 171a for that investment. ","Public","Munich Re","1) C0141 (write-offs/write downs): Please note that following the comments received EIOPA decided to not introduce this change. As a result this proposal is not included in the final ITS package\n2) C0230 (NACE):Correct. This requirement was introduced in replace of additional ones targeting at getting information on climate risks exposures\n3) C0240 (issuer group): Correct.\n4) C0292 (SCR calculation approach for CIU): Correct\n5) C0295: (crypto assets): With this requirments supervisors will monitor the present and future evolution of these assets in the insurance undertakings portfolios\n6) C0301 (Long-term equity investments - LTE): It is applicable to equities and CIUs, where yes or no should be reported, and report \"Not applicable\" to other assets categories"]
["Reporting","S.06.03","Both","While we are glad that not a even more detailed QRT has been designed we are still regrettful that EIOPA has not adjusted the requirements: Due to the current thresholds a company only investing in assets directly needs to disclose S.06.03 as soon as it invests a small sum in a fund. The administrative effort for the disclosure of S.06.03 are hugh: For all funds investments TPTs need to be negotiated, regularly collected, quality checked and processed. ","Public","Munich Re","In the case of small sums of mutual funds, lookthrough information is only necessary on yearly basis due to the existing threshhold. This reduces the burden for undertakings. Nevertheless, lookthrough information is needed for many supervisory analyses. "]
["Reporting","S.06.04","Both","The first KPI is also already part of the taxonomy reporting so the additional reporting here is questionable. Moreover, the timeline for the implementation of this KPI is not feasible as financial companies under the CSRD are only due to report this figure starting year end 2023 based on the reporting of the corporates a year before. To change deadlines of now already planned and ongoing projects is unrealistic and will lead to a data base which would not be reliable. We would like to ask EIOPA to adjust the timeline for the reporting of this figure to year end 2023 and to publish the new timeline in advance of Q1 2022.\nWith respect to the other two new KPIs it seems questionable that those may not be of much use to the supervisory authorities as every entity may report figures stemming from different methodologies and of different dimensions.\n","Public","Munich Re","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\nOn the transition and physical risk KPI, the reporting of the KPI will inform supervisors' risk assessesment before it allows comparison with other undertakings. Good practices are starting to emerge and will consolidate over time. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for the risk assessment. The consultation and pilot exercise on the guidance (March 2022) is an opportunity to test and further discuss good practices."]
["Reporting","S.07.01","Both","Very costly attributes like the attachment/detachment point which are of not much use for the supervisors should be abolished. Thresholds do not prevent that this cost arises as the KPIs need to be provided for anyways","Public","Munich Re","Comment is not clear"]
["Reporting","S.08.01","Both","The unique transaction identifier is another example for duplicating regulatory information. ","Public","Munich Re","EIOPA explained the reasoning behind the options taken regarding how and when to take into account EMIR data, in paragraphs 2.168 to 2.176 of the Report on quantitative reporting templates (EIOPA-BoS-20/754, 17/12/2020), including the link between SII template and EMIR database. The unique identifier will allow to verify the possibility to use such  link go obtain additional data for supervision from external sources"]
["Reporting","S.10.01","Both","According to field C070 in template S.06.02 the entry of the fund number is not mandatory, unless otherwise required by the national supervisory authority. The same should also apply for template S.10.01, thus field C050 should be adjusted accordingly. The requirements of the templates in this respect must be consistent.          ","Public","Munich Re","Agree. Ammended"]
["Reporting","S.14.03","Solo","Reporting should be limited to direct business, as corresponding figures from active reinsurance business could not be adequately reported or would not be comparable. Example: Number of claims for reinsurance quotas not available, claims payments only available for pure cyber quotas, but not for mixed contracts International standards for a uniform taxonomy for recording exposure and damage data must be taken into account. EIOPA should query the information at an appropriately high aggregation level. The more granularity is required, the more effort the reporting will take and the higher the likelihood that something will need to be valued. Since only stand-alone policies are to be recorded, a division into the underlying line of business does not lead to any added value in the evaluation and should therefore not be carried out. A collection of granular data as part of Solvency II reporting, as currently proposed by EIOPA, on the other hand, creates immense internal effort with no recognizable added value for the insurance industry. \n\n- C030: Product Category not possible to separate since contracts contain not only one of the threee categories but more or all three of them\n- C060: description of risk is too granular \n- C080: sum(s) insured not possible to report for proportional business/ quota shares (unlimited insured sums)\n- C140: not available in the granularity of products categories; also relevant for run- off business, where provisions still existent when business not existent anymore?\n\n","Public","Munich Re","Noted and partially agree. EIOPA clarified, where needed, further specifications for reinsurance undertakings. On the level of granularity, EIOPA sees the information to be reported in the template as important and believes, that after the review of the comments from the first consultation wave, the template granularity reached a good level of compromise asking data that undertaking should have and that are needed for supervisors to perform their daily work."]
["Financial stability guidelines",null,"Both","QRT S.14.04 - Financial Stability:\nLiquidity is managed at a entity/group level but not at reinsurance product level. Unlike Primary insurance, reinsurance cannot be viewed at a \"Product\" level and hence it is not meaningful deliver information at a product level. For life reinsurance business a quarterly submission of such information is not necessary as these are managed on a yearly projection / longterm basis with adequate provision for short term fluctuations.  The effort required to generate the information on a quarterly basis would be inappropriately large compared to the benefit achieved.","Public","Munich Re","Noted. Reinsurance undertakings are exempted to report S.14.04.11 and S.14.05.11. Guidelines have been adjusted accordingly.  "]
["LAC DT ","Other","Both","We assume that all the disclosures related to deferred taxes will be required on annual basis, because such disclosures should not be required more often than full DTA/LAC DT recoverability tests, which are usually carried out on annual basis or when plans/budgets are updated. More frequent reporting requirement would not carry any essential informational content.","Public","PZU","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","New LAC DT QRTs look oenrous and need further review.","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.29.05","Solo","QRT S.29.05.01.06: R0240/C0060+C0070 - Sign\nLog-file: Amount of future premiums as reported in S.18.01 C0070 and S.13.01 on annuities stemming from Non-life at year N-1 on an aggregated level for the corresponding LOB. The sum reported in this cell should coincide with the total in S.18.01 C0070.The value in this cell should be reported with a negative sign.This cell mainly relates to non-life insurance claims in C0070. If not relevant or not applicable report this cell with a zero\n\nStatement/Question: The value in this cell should be reported with a positiv sign.","Public","Munich Re","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Solo","QRT S.29.05.01.06: R0340/C0060+C0070 - Sign\nLog-file: Amount of future premiums as reported in S.18.01 C0070 at year N on an aggregated level for the corresponding LOB. The sum reported in this cell should coincide with the total in S.18.01 C0070.The value in this cell should be reported with a positive sign.This cell mainly relates to non-life insurance claims in C0050. \n\nStatement/Question: The value in this cell should be reported with a negativ sign.","Public","Munich Re","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Solo","QRT S.29.05.01.06: R0220 (Example only!)\n\nLog-file: \nC0070/R0220 represents the undiscounted best estimate for claims provision after the adjustments in R0020-R0040 excluding the effect of non-life annuities in R0030 as this is reported in C0060.C0060/R0220 represents the annuity best estimate claims provision after the adjustments in R0020-R0040 stemming from Non-Life Insurance obligations at beginning of year N. \n\nStatement/Question: C0070!!!/R0220 represents the annuity best estimate claims provision --> The columns have to be reversed!","Public","Munich Re","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Solo","QRT S.29.03, S.29.04, S.29.05 - Note:\nThe technical provision for annuities stemming from non-life are included in the calculation for life dominance, since they are included in the TP Life balance sheet position and thus for the relevance of S.29.03 or S.29.04, but are to be reported in S.29.05. This is at least unpleasant. In the admittedly unlikely extreme case (e.g. run-off), it may happen that the annuities stemming from non-life dominate the overall business but are not reported because S.29.05 is not submitted. In this case, the supervisor could refer to Log-File S.29.03-05 (criterion 4. 4) and demand the submission of S.29.05.","Public","Munich Re","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.30.03","Solo","QRTS.30.03/C0420 - Coverage of a layer covered by reinsurance\n\nINSTRUCTION (EIOPA)\nInclude the coverage of a layer as an amount covered by reinsurance. \n\nStatement/Question:\nThe instruction to the mentioned QRT cell is unclear. A supplementary clarification is required. Does requested information refer to Sliding Scale Commission (C0390)?","Public","Munich Re","It is not related to the sliding scale commission. It should include the maximum coverage per layer of a reinsurance treaty. The LOG has been improved."]
["Reporting","S.30.03","Solo","QRTS.30.03/C0430 - Order of claims within the reinsurance program\n\nINSTRUCTION (EIOPA)\nInclude the order of claims within the reinsurance program.\n\nStatement/Question:\nThe instruction to the mentioned QRT cell is unclear. A supplementary clarification is required. Does requested information refer to Sliding Scale Commission (C0390)?","Public","Munich Re","This cell has been deleted."]
["Reporting","S.30.03","Solo","QRTS.30.03/C0440 - Minimum commission / C0450 - Maximum commission\n\nINSTRUCTION (EIOPA)\nInclude the minimum/maximum commission as a percentage.\n\nStatement/Question:\nThe instruction to the mentioned QRT cell is unclear. A supplementary clarification is required. Does requested information refer to Sliding Scale Commission (C0390)?","Public","Munich Re","Minimum/Maximum commission that would be paid for a layer of a reinsurance treaty. This is particularly relevant for sliding commissions where the commssion is not a fixed percentage but depends on other variables."]
["Reporting","S.33.01","Group","The general comments state that the first part of the template \"(Cells C0060 to C0230) collects the information (….) regardless of the method used for the calculation of the group solvency.\" Contrary to that, a reference to the D&A is included between instructions to C0050 and C0060.","Public","Munich Re","Agree. Amended"]
["Reporting","S.37.03","Group","\"The tables shall include all the risk concentration … by the combination of the main asset classes and rating.\" -> Question: Which rating is meant? The rating of the issuer or the rating of the security?","Public","Munich Re","The rating of the security. Clarification added in the instructions."]
["Reporting","S.37.03","Group","Types of Bonds: Are covered bonds also in the scope of Z0010? If so, should they be reported separately?","Public","Munich Re","Covered bonds are in the scope but not to be reported separately. "]
["Financial stability guidelines",null,"Group","S. 38.01 from the given Options we prefer Option 1. In general we feel that the current duration requirements (Modified and effective duration) are onerous involving high effort without any adequate benefit.\nEspecially for reinsurance which primarily involves risk coverage, this requirement seems inappropriate in comparison to the effort this would cause.\nIn case it is required to deliver either one, the effective duration is not meaningful for reinsurance business.","Public","Munich Re","Noted. Reinsurance undertakings are exempted to report S.14.04.11 and S.14.05.11. Guidelines have been adjusted accordingly.  From the feedback received, Option 1 will be implemented. Therefore effective duration will only be required to be calculated in addition to the modified duration when material optionalities are present in the technical provisions"]
["Financial stability guidelines",null,"Group","S.39.01.11 - insted of the line item \"Tax paid\"  we would recomend the expense item  \"Taxes on income\" from the income statement","Public","Munich Re","Agreed. The line item \"Tax paid\" has been amended as \"Taxes on income\"."]
["Reporting","S.36","Group","Definfition of Sectors: mapping from ToU to sectors possible?","Public","Munich Re","After a brief analysis, there seems to be a possibility to reconcile S.32 and S.36. However, for a couple of codes (for instance 8 or 15), it seems advisable to review the EBA documentation and possibly consult relevant subject matter experts.\nUpdate: Due to further changes in the templates it does not seem to provide any value added to conduct this mapping."]
["Reporting","S.36","Group","Indirect transaction: If reported intra-group transactionis part of an indirect transaction (cf. General comments supra), report the “ID of intragroup transaction” (FC0010) of the related transaction in this cell.  - if there are several transaction, which ID should be used? Always the first?","Public","Munich Re","EIOPA confirms that all interim transactions should be reported separetely, even if specific transactions were executed with undertakings outside of the group. Amendments have been introduced.  If more than two transactions are related, the ID code of the first related transaction needs to be reported as a reference to link all interconnected transactions"]
["Reporting","S.36","Group","Single economic operation: If the reported intragroup transaction is part of single economic operation (cf. General comments supra),report the “ID of intragroup transaction” (FC0010) of the related transaction in this cell. -  Is this an new additional ID for all related transaction or should the ID of one related transaction be used? Which should be used if more tha two transaction are related?","Public","Munich Re","EIOPA confirms that all interconnected transactions in a single economic operation should be reported separated, even if specific transactions were executed with undertakings outside of the group. Amendments have been introduced. If more than two transactions are related, the ID code of the first related transaction needs to be reported as a reference to link all interconnected transactions. "]
["Reporting","S.32.01","Group","C0081: How is the definition meant for entities having more than one direct participation undertaking: Are you expecting one line for each holding company or only one line with the parent company having the highest capital share?","Public","Munich Re","The column C0081 on Direct Participating undertaking  is removed. "]
["Reporting","S.32.01","Group","C0290: Could you please confirm that this information is only relevant for entities having a volatility adjustment and which are using the internal model?","Public","Munich Re","Eiopa confirms that the column is seeking information on the type of  Volatility adjustment used by the solo undertakings in the group internal model. If an internal model is used without VA or if the Standard Formula is used for the group solvency calculation then ‘None’ should be selected. \n\n"]
["Financial stability guidelines",null,"Group","S.39.01.11 - insted of the line item \"Tax paid\"  we would recomend the expense item  \"Taxes on income\" from the income statement","Public","Munich Re","Agreed. The line item \"Tax paid\" has been amended as \"Taxes on income\"."]
["Reporting","S.17.02","Solo","S.17.02.01 Remark to the Log File Gereral Comments: we would recomend also to include R040, R050, R060, R070, R080, R090 in the sentence \"When this amount is higher than 90%....only R0010, R020 and R0030 shall be reported\" (please see log file)","Public","Munich Re","Agree. Amended"]
["Reporting","S.17.02","Solo","S.17.02.01.02. C0020 to C0130/R0100: the accepted proportional reinsurance is mising in the template. Where to report the amount for the accepted proportioanl resinsurance otherwise? ","Public","Munich Re","Comment not clear. The columns are in the template in a separate table below"]
["Reporting","S.17.02","Solo","S.17.02 According to our interpretation  90% of non life techical provisions only shall be reported in this template, starting with the line of business representing the highest amount. Is our interpretation correct? ","Public","Munich Re","EIOPA confirms your interpretation. The threshold is for LoB representing a coverage of 90% of the Non-life TP in addition to the current threshold on material currencies. Only lines of business need to be reported that are material However, please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold. "]
["Reporting","S.12.02","Solo","S.12.02 According to our interpretation  90% of the life techical provisions only shall be reported in this template, starting with the line of business representing the highest amount. Is our interpretation correct? ","Public","Munich Re","EIOPA confirms your interpretation. The threshold is for LoB representing a coverage of 90% of the Non-life TP in addition to the current threshold on material currencies. Only lines of business need to be reported that are material. However, please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold."]
["Other",null,"Both","GENERAL COMMENTS\n\nWhile the European Insurance and Occupational Pensions Authority’s (EIOPA) proposals take into consideration a few of the many concerns raised by the industry, it has disregarded industry feedback on many points. \n\nTiming & process\nThe implementation period is too short given the high number of proposed changes.\nEIOPA intends to implement changes to the quarterly reporting templates (QRT) in a very short timeframe. \n\n*Indeed, the Q4 2022 reporting deadline is already in February 2023. Therefore, to be able to report in a timely fashion for Q4 and full year 2022, the QRTs should be implemented before December 2022, as companies start their reporting process before the reporting date due to the tight deadlines and the fact that it is not possible to change/implement QRTs during the ‘business as usual period’ of the reporting. This means that companies will only have time starting from the EC approval of the proposals: ie from January/February until November, and nine months would be largely insufficient to implement this extensive package. \n\n*It is noted that the new implementing technical standards (ITS) will only be available at the beginning of next year, while companies must report on that same year. This means that companies should set-up internal processes to gather newly requested information from 1 January 2022. However, since the QRTs, Data Point Model (DPM) and Taxonomy will not be ready in time, companies will have to start a time-consuming retro-active data gathering exercise. \n\n*It is unclear why EIOPA is rushing these extensive changes. If these changes will be pushed through, it will be expensive to implement them: due to the need to test and validate the required changes to IT systems, and ultimately, these costs will be passed on to the customer. Such a rushed approach will also lead to data quality issues and empty fields. \n\n*For most insurers, 2022 IT budget/planning/resources/systems decisions have already been taken. As the final QRT package is not known, it is difficult for companies to already take these unknown changes into account in their IT budget/planning.\n\n*In many cases the resources needed for the implementation of the reporting package will already be working on other major regulatory changes, including the implementation of International Financial Reporting Standard (IFRS) 17 – insurance contracts and IFRS 9 – financial instruments, as well as sustainability requirements. Insurance companies will therefore have already made a detailed planning for their IT architecture and allocated resources, mostly being allocated to IFRS. Furthermore, there are simply not enough highly skilled people available: it is estimated that for an average sized company, over 100 people will be needed to implement the changes to the QRTs over a period of at least 18 months.","Public","Insurance Europe","EIOPA would like to clarify that the current ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations where the timeline for implementation was clear.\nNo amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \n. \n"]
["Other",null,"Both","GENERAL COMMENTS CONTINUED\n*EIOPA should avoid making any changes to its QRTs and reporting requirements before a proper strategic consideration has taken place of Level 1 and Level 2 issues related to the Solvency II 2020 review (including full scrutiny by the EU institutions). This would avoid the need to change the QRTs (and IT-systems) twice in a period of three years, which is both costly and burdensome. In this regard, EIOPA should respect the hierarchy of EU-regulation, and all changes should therefore be made as part of the Solvency II 2020 review.\n\n*If EIOPA persists with its proposals, the implementation date must be delayed by at least one year compared to what EIOPA is proposing, given the very large number of — often material — proposals. For new templates an even longer time frame should be considered in order to have a realistic timeframe for undertakings to report all the new information. In addition, if implemented according to plan, the new validation coming with the new taxonomy should be not blocking in the first year of submission (currently planned for 2023).\n\nThe proposed changes are disproportionate and would lead to an excessive cost and burden for undertakings. EIOPA should limit any changes to the reporting package to those that are necessary to fulfil its supervisory duties.   \n\n*EIOPA argues that the majority of the undertakings would benefit from a reduction in reporting costs for several reasons (including simplification of quarterly reporting, elimination of reporting templates and the risk-based thresholds). Overall, however, the many changes proposed by EIOPA would lead to a complication rather than a simplification, (as indicated in previous industry responses). As the volume of information to be reported and the effort needed to generate the requested data would increase significantly, together with implementation costs, contrary to EIOPA’s statement, the changes will not reduce the reporting burden for most undertakings and will actually increase costs for reporting. This would negatively impact policyholders, for example, through higher premiums.\n\n*While the thresholds introduced in a number of templates are helpful to some extent (eg S.04.05), the industry is disappointed that only a few thresholds were introduced/lowered and only to a limited extent. In fact, in practice, the thresholds may not result in a real reduction of the burden for (smaller) insurers, because if the insurer would breach the threshold in one period, this would result in a requirement to submit the data. This also implies that the insurer should have at all times a process in place to collect and submit the requested data.\nTherefore, the threshold should be valid for a longer period, or a single breach should not directly lead to a requirement to submit.\nIn addition, changing the thresholds in current templates does not necessarily imply a reduction of the reporting burden, since the IT and data systems for reporting this information have already been developed. Furthermore, the industry notes that, in its proposals, EIOPA no longer refers to the concept of core/non-core templates, which was introduced in the reporting consultation in 2019. ","Public","Insurance Europe","EIOPA disagrees. The proposed amendments are not expected to be impacted by Solvency II Review. In addition the impact on reporting from Solvency II review is not expected to be material. Currentamendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing /EIOPA is proposing extension tof the implementation date to 2024. \nFollowing the comments received EIOPA further analysed the proposed amendments and some further changes have been introduced to respond to the comments made e.g. dropped out of the LAC DT templates, reversion to the current S.29s etc. Regarding thresholds some further ones have been introduced e.g. S.04.05 and the threshold period has been extended.\nRegarding the core and non-core templates they still exist where core templates are the templates that need to be reported by al undertakings and non-core are the ones with threshold that can be exempted from reporting."]
["Other",null,"Both","GENERAL COMMENTS CONTINUED \n*While the industry welcomes the clear reference to the proportionality principle and the introduction of proportionality provisions for captives and specific ‘business models’, the remainder of the reporting package is not proportionate at all and the specific proportionality measures and their respective impact are unclear. Further, the link to the planned proportionality framework (ie the treatment of low-risk undertakings) seems to be missing. There are also still too many reporting requirements for smaller, non-complex insurance companies. There is also a disproportionate increase in the overall reporting burden given all the new templates and the added requirements, including those proposed for undertakings with internal models, which by nature cannot reflect the diversity of internal model structures. \n\n*Introducing new templates, restructuring templates, or making extensive changes to templates by, for example, adding numerous additional cells, takes a lot of time to change and/or develop and implement, with high costs as a consequence. In general, companies find the proposed changes, including both material and minor changes, very extensive. Taken together, these constitute a considerable amount of work for companies. As processes are automated, any change made is very costly. Indeed, the simple change of a row and/or column requires IT intervention. The complexity of these projects requires close collaboration between IT professionals, actuaries, and prudential law specialists. In addition, validation checks must be carried out.\n \n*While the deletion of non-necessary/not used QRTs is welcome, the industry expected to see further templates being removed in order to achieve an impactful simplification, as the majority of the templates were not reported by many undertakings. \nEIOPA, in an attempt to eliminate/reduce ad hoc requests, has tried to anticipate every single possible ad hoc request that can be made by supervisors, resulting in more and more reporting requirements. Ad hoc requests can never be eliminated, and there will always be some situations that cannot be foreseen. Attempts to try and cover every single eventuality, even if little/rarely used, therefore lead to lots of work but very little benefit. A better, more realistic balance must be struck. It should also be noted that flexible ad hoc requests can be a very useful supervisory tool. For example, the National Bank of Belgium implemented an ad hoc reporting at the start of the COVID-19 crisis.  \n\n\n","Public","Insurance Europe","EIOPA disagrees. As part of the ITS amendments all thresholds have been analysed and changes to some of them proposed as also new thresholds. Regarding the treatment of the low-risk undertaking it is part of the proposals of Level 1 Regulation and not of the ITS.\nEIOPA considers the current proposal fit for purpose reflecting long process of discussing the proposed changes.The ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations where the timeline for implementation was clear.\nNo amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. "]
["Other",null,"Both","GENERAL COMMENTS CONTINUED \nThe untransparent structure of the consultation and the lack of a comprehensive overview of the changes makes it difficult, if not, impossible for the industry to assess the significance of the changes and as such makes it unnecessarily difficult to provide meaningful and timely comments. \n\n*While a large part of the proposals can be found in the document that was released together with EIOPA’s opinion on the 2020 review in December 2020, only a high-level, incomplete overview of new proposals can be found in the cover note and cover note annex, and the proposed thresholds are in the impact analysis. Against this background, it is necessary to have a comprehensive overview of the changes and a background explanation for the reasons for them, in particular for the ones that were not included in the opinion issued in December 2020. EIOPA is using the opportunity to capture changes introduced through previous taxonomy versions where the ITS were not updated. Without a background explanation, it can be confusing to understand why certain changes are shown in Annex II and not highlighted in the annotated template: for example, the inclusion of a new row ‘C0010/R0260 - Direct URL to download the SFCR’ in template S.01.02.\n \n*Further concerns include: firstly, for a complete review the validation file should be published as part of the consultation package, since the definitions in Annex II do not always provide the information on the relationship between different data elements, especially newly introduced ones. Secondly, given that the Logfiles were only available in pdf, companies were forced to cross reference with the annotated templates to check whether definitions were changed. And finally, the new taxonomy and DPM must be available for the IT process, which EIOPA has not released. \n\nAdditional concerns\nThroughout the QRTs, EIOPA keeps referring to “earned and written premiums” as one of the requested key figures. However, with the introduction of IFRS 17, this key figure will no longer be available for companies adhering to the new standard and this will cause additional burden to keep old accounting standards in place in order to match supervisory needs while also reporting under the new ones. The P&L and balance sheets in scope of external audits will be only available under the new regime. The industry is still waiting for EIOPA to provide an interpretation on bridging the Solvency II earned and written premiums and the actuals from IFRS 17. Against this background, the industry suggests introducing the possibility to align the “earned and written premiums” required in S.05.01 with the “insurance revenues” of IFRS-17, to avoid creating an additional burden by keeping old accounting standards in place.\n\n\n","Public","Insurance Europe","EIOPA disagrees. All changes have been introduced in track changes. The changes in the majority has been based on the QRT report published by EIOPA at the end of 2020. In addition newly introduced areas were explained in the Cover Note. In addition all changes included now are based on all the work during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations.\nImpact analysis include an assessment of the thresholds but the concrete thresholds proposals are included in the consultation package in track changes more in the individual instructions of the different templates.\nThe DPM will be available early in the 2021. The consultation included only proposals of the ITS amendments together with changes in the templates. \nRegarding IFRS 17 and the impact on S.05.01 EIOPA further clarified the instructions of the template but would like to stress that S.05.01 is not a P&L and therefore some deviation may occur (e.g. differences exists also today with IFRS 4). At ‘solo’ level IFRS 17 is expected to be applied only by a minority of undertakings and it is preferable to keep one consistent metric\nIFRS users are expected to keep track of written/earned premiums (as defined Art. 1(12) of DR) in order to calculate capital requirements under SII (e.g. S.28.02).\n"]
["Reporting",null,"Both","GENERAL COMMENTS CONTINUED \nEIOPA proposes very extensive changes and new templates, and the industry sets out its detailed views and proposals for each template in this paper.   \n\nEIOPA proposes new templates for:\n \tCyber risk (S.14.03)\n \tExtensive new reporting requirements for internal model companies (10 new templates S.26.08-16, S.25.05)\n \tLAC DT reporting (three templates)\n \tSustainability reporting (S.06.04)\n \tNon-life business - policy and customer information (S.14.02)\n \tLiquidity reporting templates for financial stability reporting purposes (S.14.04/05) and changed duration measures of technical provisions (S.38.01) and a changed balance sheet template for groups (S.02.01) and new cells in S.39.01\n \tVariation analysis (S.29.05)\n \tIntra Group transaction (IGT) summary template (S.36.00)\n \tIGT P&L (S.36.05)\n \tRisk concentration templates (S.37.02, S.37.03)\n\nMajor changes/replacements of templates were proposed to the following templates:\n \tList of assets (S.06.02), a number of columns added.\n \tCross border reporting (replacing two templates: S.04.01 and S.05.02 by three new — more burdensome — templates: S.04.03/S.04.04/S.04.05, while maintaining S.12.02 and S.17.02)\n \tIntroducing Expected profits in future premiums (EPIFP) per Line of Business (LoB) for S.12.01 and S.17.01\n \tLife obligations analysis (S.14.01): many additional requirements\n \tVariation analysis: a changed template (S.29.03) and a new template (S.29.05)\n \tChanges for S.39.01 and S.36.04\n\nImprovements:\n \tThe removal of the template regarding look-through for Collective Investment Undertakings (CIU) (S.06.04)\n \tThe removal of two off balance sheet items templates (S.03.02/S.03.03) \n \tThe removal of S.06.01 - Summary of assets\n \tThe removal of S.08.02\n \tThe removal of S.40.01 and the yearly financial stability package","Public","Insurance Europe","Please note that following the comments received further changes have been introduced in the ITS amendments package aiming to reflect on the comments received and in having a balance package while also keeping the information important for the supervisory purposes. For individual templates resolutions please consult the individual comments."]
["Impact assessment",null,"Both","EIOPA’s impact assessment document shows an increase in costs and burdens both for national supervisory authorities (NSAs) (see p6) and other stakeholders. ","Public","Insurance Europe","Agree. EIOPA acknowledges that every change brings a cost. However, having a fit for purpose reporting is fundamental and in long run some of the changes are estimated to lead to a decrease. EIOPA further analysed the comments received and some additional changes are proposed in the package."]
["Reporting","S.06.04","Both","Decision not to go ahead with new template on look-through for CIU\n\nThe industry welcomes EIOPA’s proposal to no longer request this template and to keep the look-through template S.06.03 unchanged. The industry shares EIOPA’s view that the requested information is already available within the financial sector supervisory framework, so that EIOPA will only have to engage with the relevant authorities to ensure that both NCAs and EIOPA have access to that information in the future.\n\nAt the same time, the industry notes that the template could be requested on an ad-hoc basis by NSAs at all times, by using the originally envisaged template S.06.04, and that this should be only asked in clearly defined, absolutely necessary cases. \nAs EIOPA rightly states, the introduction of a regular template for only a temporary time horizon is not reasonable and too costly, due to the considerable implementation costs. This would definitely be the case for an ad hoc query. Therefore, it is important to take the proportionality principle into consideration in these cases. This should be reflected, for example, in the selection of the undertakings in scope and the level of detail of the data requested. The level of details envisaged in the draft of S.06.04 for detailed funds-look through appears in any case too high to be met with reasonable effort.\n\nRecommendation: NSAs should only ask for ad hoc reporting of this template in clearly defined, absolutely necessary cases. ","Public","Insurance Europe","Noted. "]
["Reporting","S.06.04","Both","New template for sustainable investments and climate change-related risks to investments\n\nThe industry acknowledges the need for specific climate-related reporting, in particular in relation to transition risk and physical risk. However, the reporting should not anticipate requirements which are already foreseen under the Taxonomy Regulation. Similarly, it should avoid duplication of information as much as possible, so that the burden of reporting is limited. Equally important, the industry urges EIOPA to consider the data availability for the proposals.  \n\nWith respect to taxonomy-aligned investments, the proposed indicator is inadequate. Firstly, it goes significantly beyond the scope and application timing of the delegated act (DA) on Article 8 of the Taxonomy Regulation as regulated by the Non-Financial Reporting Directive (NFRD). Secondly, it represents a simple duplication at group-level, unjustified by any prudential and consumer objectives. Thirdly, it does not appear relevant in terms of Solvency II objectives, as the Taxonomy is not a prudential tool. \n\nRecommendation on taxonomy-aligned investments: Insurers should only have to carry out sustainability reporting in one reporting format and with the same scope and timing. The Corporate Sustainability Reporting Directive (CSRD) is the preferred format and has the right scope and timing of reporting entities. EIOPA should not extend the scope of the DA on Article 8 of the Taxonomy for all Solvency II companies, even if thresholds would be applicable. In addition, EIOPA should consider the timing aspect in the context of other sustainability initiatives and wait for the reporting under Article 8 of the Taxonomy instead of forcing insurers to report taxonomy-alignment indicators before 2024, as envisaged in the CSRD.\n\nWith respect to the new indicators on physical and transition risks, a more in-depth and extensive assessment should be carried out to consider the following issues. Firstly, indicators for climate risk indicators should be consistent with ongoing policy work: eg principal adverse indicators under the Sustainable Finance Disclosure Regulation (SFDR) and potential sustainability-risk indicators under the CSRD. Secondly, the two indicators are new, meaning that it is unlikely that undertakings would compute comparable figures based on a consistent understanding and classification of risk and methodology for risk assessment, especially due to poor guidance and unclear requirements. Thirdly, the supervisory usefulness of these indicators is not clear as the indicators would not enable supervisors to truly identify economic activities exposed to physical/transition risks.\n\nRecommendation on indicators on physical and transition risks:  It is important that consistency of sustainability-related developments is achieved. EIOPA could determine the risk exposures of activities based on top-down methodologies (as opposed to leaving this to insurers’ individual methods). The information received from climate scenario analysis (following the recent proposals in the Solvency II review) would also provide important information for EIOPA to assess aggregate climate risk in the sector. ","Public","Insurance Europe","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\nOn the transition and physical risk KPI, the reporting of the KPI will inform supervisors' risk assessesment before it allows comparison with other undertakings. Good practices are starting to emerge and will consolidate over time. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for hte risk assessment.  The consultation and pilot exercise on the guidance (March 2022) is an opportunity to test and further discuss good practices."]
["Reporting","S.14.02","Both","Non-life business - policy and customer information\n\nThe template requests several datapoints for products split across 27 categories: this is inappropriate and will be burdensome and costly to implement, due to the need to make another product classification, in addition to the LOBs   and the internal classifications that are currently being used. \nIn addition, the template cannot be completed based on accounting data. This means that it will be more labour intensive, and as such very expensive to implement, support and maintain.  The industry finds it difficult to see the purpose of S.14.02, as insurers already report a lot of information at the LoB level, and the level of detail in the new template implies automation would hardly be possible.\n\nThe template requires information similar, but not identical to the new requirements under Article 8 of the Taxonomy Regulation to be disclosed via the NFRD, again with different timing and scope, causing unnecessary burden. Given the similarities of indicators, the framework for the CSRD should be the preferred way to report this type of information.\n\nIndeed, the proposed QRT S.14 on non-life will require a lot of work for almost no proven benefit for supervisors, policyholders, and the undertakings etc. \n\nRecommendation: EIOPA should not to go ahead with this template. However, if EIOPA decides to ask for information on non-life, a possible alternative could be an extension of existing templates to cover information for the largest total number of single risks by sum insured. ","Public","Insurance Europe","EIOPA is aware of the additional burden which this template may require and it has carefully assessed the information to limit requests. However, significant gaps exist on data on non-life insurance liabilities for products. These gaps were further highlighted with the pandemic and in relation to NatCat event. \n\nTo reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify. \n\nThe proportion of GWP covering climate related perils is also an input for the corporate reporting by non-life undertakings when reporting the KPI related to underwriting activities on the amount of environmentally  sustainable non-life underwriting, as per Art. 8 of the Taxonomy Regulation TR (see link below). EIOPA's proposal is to ask companies to report this also for other purposes, and prudentially relevant, as it can contribute to establishing insurance penetration rates for certain perils.  The information on risk-prevention measures is a type of information which non-life undertakings may report to establish compliance with the taxonomy climate adaptation objective under the Climate Delegated Act technical screening criteria. It is prudentially relevant to ask for this information, as it can help supporting the analysis of the undertaking’s underwriting strategy."]
["Reporting","S.14.03","Both","CYBER RISK\n\nWhile the industry acknowledges that information on underwritten cyber risks should be reported, the proposed template on cyber risk is overly detailed and will prove very burdensome for undertakings, while offering little obvious benefit for supervisors seeking to understand cyber insurance market trends. \n \nRecommendation: A threshold must be applied to the template so that undertakings with limited cyber portfolios are not faced with disproportionately burdensome reporting requirements, which would be likely to disincentivise offers of cover for cyber risk. Furthermore the level of detail of the template must also be reduced.","Public","insurance Europe","Noted. Please note that a threshold will apply to this template and was already identified in the 2020 review opinion (i.e. The template shall be subject to the application of a threshold based \non the following:\n- The sum of exposures of standalone cyber and policies with cyber \nas add-on coverage is greater than 25% of the overall non-life \nbusiness pursued by the undertaking \n OR \n- Number of policies that include cyber (i.e standalone cyber and/or \ncyber ad add-on policy) represent more than 3% of the total \nnumber of policies sold for the non-life busines)"]
["Reporting","S.22.01","Both","IMPACT OF LTG and TRANSITIONAL MEASURES\n\nWhile the industry supports the inclusion of the solvency capital ratio (SCR) and minimum capital ratio (MCR) ratios in the S.22.01 template, this template should not be public.\n\nIn addition, the industry strongly disagrees with EIOPA’s proposals to add further reporting requirements (eg impact of volatility adjustment set to zero on SCR ratio, impact of transitional on interest rate on SCR ratio) to the public version of this template (S.22.01.21). The volatility adjustment (VA) and matching adjustment (MA), are two key elements of the Solvency II Directive. Requiring companies to disclose the impact without MA or VA is confusing for policyholders and may give the impression that long-term guarantees measures might be a potentially movable or ancillary element of the framework that might at some point exist or not. The industry considers that such a message would be highly detrimental to all stakeholders. \n\nFurthermore, the proposed calculation of the impact for the ratios could be interpreted wrongly, as the ‘impact of transitionals on eligible own funds’ divided by the ‘impact of transitionals on SCR or MCR’ will not show the effect the transitionals have on the solvency ratio. ","Public","Insurance Europe","Noted. The proposal has been removed from the disclosure template."]
["Reporting","S.29.01","Both","VARIATION ANALYSIS\n\nEIOPA’s proposal on the QRT on variation analysis S.29 is unreasonable. During the consultation in 2019, EIOPA proposed to delete QRTs S.29.01-02 and replace QRTs S.29.03-04 with new QRTs S.29.05-06. EIOPA now proposes to keep current QRTs on demand of the supervisors. On top, EIOPA proposes to add an additional QRT for non-life. \n\nEIOPA also notes that “the sector was generally supportive of the QRT for non-life” (this is the new template S.29.05 but was previously consulted as S.29.06). However, the sector made those remarks under the impression that the other QRTs would be deleted and replaced.\n\nThe added value from these QRTs is not clear, and these QRTs were not used for discussions or other purposes by the supervisor. In addition, new and changed QRTs produce significant effort. The cost-benefit analysis is, therefore, conceivably unfavourable. \n\nRecommendation S.29.01-S.29.04 should remain unchanged. ","Public","Insurance Europe","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["LAC DT ","Do you agree with the proposed threshold?","Both","It is not apparent why DTLs are also looked at for determining the thresholds for reporting C0030 and C0040 on the balance sheet and not just DTAs.","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Do you agree with the proposed threshold?","Solo","Instead of the stated ratio of 10% between DTA and SCR as a threshold for reporting S.XX.02, would not a consistency with the 15% eligible Tier 3 equity (including DTA) own funds make more sense?","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.25.05","Both","EIOPA added 10 new templates for internal model companies (S.25.05, S.26.08-16). \n\nThese new templates require much more — and to a vast extent unnecessary — information which often does not align with the structure of individual internal models, necessitating estimations likely to lead to meaningless results. Supervisors already have extensive tools to ensure that internal models continue to generate prudent SCR numbers, and they are responsible for the original internal model approval, for approving any major change to that model, and will typically be notified of all other changes on a regular basis. Therefore, it is unclear which additional insights the new templates shall provide.  \n\nThe templates undermine the functioning supervisory dialogue between internal model firms and their NCAs by introducing arbitrary measures that are likely to invite unjustified comparisons. In particular, the industry opposes results from standardised reporting on internal models to be used as a basis for comparison between companies or as a basis for assessing the evolution of internal model capitalisation over time. \n\nRecommendation: For the abovementioned reasons, EIOPA should not proceed with the introduction of these templates.","Public","Insurance Europe","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting",null,"Group","GROUP REPORTING\n\nWhile the industry welcomes the alignment of the intragroup transaction templates (S.36) and the risk concentration templates (S.37) with the Financial Conglomerate Directive  (FICOD) templates, these changes to the templates should however not affect groups that are mainly insurance groups, and which do not form a financial conglomerate. ","Public","Insurance Europe","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insurance groups. Please also consider that the new S.37.01 template is less granular. Moreover, it is not desirable to have two totally different sets of templates for insurance group and financial conglomerates."]
["Financial stability guidelines",null,"Both","FINANCIAL STABILITY TEMPLATES:\n\nEIOPA has proposed several changes in this area, in particular the new requested liquidity templates (S.14.04/05) seem challenging to complete. \n \nRecommendation: The inclusion of any new detail in the Financial Stability QRTs is not supported by the industry.\n\n","Public","Insurance Europe","Noted. EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information in order to reduce the burden for undertakings: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category)."]
["Reporting",null,"Both","COMMENTS ON TEMPLATES NOT MENTIONED IN THE COVER NOTE\n \nA number of important changes to QRTs were not mentioned in EIOPA’s cover note. \n\nCross border templates, for which a set of three templates (S.04.03-05) is proposed in order to replace S.04.01/S.05.02. \n\nRecommendation: The industry suggests keeping the existing templates, and have no new S.04.03/04/05. If EIOPA decides to proceed with these changes, a threshold, for example, of 10% of gross written premium, is needed to avoid burdensome processes for insignificant cross border activities.\n\nList of assets (S.06.02) \nRecommendation: EIOPA should not to proceed with its proposals to expand this template, since it is already very extensive.\n\nLife obligations analysis (S.14.01)\nRecommendation: EIOPA should not to go ahead with the changes proposed to this template. ","Public","Insurance Europe","EIOPA would like to clarify that the Cover note covers only the areas not included in the QRT reports published at the end of 2020 as they were not finalised and additional work was needed.\nFollowing the comments received EIOPA has introduced a 5% GWP threshold to the S.04.05. On S.06.02 please refer to the individual templates. Further simplifications have been introduced to S.14.01."]
["Reporting","S.01.01","Both","The industry welcomes clearer instructions and field options as suggested.\n\nAnnex II of the ITS on reporting does not reflect the new deferred tax templates.  \n\nThere is inconsistency between the annotated template for the ring fenced fund variant, SR.01.01, and the ITS Annex II. In the template, there is still a row R0850. This should now be R0855 as per the changes indicated in Annex II.","Public","Insurance Europe","Note. The changes have been amended."]
["Reporting","S.01.02","Both","Proposed changes seem limited and are considered relevant.","Public","Insurance Europe","Noted"]
["Reporting","S.02.01","Both"," The industry welcomes clearer instructions as suggested, and the further changes seem to be reasonable.\n \nIn addition, EIOPA’s decision to not require ECB add-on fields for group QRTs is welcomed.","Public","Insurance Europe","Noted"]
["Reporting","S.02.02","Both"," While the industry does not disagree with the deletion of the assets part, the resulting impact of adding ‘currency’ to S.31.01 (Share of reinsurers (including Finite Reinsurance and SPV's)) is very onerous – please refer to comments on template S.31.01.\n \nThe industry welcomes the lowering of the threshold so that the template is not required if one single currency represents more than 80% of liabilities (previously the threshold was at 90%). However, for companies that already have incorporated these templates in their IT-systems, this change will not make much difference. ","Public","Insurance Europe","The comment is incomprehensible (Insurance Europe expectations are not clear), because on the one hand Insurance Europe indicates that the industry welcomes the lowering of the threshold and on the other hand informs that for companies that already have incorporated these templates in their IT-systems, this change will not make much difference. \nAdditionally, please see the appropriate EIOPA comment on the issue of adding a currency to the S.31.01 template. "]
["Reporting","S.03.01","Both","The industry takes note of the threshold introduced by EIOPA, although it is somewhat complex given that there are several items requested for calculation of the thresholds in the template.  \n \nThe industry welcomes the clearer instructions as suggested.","Public","Insurance Europe","EIOPA does not see the ground to simplify the threshold for S.03.01 template, as it has to include all relevant data reported in S.03.01. \nIn addition, ITS indicated exactly which items from S.03.01 should be included in the calculation of the threshold . EIOPA has also extended the observation period of the annual thresholds to release the reporting burden. Furthermore, it should be noted that the application of the threshold is not mandatory, ie. insurer may or may not use it."]
["Reporting","S.03.02","Both","The industry welcomes the removal of these templates. ","Public","Insurance Europe","Noted"]
["Reporting","S.03.03","Both","The industry welcomes the removal of these templates. ","Public","Insurance Europe","Noted"]
["Reporting","S.04.01","Solo","The industry suggests keeping the existing templates, and having no new S.04.03/04/05. \n\nAs stated in the response to the 2019 consultation, the industry disagrees with the replacement of S.04.01 and S.05.02. The S.04.03/04/05 QRTs are simply an amalgamation of S.04.01 and S.05.02, with added further requirements. Therefore, instead of reporting less, insurers are forced to incur the costs of deleting two QRTs and reporting the same information in three new QRTs, with no additional benefit for policyholders, companies or NSAs. Instead, it just increases the costs of implementation. \n\nParagraph 2.62 of EIOPA’s report on reporting and disclosure is incorrect: although the concept of “premiums” still exists under IFRS 17, that is not the same as earned and written premium, and neither are expected to be reported (or disclosed). Insisting that written premium should continue to be reported whilst stating that there are no additional costs for companies is therefore not credible.\n\nIf EIOPA decides to proceed with these changes, a threshold, for example 10% of gross written premium, is needed to avoid burdensome processes for insignificant cross border activities.\n\nFor cross-border reporting, EIOPA has introduced the need to provide the number of insured and number of contracts. This new information would be very burdensome to collect. Therefore, if EIOPA proceeds with requesting this information, a threshold should be implemented to allow for proportionality. As indicated in the previous paragraph, the threshold could be based on the written premium, eg 10%, which is also applicable to template S04.05.","Public","Insurance Europe","Supervisory experience since the introduction of Solvnecy II has shown that the existing templates do not provide sufficient information on location of risk to enable effective cross-border supervision.  Therefore, we do not consider retention of the existing templates as a viable option.\n\nThe observations on proportionality are noted.  It is not possible to introduce a threshold for template S.04.04 on location of underwriting (where information is required for cross-border statistical exchanges), but a threshold (e.g. 5% of GWP by LoB) could be considered for location of risk reporting in S.04.05."]
["Reporting","S.05.01","Both","The industry takes note of the deletion of the information related to ‘changes in other technical provisions’.\n\nParagraph 2.81 of EIOPA’s report on reporting and disclosure is incorrect: although the concept of “premiums” still exists under IFRS 17, that is not the same as earned and written premium. \n\nThe industry highlights that, with the introduction of IFRS17, this key figure will no longer be available for companies adhering to the new standard and will cause additional burden to keep old accounting standards in place in order to match supervisory needs while also reporting under the new ones. The P&L and balance sheets in scope of external audits will be only available under the new regime. \n\nThe industry is still waiting for EIOPA to provide an interpretation on bridging the Solvency II earned and written premiums and the actuals from IFRS 17. \nAgainst this background, the industry suggests introducing the possibility to align the “earned and written premiums” required in the S.05.01 template with the “insurance revenues” of IFRS-17, to avoid having an additional burden by keeping old accounting standards in place.","Public","Insurance Europe","EIOPA recognizes that IFRS17 will bring material changes in the recognition, valuation, presentation, disclosure of insurance contracts. However, the template S.05.01 will be kept as it is now even if IFRS insurers don´t report the written and earned premius in their accounting P&L. The main reason is to maintain consistent basis of reporting for all insurers (IFRS and local gaap users). Further reasons:\n1) Although linked to accounting, S.05.01 is not a P&L but simply requires some P&L related items to collect some volume measures to measure the performance trend and for market wide analysis;\n2) This approach is already in place today with regard to insurance contracts with no significant insurance risk, whose written premiums/claims paid are not accounted for in the IFRS P&L (according to IFRS 4) but are still to be reported in S.05.01;\n3) The mandatory disclosure of IFRS 17 on premiums/claims paid would allow undertakings to fill in S.05.01 following the current approach;\n4) Re(insurance) undertakings will have to keep track of written/earned premiums for MCR/SCR calculation.\n\nFor IFRS17 users: Written premius/claims paid will be reported in the notes to the financial statements. "]
["Reporting","S.05.02","Group","Please refer to comments in the paragraph on the new templates S.04.03/04/05.\n \nThis template is still requested in an annual basis for groups, which makes it more complicated for groups and the reconciliation between solo undertakings belonging to a group. ","Public","Insurance Europe","S.05.02 is kept at group level, acknowledging that it will be mainly based on consolidated accounts."]
["Reporting","S.06.01","Both","The industry welcomes the removal of this template. ","Public","Insurance Europe","Noted"]
["Reporting","S.06.02","Both","Many changes have been suggested to an already extensive template, which will be burdensome and costly to implement. Some of the new information required can hardly be considered to improve the template:\n \tApplicability of bail-in rules\n \tDetailed information on property\n \tEuropean Central Bank (ECB) add-on items (write-offs/write-downs and issue date)\n \tEIOPA has added a non-mandatory cell for fund number\n\nMoreover, this is a very good example of how requirements have become more complex over time. \n\nFurther changes include reporting of: regional government and local authority (RGLA) listed/non-listed, crypto-assets related investments information, Long term equity investments related information.\n\nEIOPA should therefore not proceed with its proposals to expand this template, since it is already very extensive.\n\nIn its December report on quantitative reporting templates, published together with the EIOPA opinion on the 2020 review para 2.130, EIOPA proposed that ‘changes in the reporting requirements regarding the list of assets should be balanced with use of complementary external financial information by NCAs’. EIOPA should therefore provide clarification and/or concrete examples as to what this entails.  \n\nThe industry welcomes clearer instructions, as it had suggested.","Public","Insurance Europe","Please note that changes introduced in the template follows the fit for purpose reporting and they are largely based on the QRT report published by EIOPA in December 2020. Following the comments recieved from the public consultation on the ITS amendments EIOPA further discussed the changes proposed and decided to drop the ECB add-on items.\n1. On concrete examples of changes not introduced due to the proposed balanced approach, EIOPA recalls that some examples were included in the consultation paper on reporting templates. \nOne of them was the need of information for computing cash flows arising from assets for deeper understanding of the LTG measures, additional use of RFR information and estimating profit participation (coupon of any respective bond,  the first call date, reference benchmark of floater, spread of the floater, Cap or Floor of the respective floater). EIOPA considered that these reporting items would be overly burdensome for undertakings to produce and EIOPA considered that some alternatives are possible and preferable, such the recourse to external sources.\n"]
["Reporting","S.06.02","Both","While the industry takes note of EIOPA’s suggestion not to move forward with the mandatory reporting of the item “fund number”, EIOPA allows for an NSA optionality in completing this field. This should be avoided in order to maintain comparability. Should NSAs wish to deviate from the default template, this should be done via a national specific template. \n\nThe industry would like to add the following detailed feedback on specific column definitions:\n\nC0120 (custodian): EIOPA states that, for assets where there is no custodian or when this item is not applicable, report “No custodian”. It is also stated that: Items C0110, C0120, C0121, C0122, C0130, C0140, C0141, C0160, C0200, C0230, C0270, C0280, C0310, C0370, and C0380 are not applicable to CIC 09 - Other investments. EIOPA is asked to clarify whether this implies an empty reporting for CIC-09 field C0120, or “No custodian”.\n\nC0140: Par amount for CIC=09 does not make much sense, since these might be very often assets not having a nominal value, eg commodities, artworks, cryptocurrencies\n\nC0190: “(unless required by the national supervisory authority).” Some companies are already struggling with requirements from local authorities, which are often inconsistent across the different EU countries. This leads often to a situation where the requirements cannot be implemented in the group-wide asset subledger or reporting system due to technical restrictions/inconsistencies and the reported solo data must be adjusted/enriched for group reporting. \n\nC0200 (issuer name): Since most CIU's are legally separated from the trustee, EIOPA is asked to clarify whether the issuer name should be the legal name of the fund: eg BlackRock Emerging Markets Local Bond Index Fund B or BlackRock Institutional Trust Company N.A.\n\nC0230: The enrichment to full NACE code leads to high additional effort without obvious significant benefit for the supervisor.","Public","Insurance Europe","2. On the fund number, there is no additional requirement. The objective is to clarify the applicability and provide the adequate framework for the current practice in some jurisdictions. EIOPA considers that suggesting the introduction of an additional (local) reporting requirment is increasing the reporting burden. \n\n3. C0120 (Custodian): EIOPA clarifies that the instructions for each single item prevail over the general intructions. In this item, \"No custodian\" shall be reported.\n\n4. C0140 (Par amount): Agreed. Aquisition value has more relevance for this CIC code. Instructions clarified.\n\n5. C0190 (Item title): Agreed. Will be made applicable to CIC 09 without exceptions.\n\n6. C0200 (Issuer name): As mentioned in the instructions, the company who can and is responsible for managing the fund is the one to be reported.\n\n7. C0230 (Issuer sector): This requirement was introduced in replace of additional ones targeting at getting information on climate risks exposures"]
["Reporting","S.06.02","Both","C0240 (issuer group): The definition of the issuer group has been unclear since the very beginning of Solvency II. The industry appreciates EIOPA’s attempt to clarify the definition, but it seems to be still very unprecise and not practical. The reason that sovereigns are excluded leads to an inconsistency with the calculation of the concentration risk, which leads to a situation where at least two ultimate parents have to be stored in the systems. It is also unclear what should be reported, if there is an ultimate parent indicated in the LEI database, but it is incorrect or not the highest controlling party in the group hierarchy. The (unclear) guidance with “at least as ultimate consolidation entity” makes it unclear whether, in the case of state-owned groups, the ultimate company (which would be again inconsistent with concentration risk) or the sovereign should be reported. \nThe definition of “government agency” is also unclear. Moreover, it is not clear which NSA is meant: ie would it be the NSA of the issuer or NSA of the insurance undertaking? This leads again to a possible reference to “expectation of the national supervisory authority in this area”, which leaves room for interpretation inconsistencies, which cannot be handled in group wide systems and reporting. The requirement that the bonds issued by the group members should be reported including the ultimate parent, but the bonds issued by the ultimate parent itself without this field being filled requires very complex data models and makes it hardly possible to find out the full exposure towards one group based on the information in S.06.02. \nSince most CIU's are legally separated from the trustee, EIOPA is asked to clarify whether the issuer group should be the legal name of the fund or the ultimate parent of the trustee.\n\nC0290 (CIC): It is unclear which CIC code must be used in case of crypto assets, because at this stage the guidance will not lead to a level playing field across European insurers. Furthermore, in the case of a bond with a different currency for the nominal and the accrual, EIOPA should clarify whether the currency of the nominal is leading for identifying CIC 18.","Public","Insurance Europe","\n8. C0240 (Issuer group)\na) “The industry appreciates EIOPA’s attempt to clarify the definition, but it seems to be still very unprecise and not practical” –  EIOPA would like to clarify that the ITS on reporting and disclosure do not provide definitions. The indicated cells provide instructions what is to be reported in this cell. As indicated EIOPA further clarified the instructions.\nb) “The reason that sovereigns are excluded leads to an inconsistency with the calculation of the concentration risk, which leads to a situation where at least two ultimate parents have to be stored in the systems” - Noted\nc) “It is also unclear what should be reported, if there is an ultimate parent indicated in the LEI database, but it is incorrect or not the highest controlling party in the group hierarchy” – What is asked to report is the name of the entity in the LEI database, regardless of it being classified there as the ultimate parent or not. It is the responsibility of the undertaking to identify the ultimate parent.\nd) “The requirement that the bonds issued by the group members should be reported including the ultimate parent, but the bonds issued by the ultimate parent itself without this field being filled requires very complex data models and makes it hardly possible to find out the full exposure towards one group based on the information in S.06.02” - Noted\n\n9. C0290 (CIC): The CIC is independent from the asset having or not a link to crypto-assets. The CIC should be the code attributed to the “basis” asset. If it is a (new) asset category, not classifiable under the existent CIC categories, then CIC 09 should be used. Item C0295 will complement its identification. The currency of the nominal should be used to classify the asset in the example.\n"]
["Reporting","S.06.02","Both","\n\n\nC0295: If an insurer would invest in a company building a platform based on blockchain, EIOPA should clarify whether it should complete this field: eg in the case of the company B3i.\n\nC0296: Guidance is lacking on how mixed-use properties should be treated (eg 40% hotel, 45% residential, 15% offices). Furthermore, it is unclear how land plots would have to be treated. \n\nC0297: It is unclear how to classify the assets. EIOPA should therefore clarify from which perspective it should be assessed as to whether a location is prime or not. It matters whether the decision to be prime is based on a local geographical perspective, regional or country perspective.\n\nC0298: EIOPA wants to know whether a property location is prime or not. As the group information is consolidated from other group members, the perspective can change. In fact, EIOPA should state that the perspective and decision whether the property is prime/non-prime should be unchanged.\n\nC0301: The new metric for long-term equity (YES/NO) is positioned in the wrong row. Whether a share is long-term equity is not a characteristic of a share, so this metric should not be in the row “information on assets” but rather in the row “information on positions held”. Otherwise, when the metric would be YES, that would imply that all the shares of one company (one ISIN) are held as long-term equity, which is not necessarily the case. Therefore, setting the metric in the row “information on positions held” leaves an insurance company the possibility to add multiple rows of one share, one for long-term equity (YES) and once not (NO) and then add the quantity (C0130) and the market value (C0170) for each row.","Public","Insurance Europe","\n10. C0295 (Crypto-assets) The comment to vague. An answer can only be provided with additional information.\n\n11. C0296 (Property type) Property type refers to the primary use of a commercial property. This item depends on the approach used in the ESRB recommendation. Please refer to ESRB Recommendation of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real estate data gaps (ESRB/2019/3), as mentioned in the instructions. It is not clear what “land plot” refers to.\n\n12. C0297 (Property location) Please refer to ESRB Recommendation of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real estate data gaps (ESRB/2019/3), as mentioned in the instructions.\n\n13. C0298 (Property location, groups): There should not be different perspectives as the property does not change\n\n14. C0301 (Long-term equity investment) Agreed, will be amended"]
["Reporting","S.06.03","Both","The industry welcomes the decision not to require S.06.04 to contain item by item information on the look through for collective investment undertakings or investments packaged as funds. \n\nThe industry welcomes EIOPA’s efforts to access ECB statistics on the assets and liabilities of investment funds and EIOPA’s decision to wait for the reviews of the Alternative Investment Fund Managers Directive (AIFMD) and Undertakings for Collective Investment in Transferable Securities Directives (UCITS) and the EC’s work on the supervisory data strategy. This would offer the possibility to have the information available in the future through another data flow. Attention should be paid to which data requirements resulting from S.06.03 on mutual funds — ie funds where the insurer usually has no influence on the investment strategy, which involve a lot of effort on side of the insurer — are redundant due to availability by other means.  \n\nFurther detailed comments:\nC0040 (Country of issue): EIOPA is asked to clarify whether this is a mandatory field for categories 8 and 9, as reported in C0030.","Public","Insurance Europe","Noted. The field C0040 - Country of issue is a mandatory field for categories 8 and 9 as reported in C0030."]
["Reporting","S.06.04","Both","The industry acknowledges the need for specific climate related reporting, in particular in relation to transition risk and physical risk. However, the reporting should not anticipate requirements which are already foreseen under the Taxonomy Regulation. Similarly, it should avoid duplication of information as much as possible, so that the burden of reporting is limited. Equally important, the industry urges to consider the data availability for the proposals. \n\nFocusing on the first requirement to report on taxonomy-aligned investments as defined in Article 8 of the Taxonomy Regulation, the industry notes that is inconsistent and inadequate for the following reasons:\n1. As the new requirement is at solo-level, it goes significantly beyond the scope of Article 8 of the Taxonomy Regulation as regulated by the NFRD (and in the future by the CSRD). EIOPA’s proposals on Solvency II should not go against the decisions already taken by co-legislators on the scope (ie the CSRD scope is decisive for consistency and proportionality reasons) and the timing of the proposal (as financial undertakings will start disclosing taxonomy alignment of investments only in 2024). EIOPA’s proposals introduce additional complexity, without considering insurers’ information and time requirements for this reporting. For companies not subject to the NFRD/CSRD, there should be no new requirement for reporting this information. \n2. The proposal will represent a duplication at group-level, which is not justified under prudential and consumer objectives. It comes with inconsistencies and additional complexity, while counteracting the file-only-once principle. If reporting this KPI is deemed as being absolutely necessary in the QRT (beyond entity-level taxonomy information from DA on Article 8 and from the SFDR templates), then insurers should be able to comply with this requirement via cross-referencing. \n3. The new KPI does not appear relevant to the objectives of Solvency II. The Taxonomy has not been designed as a prudential tool. In fact, the Taxonomy is limited in scope at this stage and expected to significantly change over time. Therefore, additional solo-level information on taxonomy-aligned investments would not bring about any added value. Relevance for Solvency II could be reassessed at a later stage, when the Taxonomy has further evolved and provides a more comprehensive overview on sustainable investments (which is not yet the case). \n\nRecommendation on taxonomy-aligned investments: Insurers should only have to carry out sustainability reporting in one reporting format and with the same scope and timing. From the industry’s point of view, the CSRD is the preferred format and has the right scope of reporting entities. With the ongoing revision of the NFRD, more insurers will have to report on sustainability KPIs. Therefore, EIOPA should refrain from extending the duty to all Solvency II companies, even if thresholds would be applicable. Furthermore, EIOPA should consider the timing aspect in the context of the initiatives of the EC sustainability agenda and wait for the reporting under Article 8 of the Taxonomy, when insurers will have to report the KPI starting from 2024 (insurers in scope of the CSRD should not be forced to report this KPI at an earlier stage). \n\nWith respect to the new indicators on physical and transition risks, the industry notes a more in-depth and extensive assessment should be carried out to consider:\n1. Consistency of sustainability-related developments. Indicators for climate risk indicators should be consistent with ongoing policy work. Firstly, current entity level indicators for principal adverse indicators — including risk-related exposures — are under development in the context of the Level 2 SFRD and will be further defined by the EC, as planned in the Renewed Sustainable Finance Strategy. Secondly, further sustainability indicators, likely covering risk considerations, are likely to be developed in the context of the CSRD. \n2. The fact that, as proposed, the two indicators are new. Without further coherent guidance across sectors (and more generally with a view to the overall regulatory framework), it is unlikely that undertakings would compute comparable figures based on a consistent understanding and classification of risk and methodology for risk assessment. Even if, for example, transition risks are taken into account in the risk management of the companies in the known risk types, this does not mean that key figures can also be calculated without further effort. In terms of the current proposal, for example, it is also not clear: \n How the new requirements should account for the way economic variables are evolving, resulting in an economic value. These indicators are influenced by several variables and their evolution does not imply that an insurer will be more or less sustainable. This could lead to wrong information and conclusions.\n How the information/KPIs for financial conglomerates requested by the different European Supervisory Authorities (ESAs) should be aggregated (eg how would the KPI from an asset manager be aggregated into the group KPIs). \n How insurers should address and reconcile different accounting and prudential perspectives. The European legislation mentioned by EIOPA is based on an accounting perspective, but EIOPA refers to the list of assets based on the economic value and methodology of Solvency II in the requested data fields. These differences could result in the same KPI having different values.\n Whether the information is to be derived from the S.02 (balance sheet) or based on the look through balance sheet.\n How insurers should report the longitude: eg for indirect property and property in investment funds.\n3. It is not clear whether these indicators would be truly useful from the supervisory point of view as the indication of a figure in S.06.04 is not sufficient to enable the supervisory authority to identify economic activities exposed to physical/transition risks. Further required guidance on such risks should not be considered in isolation for the purpose of Solvency II reporting only, as those risks are relevant across sectors and more generally with view to the overall regulatory framework.\n\nRecommendation on indicators on physical and transition risks: As EIOPA has already identified relevant economic activities in its previous work on sensitivity analysis of climate-change related transition risks, it would then still have the possibility to determine the exposures of activities (as opposed to leaving this to insurers’ individual methods) based on top-down methodologies: eg by building a shared understanding of which economic activities should be considered for these exposures (using NACE codes in S.06.02). The information received from climate scenario analysis (following the recent proposals in the Solvency II review) would also provide important information for EIOPA to assess aggregate climate risk in the sector. \n\n\n","Public","Insurance Europe","EIOPA confirms that the information is to be derived from the S.02.01.\n\nAs to the methodologies for reporting the physical and transition risk, building on previous work as referred to in the comment,  EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for the risk assessment. The reporting of the KPI will inform supervisors' risk assessesment before it allows comparison with other undertakings. Good practices are starting to emerge and will consolidate over time. We acknowledge that the sustainability risks are occuring in an economic environment and influenced by several variables, which will reflect in the risk assessment."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?",null," *If the undertaking is not subject for reporting in NFRD/CSRD, it should not be required to report this information on sustainable investments in the QRT. \n *The reporting requirements need to be in line with NFRD/CSRD and there should be no increased burden through QRT-reporting. Thus, the undertakings should only report information on sustainable investments if subject to NFRD/CSRD and the thresholds for reporting should be the same. For undertakings in the scope of the NFRD/CSRD which provide Taxonomy reporting at group-level, there should be no (additional) reporting requirements at solo-level.\n *NFRD/CSRD contain some conditions and reliefs for smaller undertakings. The same proportionality should apply in Solvency II QRT reporting. It is also of importance that the same definitions of specific data in the frameworks are the same. In addition, principles for aggregation to group level should be harmonized with NFRD/CSRD. ","Public","Insurance Europe","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ",null," \tYes, it is appropriate to implement a materiality threshold for the KPIs.  However, it is not clear whether these indicators would be truly useful from the supervisory point of view.","Public","Insurance Europe","Noted. EIOPA tends to agree that tresholds for the proposed KPIs may be of limited supervisory value."]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?",null,"Yes, it is appropriate to implement a materiality threshold for the KPIs. However, it is not clear whether these indicators would be truly useful from the supervisory point of view.","Public","Insurance Europe","Noted. EIOPA tends to agree that  tresholds for the proposed KPIs may be of limited supervisory value."]
["Reporting","S.07.01","Both"," The industry is disappointed that neither the current threshold nor the template itself has been improved. Template S.07.01 requires very detailed data for some specific instruments that, in many cases, has to be provided by specialized data providers. While the industry agrees with EIOPA that structured products can entail significant risks, it highlights that it is not necessarily the case. Furthermore, it is questionable whether the detailed data, which has to be reported via S.07.01 gives the NCAs relevant additional insights. \n \nTherefore, the industry is of the opinion that a simplification of this template, by deleting the items C120 to C190 — as discussed in the consultation paper — would be adequate.","Public","Insurance Europe","EIOPA disagres and keeps the template as it is. EIOPA further discussed the possibility to improve the threshold . The proposed threshold by the industry - s defined in Annex IV — Asset Categories of this Regulation and the sum of item C0010/R0070 and C0010/R0220 of template S.02.01,– is higher than 10% has been analysed. EIOPa consider current threshold to be adequate and will keep it.EIOPA disagrees with the deletion of items C120 to C190. "]
["Reporting","S.08.01","Both","The deletion of column (delta) is positive.\n\nThe column notional amount in original currency seems to be relevant. \n\nThe other columns should not be implemented (unique transaction identifier, currency of price) as they do not add any relevant information.\n\nIn addition, instead of using the information available in EMIR reporting, EIOPA is asking companies to report the same level of information (the new fields seem to just replace what is proposed to be deleted) and merely provide a European market infrastructure regulation (EMIR) identifier. \n\nC0340 (Counterparty group code) and C0270 (Counterparty code): Is it correct to say that C0270 must be filled out for all derivatives and C0340 only for OTC derivatives.\n\nC0371 (Currency of price): For insurers reporting S.08.01 in Euro, suppose a cross-currency swap has been concluded between USD and GBP. EIOPA should clarify what is to be reported in this field for this specific case. \n\nC0060: There should be no NSA optionality in the standard QRT templates.","Public","Insurance Europe","EIOPA explained the reasoning behind the options taken regarding how and when to take into account EMIR data, in paragraphs 2.168 to 2.176 of the Report on quantitative reporting templates (EIOPA-BoS-20/754, 17/12/2020), including the link between SII template and EMIR database. \n\n1) C0340 (Counterparty group code) and C0270 (Counterparty code). Yes, it is correct. C0340 is only required for OTC as these are the cases where it is relevant to access the risk at group level.\n\n2) C0371 (Currency of price). It is the currency of the amount being exchanged. For example, if the undertaking is paying (or receiving) GBP for the notional amount (whatever it is – USD, EUR, …), the currency of the price is GBP. The currency of the notional amount (C0370) is, in the example, USD. \n\n3) C0060. EIOPA sees the point of the request and despite that would like to have more harmonisation in the reporting NSAs can request additional information regardless whether it is explicitly mentioned in the instructions or not. In addition this isn't a new requirement and the change in the instructions aims to clarify it's applicability, that is, to clarify what was the meaning of \"not mandatory\"."]
["Reporting","S.08.02","Both","The industry welcomes the proposal to delete this template. ","Public","Insurance Europe","Noted."]
["Reporting","S.09.01","Both","C0050 — There should be no NSA optionality in the standard QRT templates. ","Public","Insurance Europe","This isn't a new requirement and the change in the instructions aims to clarify it's applicability, that is, to clarify what was the meaning of \"not mandatory\". In addition EIOPA would like to clarify that NSAs can request additional information regardless whether it is explicitly mentioned in the instructions or not. "]
["Reporting","S.10.01","Both"," The industry is disappointed that the threshold for this template was not improved. According to field C070 in template S.06.02 the indication of the fund number is not mandatory, unless otherwise required by the national supervisory authority. This should also apply to template S.10.01, so field C050 should be adapted accordingly. The requirements of the templates must be consistent in this respect.  \n \nC0040 — There should be no NSA optionality in the standard QRT templates.","Public","Insurance Europe","Agree. Amended"]
["Reporting","S.11.01","Both","The industry welcomes the introduction of a threshold for this template. \n\nHowever, EIOPA-BoS-21-296 states: ‘1.8. Template S.11.01 - Assets held as collateral - the current threshold and the impact of the different options have been analysed but decided to keep as of today’. In the current situation there is no threshold. While 2450_ITS_reporting_consolidated_AnnexII_solo instructions_S.01_to_S.13.pdf states: ‘This template should be only reported annually when the ratio of the value of assets held as collateral to total balance sheet exceeds 10%.’ It seems that the two instructions do not match. EIOPA is requested to clarify.","Public","Insurance Europe","Noted. The Impact assessment has been clarified."]
["LAC DT ","Other","Solo","It is unclear whether QRTs S.XX.01-03 are to be reported only by solo companies or also by the group.","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.12.02","Solo","While the industry welcomes the decision to keep this template unchanged, it refers EIOPA to the its comments on the new templates S.04.03/04/05, that note that the overall reporting burden for cross border requirements will increase substantially. \n\nThe clarification of the definition of threshold regarding the negative technical provisions is welcomed. ","Public","Insurance Europe","Please refer to the comments on S04.03/04/05"]
["LAC DT ","Other","Solo","Why is the data in S.XX.02 and S.XX.03 asked 10 years into the future, even though we are only allowed to use 5-year planning when calculating the impairment test?","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.14.01","Solo","Despite strong concerns expressed by the industry in response to the reporting consultation back in 2019, many changes have been suggested in this template, which will be burdensome and costly to implement.\n\nOn top of the extensive changes already announced in 2019, EIOPA suggests adding the following information on:\n \t“Expected future commissions” differentiated also for new contracts. \n \tA yearly interest rate guarantee for the reporting year.\n \tExit conditions of a product.\n \tOn the amount on which the interest rate is guaranteed.\n\nThe only justification EIOPA is providing is that this template is extensively used by supervisors.\nEIOPA should not go ahead with the changes proposed to this template. \n\nThe industry notes the following with regard to this template:\n*Premiums written per product are to be further broken down into additional three dimensions: at the level of single premiums/current premiums, at the level of sales channels (direct/via credit institutions/other) and at the level of portfolio/new business. Such a granular breakdown is currently not available, and could only be delivered at great expense, if at all. In fact, it is questionable whether the breakdown for premium and commissions in three dimensions is relevant for prudential reasons. The risk of a product is not affected by its sales channel or whether it is new business, single premium/current premium\n*Information on commissions paid at product level and a required breakdown of commissions into existing and new contracts are currently not available. This information could only be obtained with additional effort, and implementation is not feasible at present. The level of granularity also implies insures will be forced to set arbitrary assumptions in the allocations of expenses which are recognised at a higher level than the product level. Against this background, this requirement is not acceptable. The reasons for EIOPA’s decision to introduce a sales view for many templates is unclear. Many new data queries are not possible because data with this level of granularity is not available in the companies. It would be appreciated if EIOPA could further explain the supervisory purpose of these new requirements.\n*Reporting on the expected future premiums of new contracts in the FY is burdensome. Implementing the reporting requirement involves a great deal of effort, as additional model points and projection calculations would be necessary.\n *In general, the new information cannot be completed based on accounting data – information will be very  labour intensive to collect, and as such the changes to this template will be very expensive to implementand and to maintain.\n*In the log files, EIOPA states: \"All information shall be reported by product including the table on product portfolio. Reporting by fund number is not mandatory, unless otherwise required by the national supervisory authority.” The industry notes that any additional requirements set by NSA's should be included in national QRTs and should not be included in the general templates to be used by all insurers across Europe.","Public","Insurance Europe","EIOPA notes that the new information required goes along with implementation efforts. Though, the additional information is considered necessary and should - at least in parts - already be available. E.g. the information on the yearly interest rate guarantee should be known to each undertaking, the same holds for the amount on which the interest rate is guaranteed, which may even be a local statutory figure.  Also, approximations are allowed for some of the figures required to reduce the burden. \n\nIn view of the concerns expressed and the implementation effort required, EIOPA however decided to limit the set of newly introduced information:\n-  Information on the amount of  premiums written by distribution channels is essential to allow for an assessment of relevance of sales channels. Currently availble soruce of information on distribution channels are limited. The added information allows to determine the business models used to commercialise certain products and possible concentration risks. EIOPA notes that the new information required may be a burden. However this information is deemed necessary to assess concentration risks and determine the changing distribution patterns - i.e., more reliance on own channels. Moreover, information on written premium by distribuition channels should be already available to insurance undertakings as they should know the channels through which they are writing premium/selling certain products to monitor risks arising from distribution. This information for several Member States and in a more granular manner (i.e., more granulirity in terms of distribution channels) is published annually by InsuranceEurope itself showing that for several markets this information is available. Aware of the possible burden to undertakings, to strike a balance between supervisory needs and and limiting the reporting burden EIOPA has reduced the number of new cells by reducing the granularity required on premiums written by distribution channel, no longer requiring a split between regular and single premiums.  \n- Commissions represent a key information on products being extensively used for understanding insurance undertakings' business model and sales strategy, including to identify whether the possible higher commissions could raise solvency issues and/or increase mis-selling which in turn could lead to solvency risks. This includes information on expected future commissions to allow an assessment of the commissions paid during the whole life-time of the contract. EIOPA also notes the burden to the industry but also notes that the information on commissions paid during the year should be already available as it should be calcualted for both pricing purpose and when commissions are paid to intermediaries. The information on expected future commissions is part of the calculation of the best estimate liabilities, approximations can be used to determine the necessary information. To strike the balance between supervisory needs and possible burden to the industry EIOPA dropped the breakdown between commissions for new contracts for single and regular premium products and no longer requires the information on expected future commissions for new contracts.\n- Information on expected future premiums is important to assess the volume of the business across the whole life-time of the contract and provide a volume measure to which the commissions are compared (i.e. to determine a sensible commission rate). We acknowledge the additional burden on undertakings and the necessity for approximations and simplifications. Also, to reduce the burden, the information does no longer be separately provided for new business.\n- Further, to reduce the burden the information on number of surrenders during the year was simplified and no differentiation for new contracts is required.\n"]
["Reporting","S.14.02","Both","The template requests several datapoints for products split across 27 categories, which is deemed inappropriate and will be burdensome and costly to implement. This would introduce a new, third categorisation to Solvency II, on top of the existing two categorisations systems: lines of business and branches. It would be burdensome to make another product classification, in addition to the LoBs, branches and internal classifications that are currently being used. The industry strongly takes the view that this template should not be introduced for the following reasons:\n\nThe proposed QRT S.14.02 non-life will require a lot of work and cause significant excess costs for almost no added benefit. There also appears to be significant overlap with aspects of data reported on certain other templates, such as S.04, S.05, S.20, S.21.01. The industry finds it difficult to see the purpose of S.14.02 as it already reports a lot of information at the LoB level, and the level of detail in the new template implies automation would hardly be possible.\n\nIn fact, the QRT is not needed for prudential reasons and Solvency II reporting should remain limited to prudential reporting only. The insurance sector deems it inappropriate to use QRTs for reasons other than prudential reporting, and thus not for conduct of business/protection purposes. The resources preparing the QRTs are not familiar with the information requested.\n\nSome member states, such as Belgium, are already reporting information on branches to their NSA. It is noted that the current classes are defined in annex I of the Solvency II Directive and are used for SCR purposes. The new categorisation system however has no legal basis. As such, any new reporting based on different categories will be burdensome to implement. The new QRT will not replace the existing national non-life statistics in Belgium and it is expected that this will be the case in other member states as well. That is partly due to the fact that the requested information in this QRT is limited to premium, commission, number of contracts and does not contain prudential information such as the technical provisions. Also, in the first ten years or so, the new categorisation system will not be useful as it lacks the required history for proper analysis. \n\nIn addition, this template cannot be completed based on accounting data (in contrast to the national reporting in some member states, such as Belgium) meaning that it will be labour intensive, and as such very expensive to implement, support and maintain this template.  \nIndeed, the template contains detailed inventories by product category and sales channel supplemented with information on certain costs and the year's claims payments. In practice, this means that all insurance products in the company must be reviewed and categorised, and this has to be continued every year thereafter. The company then needs to do the same for each new product. Furthermore, it must be decided whether the course of the product is affected by climate-related elements. Ultimately, completing and maintaining this template will be a project that requires ongoing maintenance and a close relationship with the product development department. The fact that data comes from many different sources with vastly different levels of detail is adding to the template’s complexity. \n\nIf EIOPA decides to require information on non-life, a possible alternative to be considered could be an extension of existing templates to cover information for the largest total number of single risks by sum insured. \n\nIn addition, to monitor climate risk, EIOPA has proposed to introduce two new cells:\n \tProportion of premiums covering climate-related perils (0-100).\n \tAllowance for climate-risk prevention measures in product design (Y/N).\n\nFurthermore, it must be assessed whether the course of the product is affected by climate-related elements. Ultimately, completing and maintaining this template will be a project that requires ongoing maintenance and a close relationship with the product development department. The fact that data comes from many different sources with different levels of detail adds to the template’s complexity. \nThe template requires information similar, but not identical to the new requirements under Article 8 of the Taxonomy Regulation to be disclosed via the NFRD, again with different timing and scope, causing unnecessary burden. From the industry’s point of view and given the similarities of indicators, the scope of the CSRD should be used to report on this type of information and content of the Taxonomy DA on Article 8 to guide the disclosures. This is in line with consistency and proportionality considerations.\nIt is also questionable how insurance companies can calculate the proportion and allowance since it is unclear to which extent risks are affected by climate change. Climate change will likely increase the severity and frequency of certain events. As EIOPA rightfully concluded in its methodological paper on potential inclusion of climate change in the Nat Cat standard formula, it is not an easy feat to estimate such an increase, even for highly specialised reinsurance companies and for EIOPA, let alone individual insurance companies. \n\nFurther detailed comments:\n*The product categories 15, 24, 25 should not be separated. The industry would ask EIOPA to clarify where “risk class 13, subclass III” is defined.\n *C0032: EIOPA is requested to clarify what the definition is of a product (within the same product category), what the granularity is and whether two supplementary health care policies from the same brand, but with increasing coverage would be considered as two different products. And whether two basic health care policies with the same coverage, but with different names within the same entity would be considered as two different products. \n*C0110: EIOPA is asked to clarify the definition of “country where the contract was entered into\". For S.04 versions with “the country in which the risk is situated\" and “location of underwriting” exist, and EIOPA is asked to clarify whether these are all different or whether they should first be aligned with one of the others.\n *EIOPA introduces classes of insurance which are not identified as such in the IT-systems of the insurers. For example, asking details on \"gadget insurance\", while it can be questioned how significant this type of insurance is in reality, and why this granular information needed. EIOPA should be aware that the administrative burden of additionally administrating this kind of information is tremendous and this information will only be used for supervisory reporting business.\n*In the Logfile, EIOPA refers to a TEG final report on the EU Taxonomy. It must be stressed, however, that the work of the TEG does not have legal basis. Therefore, it is also not clear whether the presented table will be a legal requirement categorisation.\n","Public","Insurance Europe","EIOPA is aware of the additional burden which this template may require and it has carefully assessed the information to limit requests. However, significant gaps exist on data on non-life insurance liabilities for products. These gaps were further highlighted with the pandemic and in relation to NatCat event. \n\nTo reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n\n\nIn relation to the questions being raised as to the prudential need of having a product by product reporting for non-life insurance products, it is important to note that the information is limited and it will help NCAs in better understanding product structures and issues around products which could have a prudential re-percussion. In particular taking into account that it is difficult to have visibilty on the product categories specified given they either fall under multiple lines of business or multiple products fall under the same line of business. Moreover, recent crisis events highlighted the supervisory needs to have an overview of the number of products and their features rather than just collecting information a line of business basis. For example, because of information being collected on an insufficient level of granularity, when the COVID-19 crisis materialized many supervisors had not visibility of how many business interruption or travel insurance products were being sold and which undertakings were mostly exposed limiting the possibility to assess the prudential of the crisis. Similarly, looking at the increased risk of climatic catastrophic events it is important that supervisors have information on which products cover (and to what extent) climate change related risks to then assess possible prudential impact. \n\nMoreover, the annual collection of product related information would limit ad hoc requests from supervisors which are often burdensome and uncoordinated. It would also limit the risks that new reporting requirements are being developed at the national level to fill the gap on product related information. \n"]
["Reporting","S.14.03","Both","As stated in response to the 2019 consultation on supervisory reporting and public disclosure, Insurance Europe acknowledges that there is merit in including cyber risks in the scope of the Solvency II reporting package, in order to better understand this emerging risk. The industry also agrees that information on underwritten cyber risks should be reported on an annual basis.\n\nHowever, the industry does not agree that EIOPA’s objective of a ‘deeper understanding of cyber risk’, as indicated in the 2020 Solvency II Opinion, which necessitates the detail of reporting envisaged by the draft template. Furthermore, it is questionable whether companies can report on cyber risks with data of the level of granularity requested by EIOPA in the draft template. This was indicated by the results of the 2018 stress test on cyber, during which participating companies had difficulties providing the requested data, a point acknowledged by EIOPA in its report on QRTs as part of the December 2020 Opinion on the Solvency II review. The industry also questions whether certain requested information, such as target market details and cyber coverage in the product category, would add value to the supervisory efforts to understand the cyber insurance market. Reporting requirements which generate superfluous data and offer no useful insights should be avoided at all costs as they are inherently disproportionate.\n\nSimilarly, the industry is concerned that the draft template, as it stands, would significantly increase the burden on a significant number of entities, especially those with only a limited cyber insurance portfolio. While the EU cyber insurance market is growing, it is still at an early stage of development, representing only a very small fraction of non-life premiums in EU markets. Requiring companies to provide detailed reports on their cyber insurance business, whatever its size, would therefore be disproportionately burdensome — both in terms of costs and resources — considering the size of the market. This is especially true given that the information requested in the draft cyber template is more detailed than what is requested for other, more mature, non-life product categories, for example property, as reported under [S.21.02]. Therefore, at this point in time, Insurance Europe opposes the introduction of a template for reporting cyber risks with the level of detail proposed in the consultation paper, especially when no threshold is applied. The introduction of a detailed template on underwritten cyber risks should be delayed until such a time as when the cyber insurance market grows to a size and market share that justifies such reporting. \n\nThe industry also asks for clarification on how information reported under the QRT will be made available to companies: ie whether through a dedicated database on cyber risks, a supervisory report, or other means. The cyber QRT will provide EIOPA with valuable insights into the European cyber insurance market — insights that hold equal value for companies — and it is vital that these insights are shared with the industry in return for the considerable administrative burden that will be associated with the introduction of the new template. \n\nIn light of this, Insurance Europe proposes the following comments on the draft template:\n\nReporting should be subject to the principle of proportionality based on the size and complexity of exposures, translating into reduced reporting for undertakings with simple, non-complex risk profiles. Therefore, Insurance Europe regrets that EIOPA no longer proposes to apply a threshold to the cyber reporting template (as was included in the report on QRTs accompanying the Opinion on the 2020 review). Given the level of detail contained in the draft template, only companies for which cyber is a significant line of business should be required to report on their business. With this in mind, EIOPA should adopt a reporting threshold by reference to gross written premiums set at least at 10% of business written to ensure reporting requirements apply only to market participants with a larger presence in the cyber insurance market. Detailed reporting requirements which are not subject to a threshold are also likely to disincentivise new entrants into the cyber insurance market, standing contrary to EIOPA’s stated aim of encouraging the growth of the market. \n\nCyber risk products should be clearly defined: eg as insurance policies that cover loss caused by an information security breach. An information security breach means an impairment of the availability, integrity, or confidentiality of electronic data of the policyholder or of information processing systems which are being used by the policyholder. \n\nReporting should be limited to affirmative cyber risk products.\n\nReporting should also be limited to direct business (as in the new versions of templates S.14.01 and S.14.02), as corresponding figures from active reinsurance business cannot be adequately reported or would not be comparable. For example: the number of claims for reinsurance quotas is not available, and claims payments are only available for pure cyber quotas, but not for mixed contracts. International standards for a uniform taxonomy for recording exposure and damage data must be taken into account. \n\nThe requirement to include information on the target market (C0020) is excessive and it is unlikely to add any value to the supervisory analysis. \n\nThe draft template requires product categories to be reported separately (C0030): however, cyber insurance products are generally combinations of different product categories and, as such, are difficult to unbundle and separate. Instead, companies should only be required to report on which of the three categories of coverage (first party loss, third party loss, or costs and related services) are included in a product.\n\nThe draft template requires cyber as add-on coverage to be reported (C0040): however, only standalone cyber products should be included in the scope of reporting. Given the wide variety in the type of add-on cyber coverages, which can range from single clauses to extensive cyber add-ons, it is not feasible to report on cyber as add-on coverage without such reporting amounting to a considerable burden on companies. It is also not immediately obvious what value this type of information would add to a cyber insurance market analysis.\n\nAs it currently stands, the reporting line ‘description of risks included in the coverage (C0060)’ is overly detailed and it is unlikely that it will be possible for many companies to report such information in practice. As a point of comparison, the existing QRT on non-life underwriting risk [S.21.02] only requires the 20 biggest single underwriting risks to be listed, a more proportionate approach. \n\nA threshold should be applied to the reporting of currency (C0070).\n\nA cyber product, as a combination of different product categories, usually has several insured sums as well as possible additional sub-limits. These different sums cannot be easily aggregated, and it is therefore unlikely that it will be possible for many companies to report their sum(s) insured (C0080).\n\nInsurers usually have a combination of different reinsurance coverages (quota share, XL…) that cannot be easily aggregated. It is therefore also unlikely that it will be possible for many companies to report their sum(s) reinsured (C0100).\n\nThe requirement to provide information on the number of claims (C0110; C0130) is also excessive with no evident value that this information would offer.  \n\nThe requirement to report the number of technical provisions (C0140) should be replaced by the reporting of case-by-case reserves, as the former does not exist in such granularity at product level and would have to be allocated down to the cyber product categories, leading to spurious degrees of accuracy. ","Public","Insurance Europe","EIOPA acknowledges the difficulties in being initialy able to provide the requested information, but doesn not see as a valid justification the fact that undertakings might not be able to derive the requested information from the data on underwritten policies. information on lines of business impacted, premiums and technical provsions represent the basic information that constitutes the basis for good risk management practices. Furthermore, delaying the application of the reporting until the market further develops might not only make things more difficult, but also compromise the necessary monitoring of market development for such emerging risks. With regard to proportionality, thresholds have been established to the template in line with the ones already included in the 2020 review opinion. On information sharing and feedback to the market, EIOPA will embed this objective in the implementation of the Cyber Underwriting Strategy in the context of EIOPA being a facilitator in the market development for cyber risks.\n"]
["Reporting","S.15.01","Both","The insurance industry welcomes the proposal to remove these templates.","Public","Insurance Europe","Noted"]
["Reporting","S.15.02","Both","The insurance industry welcomes the proposal to remove these templates. ","Public","Insurance Europe","Noted"]
["Reporting","S.16.01","Solo","The industry welcomes clearer instructions as suggested.","Public","Insurance Europe","Noted"]
["LAC DT ","Other","Both","It is unclear whether all New LACDT-QRTs are to be reported quarterly or annually. ","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Other","Both","For LACDT-QRT S.02.01.01, a more detailed explanation of colums C0030 and C0040 is required.","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ",null,"Both","–  we agree with the Insurance Europe that the new templates should not be required (they are very burdensome). “In many cases, the QRT asks for a level of detail that may not present a clear added value for LAC DT calculation”.\nMoreover we suggest a change of the threshold definition for report S.02.01.01 (different than proposed by Insurance Europe), i.e. from: \"C0030 and C0040 should be reported only where the amount of net deferred tax assets or the amount of net deferred tax liabilities are higher than 10% of the SCR\" to: \"C0030 and C0040 should be reported only where the amount of net deferred tax assets is higher than 10% of the SCR\", as a significant deferred tax liability is safe from the SCR tax loss settlement perspective, therefore, only large deferred tax asset in pre-stress situation should be burdened with additional reporting.\n","Public","Polish Chamber of Insurance  ","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.19.01","Solo","The industry welcomes clearer instructions as suggested.\n\nProposed changes will mean a reduction in the template reporting requirement, which is positive. \n\nWhile the industry takes note of the improved threshold, it deems an 80% threshold to be appropriate. The industry highlights that with the proposed 90% threshold, smaller LoBs would have to be. ","Public","Insurance Europe","Noted. However, as regards to the threshold EIOPA disagrees of reducing it to 80% and keeps the 90% as publicly consulted."]
["Reporting","S.20.01","Solo","While the industry takes note of the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions, it believes a threshold of 80% would be appropriate, with the proposed 90% threshold, smaller LoBs would have to be included. ","Public","Insurance Europe","EIOPA disagrees of reducing the threshold to 80% and keeps the 90% as publicly consulted based on the impact assessment."]
["Reporting","S.21.01","Solo","While the industry takes note of the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions, it believes a threshold of 80% would be appropriate, with the proposed 90% threshold, smaller LoBs would have to be included. ","Public","Insurance Europe","EIOPA disagrees. Based on the impact assessment the threshold is kept as publicly proposed of 90%."]
["Reporting","S.22.01","Both","While the industry supports the inclusion of the SCR and MCR ratios in the S.22.01 template it notes that this template should not be public.\n\nThe volatility adjustment (VA) and matching adjustment (MA) are two key elements of the Solvency II Directive. Requiring companies to disclose the impact without MA or VA is confusing for policyholders and it may give the impression that long-term guarantees measures might be a potentially movable or ancillary element of the framework that might at some point exist or not. The industry considers that such a message would be highly detrimental to all stakeholders. \n\nFurthermore, the proposed calculation of the impact of the ratios could be interpreted wrongly, as the ‘impact of transitionals on eligible own funds’ divided by the ‘impact of transitionals on SCR or MCR’ will not show the effect the transitionals have on the solvency ratio. ","Public","Insurance Europe","Noted. The proposal has been removed from the disclosure template."]
["Reporting","S.23.01","Solo","In cell R0720/C0060, EIOPA introduces a definition on foreseeable dividend which deviates from the guidelines of EIOPA on the own funds. Foreseeable dividends are recognised when the proposal is declared by the administrative, management or supervisory body (AMSB). The industry does not see a need to change the definition for foreseeable dividends and proposes to keep the original definition.","Public","Insurance Europe","EIOPA disagrees. The proposal is in line with the Q&A on the reporting of foreseable dividends. See Q&A 1701"]
["Reporting","S.23.01","Group","The industry takes note of the changes proposed regarding ‘non-available own funds’. \n\nThe industry takes note of the changes proposed regarding ‘minority interests at group level’. \n\nThe industry is disappointed with the increase of the reporting requirements regarding total available own funds, for which many additional datapoints are added. \n\nThe industry notes that the proposed definition for foreseeable dividends was not proposed here. ","Public","Insurance Europe","Noted. The additional information about non available Own funds is deemed essential for supervisory analysis and it should be available to the groups."]
["Reporting","S.23.01","Both","It is clear that, in the current year reporting, foreseeable dividends from past year results, should be reported in full until they are paid in the current reporting year. However, the reporting of foreseeable dividends from current year business at once in Q1 reporting does not make economic sense, since these dividends will not have been earned fully in Q1 (and also not fully in Q2 and Q3). It is therefore economically sensible to report foreseeable dividends from current year business only incrementally from quarter to quarter (when the dividend has been earned). The full disclosure in Q1 would distort the true economic picture in the quarterly reporting and misrepresent available own funds by erroneously decreasing own funds.","Public","Insurance Europe","EIOPA disagrees. The proposal is in line with the Q&A on the reporting of foreseable dividends. See Q&A 1701"]
["Reporting","S.23.02","Solo","The industry welcomes the deletion of the information related to ‘excess of assets over liabilities, which was not announced in EIOPA’s report on quantitative reporting templates, published together with the EIOPA opinion on the 2020 review.","Public","Insurance Europe","Noted"]
["Reporting","S.23.02","Group","The industry notes that, for groups, EIOPA did not suggest the deletion of the information related to ‘excess of assets over liabilities.  ","Public","Insurance Europe","EIOPA prefers to keep the  table on \"Excess of assets over liabilities - attribution of valuation differences\" at  group level, considering that the Variation Analysis templates don't apply at group level"]
["Reporting","S.23.03","Both","The industry welcomes the inclusion of a threshold for this template, both for solo and group template. ","Public","Insurance Europe","Noted"]
["Reporting","S.23.04","Solo","The industry welcomes the inclusion of a threshold for this template, both for solo and group templates. ","Public","Insurance Europe","Noted"]
["Reporting","S.23.04","Group","The industry welcomes the inclusion of a threshold for this template, both for solo and group templates. \n \t\nWhile the industry takes note of the changes proposed regarding ‘non-available own funds’, it opposes any additional increase in granularity for this template. ","Public","Insurance Europe","Noted. The additional information about non available Own funds is deemed essential for supervisory analysis and it should be avaialable to the groups."]
["Reporting","S.25.01","Both","Both for group and solo level: \n\nThe industry notes that this template is only applicable for SF undertakings/groups, and that EIOPA introduced a new set of templates for the standardised reporting requirements for internal models. \n\nEIOPA introduced burdensome changes when it comes to including diversification benefits and more detailed information on capital add-ons, which are also included in the public version of these templates (S.25.01.21/22). The industry notes that new cells should be omitted in the SFCR and the industry would ask EIOPA to elaborate on the added benefit for the introduced cells, especially because the legal background for the set capital add-on should anyhow be known by the NCA.\n\nFurther comments:\n*R0060/C0030-C0040: The industry would ask EIOPA to clarify whether the introduction of “including diversification within each risk module” in the description of diversification effects is for clarification purposes only and should only be calculated on the level of module components that form the Basic SCR, or whether the requested items also include diversification effects within the respective module components and if so, to which extent.\n*In row 0070, EIOPA introduces \"market risk & credit risk\". This terminology is confusing as it does not relate to a category of the Solvency II legislation. Normally, credit risk is part of market risk. \n*In row 270, EIOPA introduces business risk. However, a definition is lacking, and groups can use multiple interpretations, EIOPA is asked to clarify how this would provide additional information.\n*In row 310, EIOPA introduces net non-life risk. EIOPA is asked to clarify how \"net\" is defined in this cell.\n*S.25.01.01 and S.25.01.04: The new split of Capital Add Ons includes the \"Article 37 (1) Type b\" that in our understanding is Internal Model specifically related. If this is confirmed by EIOPA, it is suggested to gray out the relevant quantitative input cell.","Public","Insurance Europe","There is a mix-up of templates here.\nR0060/C0030-C0040 refers to S.25.01. The clarification is there to explain that the diversification should include all applicable levels within each module and between each module component that forms the Basic SCR.\nR0070 refers to S.25.05. It is there to explain that models calculationg credit risk separately (non-integrated models) should include credit risk.\nR0270 referes to S.25.05. Business risk is defined by some undertakings and the definition can differ. If an undertaking does not have it defined then it should not report anything in this data field.\nR0310 referes to S.25.05. The definition is in the LOG file.\nS.25.01.01 and S.25.01.04: Type b is Internal Model specific. Should grey out the cell since S.25.01 is only for Standard Formula undertakings."]
["Reporting","S.25.05","Both","The industry strongly opposes standardised reporting requirements for internal model companies. The industry suggests that the current templates are maintained.\n\nEIOPA does not foresee any proportionality for partial internal models, for which the additional reporting requirements will be very burdensome in comparison to their partial internal model. \n\nNote that S.25.05.21/22 are also public disclosure templates.\n\nEIOPA notes in para 2.411 of its report on quantitative reporting templates, published together with the EIOPA opinion on the 2020 review that “the template allows for great flexibility” and that “data reported is agreed between each undertaking and the group and the NCA”. For the sake of comparability undertakings will now have to report the burdensome new template S.25.05. This is highly undesirable as it would imply that the content of each reporting templates would have to be agreed upon individually with the respective NCA. Differing opinions from different NCAs would make reporting this template extremely burdensome, especially for internationally operating groups. Insurance Europe would appreciate detailed and generally accepted binding instructions for filling in this template. The NCA’s opinion on the components to be reported in this template carries over to other templates S.26.08-16 because they contain the same or more detailed information. This is in contrast to the statement in the general comments section of the proposed ITS for those templates that “cells have only to be filled if this is possible with reasonable effort”.\n\nFurthermore, as it is not clear, where the specific modelling of a group does not coincide with the prescriptive QRT granularity, EIOPA is requested to clarify what is to be done. Are simplifications in reporting admitted, and should there be more flexibility in each macro module for a residual generic micro module to be used in case of different modelling? For example, spread and migration risk as well as life underwriting risk components assessed jointly and not separately.\n\nSpecific concerns for partial internal model users:\nThe proposed template tries to capture additional insights into full internal models. The intended use of this template for companies with partial internal models is not clear. The industry would appreciate clear instructions on how NCAs will collect information about the remaining modules calculated with the standard formula (SF) and how the structure of the SF would translate to the structure of the template.\nCompanies or groups for which only part of a specific module is covered by an internal model will face difficulties in generating the requested information for the newly introduced templates. If, for example, only half of the equity portfolio is covered by the partial internal model, the mVar (“modelled VAR”) in 26.09/R0110/C0020 carried over to 26.08/R0120/C0010 is only a part of the equity risk SCR. EIOPA is requested to provide clarification as to how C0010 and C0070 should be completed for partial internal models.\nCompanies with partial internal model reporting where the SF component of the SCR is either a separate set of risk modules or a part of the existing ones will also face difficulties. For example, the request of probability distribution functions points (mVaR) could only be addressed by full internal models if no further details on the consistency of templates are provided by EIOPA.\n \t\nIn S.25.05.01, S.25.05.04 the following cells are repeated twice:\n \tC0010/R0050 is apparently equal to C0100/R0300\n \tC0010/R0060 is apparently equal to C0100/R0310\n\nIn S.25.05.21 a row is missing. Above C0100/R0211 the total \"Capital add-ons already set\" (as sum of the 4 categories allowed) is missing in comparison with the other QRT templates.\n\nIn S.25.05.22 two rows are missing: \n \tAbove C0100/R0160 the \"Adjustment due to RFF/MAP nSCR aggregation\" is missing in order to allow the matching of the Total SCR with S.25.05.04. \n \tAbove C0100/R0211 the total \"Capital add-ons already set\" (as sum of the 4 categories allowed) is missing in comparison with the other QRT templates. ","Public","Insurance Europe","Undertakings with partial internal models need only report the templates and data fields that correspond to the risks covered by their partial internal model. If only one risk is covered then they will only need to report this. S.25.05 can be considered as a summary template which mostly collects information from the other IM templates. And again for a partial internal model only the risks covered will be applicable. The reporting of the Standard Formula remains unchanged.\n\nRegarding the public disclosure, the level of granularity disclosed is very similar to what exists currently.\n\nParagraph 2.411 of the report on quantitative reporting templates refers to the exisitng templates S.25.02 and S.25.03 which will be discontinued. It is in these templates that items reported needed to be agreed with the NCAs and no issues were identified in this process for local or internationally operating groups. LOG files have been amended in order to provide clarification.\n\nUndertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nCorrections to the QRTs have been made where appropriate."]
["LAC DT ","Do you agree with the proposed threshold?","Both","We suggest a change of the threshold definition for report S.02.01.01, i.e. from: \"C0030 and C0040 should be reported only where the amount of net deferred tax assets or the amount of net deferred tax liabilities are higher than 10% of the SCR\"\nto:\n\"C0030 and C0040 should be reported only where the amount of net deferred tax assets is higher than 10% of the SCR\",\nas significant deferred tax liability is safe from SCR tax loss settlement perspective, therefore, only large deferred tax asset in pre-stress situation, should be burdened with the additional reporting.","Public","Polish Chamber of Insurance  ","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.26.07","Both","EIOPA has proposed to remove a number of cells: for windstorm, hail, earthquake, flood and subsidence the risk weight chosen in the Nat Cat simplifications no longer must be reported. ","Public","Insurance Europe","Agree"]
["Reporting","S.26.08","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nOn p50 of the ‘Annex II Solo instructions S.26.02 to S.36.05’ and p50 of the ‘Annex III group instructions S.26.02 to S.37.03’ EIOPA notes that: “The purpose of this template is to collect data on an aggregate level and show diversification benefits between separate risk modules. Some entries are taken from other templates but are indicated below. From a technical perspective these are not duplicated as they are essentially the same datapoints. Therefore, by filling data in one template it automatically appears in the other one.”\n\nIn S.26.08.01 and S.26.08.04 a clearer clarification should be provided regarding the approach for taxation. For example:\nC0010/R0020: It is not clear if the diversification benefit should be calculated before or after tax absorption. Insurers recognise the cell R0060/C0100 is calculated after tax absorption, and consequently must be clarified if a double entry is requested or a pre-tax amount has to be included.\nC0010/R0070;C0010/R0190;C0010/R0200: it is not clear if these amounts shall be after tax, since in cells (H18;H20;H21) no reference to taxation is present, and no clarification is included in the \"2450_ITS_reporting_consolidated_AnnexII_solo instructions\".\n\nIn S.26.08.01 and S.26.08.04 the following cells are repeated twice:\nC0010/R0050 is apparently equal to C0100/R0300\nC0010/R0060 is apparently equal to C0100/R0310\nfrom C0010/R0090 to C0010/R0200: it is not clear if these amounts shall be after tax, since no reference to taxation is present, and no clarification is included in the \"2450_ITS_reporting_consolidated_AnnexII_solo instructions\". \n\nIn S.26.08.01 and S.26.08.04 is not clear if C0100/R0010 is equal to the sum of C0100/R0070+C0100/R0190+C0100/R0270+C0100/R0290+C0100/R0510+C0100/R0530 or to different amounts.","Public","Insurance Europe","All values are reported before any tax effects unless otherwise stated. A clarification has been added in the general comments of the LOG files.\n\nCorrections to the QRTs have been made where appropriate.\n\nIn the instructions it is stated that C0010/R0010 in S.26.08.01 and S.26.08.04 is the sum of diversified capital charges for each risk module and a formula is given. Diversification between risk modules is not included. Each of those cells in the comment refers to the undiversified component."]
["Reporting","S.26.09","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nIn the general comments section of the proposed ITS it is noted that “cells have only to be filled if this is possible with reasonable effort.” This is contrary to the instructions provided for templates 25.05 and 26.08 that share identical datapoints with 26.09 and for which “the components to be reported shall be agreed between national supervisory authorities and insurance and reinsurance undertakings.” The industry would appreciate detailed and generally accepted conditions for filling in this template.\n\nThe proposed template attempts to capture additional insights into full internal models. The intended use of this template for companies with partial internal models is not clear. Further clarification on how NCAs will collect information about the remaining modules calculated with the SF and how companies and groups should provide the requested information in C0010 and C0070 if a model only covers some part of a specific risk module would be appreciated.\n\nR0210-R0480/C0280-C0330 — The proposed template includes a very extensive set of market sensitivities. Considering the tight reporting deadlines, providing this large set of sensitivities would be an extreme burden on most companies and groups. If EIOPA would proceed with the template, the industry suggests removing these cells from the template.\n\nFurther comments:\n\nEIOPA states that \"these figures should correspond to impact on the ‘net asset value’ associated\". In other cells and templates, even in the next sentence, reference is made to BOF. EIOPA should therefore clarify the definition of net asset value.\n\nEIOPA states that \"mVaR 99.50% without volatility adjustment (VA) and without transitionals\". EIOPA should therefore clarify whether this implies that it should also reported without DVA.\n\nEIOPA asks insurers that are in scope to provide several sensitivities. However, these sensitivities do not align with the proposals made by EIOPA for a standardised set of sensitivities to be included in the SCR. For similar categories, different sensitivities are requested. This significantly adds to the administrative burden. The industry suggests removing these sensitivities. However, if EIOPA decides to implement these, the industry suggests that EIOPA aligns the sensitivities. \n\nIn S.26.09.01 and S.26.09.04 \"of which: Interest rate risk diversified\" (R0050) it is unclear what it is expected to be included in columns from C0070 to C0270, taking into account that field is a diversification benefit and not an overall SCR amount.\n\nIn S.26.09.01.02 insurers are required to report the \"Modelled VaR\" values (mVaR). EIOPA should confirm if the required \"mVaR\" is the same type of measure required for the MCRCS study, and that it shall be computed as explained in the \"Market & credit risk modelling comparative study (‘MCRCS’), year-end 2020 edition -  Instructions to participating undertakings for filling out the data request\" in Section \"VI.3. Appendix 3: Q&A to specific parts of the data request\". Further clarifications are necessary to avoid the wrong input being provided. ","Public","Insurance Europe","There is no contradiction in these two statements. Whether data can be submitted with reasonable effort or sensible manner is going to be decided by the undertaking and the NCA that supervises the model. The sentence “the components to be reported shall be agreed between national supervisory authorities and insurance and reinsurance undertakings.” has been removed fron the LOG files so as not to cause confusion.\n\nUndertakings with partial internal models need only report the templates and data fields that correspond to the risks covered by their partial internal model. If only one risk is covered then they will only need to report this. If a risk is partially covered then the undertakings will only need to report what is covered by the partial internal model. The standard formula part is going to be reported in the relevant standard formula templates.\n\nLOG files amended for C0010 in S.25.05 and S.26.08.\n\nSensitivities are essential in monitoring model behavior. Most NCAs already request most of these sensitivities.\n\n'Net asset value' sentence has been amended in the LOG file in order to avoid confusion.\n\nYes, DVA is also excluded.\n\nThe standardised sensitivities proposed by EIOPA for the SFCR are not part of the ITS amendments. This is under review and depends on the COM proposal and if changes are needed they will be included in another ITS amendment.\n\nThe mean, standard deviation and percentiles of the diversified intrest rate risk distribution.\n\nmVaR is the same measure as in the MCRCS but it is also described in the LOG file."]
["Reporting","S.26.10","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nIn S.26.10.01 to S.26.12.01, it seems that concentration risk is missing.\n\nIn S.26.10, insurers are required to report the field C0050 Average Probability of Default. EIOPA should confirm if it is correct to assume that from S.26.10.01.01 to  S.26.10.01.04 for the fields  \"Counterparty Group/Single Exposure 1-10\" the 1Y Probability of Default associated to each of the reported counterparties must be reported. \n\nIn S.26.10, it is required to report the field C0060 - Average Loss Given Default. EIOPA should confirm if it is correct to assume that, unless stochastic LGD are used in the model, from  S.26.10.01.01 to  S.26.10.01.04 for the fields  \"Counterparty Group/Single Exposure 1-10\" the the LGD associated to each of the listed counterparties must be reported. \n\nIn S.26.10, it is required to report the field C0050 Average Probability of Default. EIOPA should confirm if it is correct to assume that for the fields different from the \"Counterparty Group/Single Exposure 1-10\" the average 1Y Probability of Default associated to each of the reported counterparties, weighted by the market value (or the Exposure at Default?) of the counterparties, must be reported.\n\nIn S.26.10, insurers are required to report the field C0060 - Average Loss Given Default. EIOPA should confirm if it is correct to assume that, unless stochastic LGD are used in the model, from  S.26.10.01.01 to  S.26.10.01.04 for the fields different from the \"Counterparty Group/Single Exposure 1-10\" the average LGD associated to each of the listed counterparties, weighted by the market value (or the Exposure at Default?) of the counterparties, must be reported.\n\nIn S.26.10.01.07, insurers are required to report, under an mVaR 99.50% metric, the R0740 - Credit Event Risk and the R0750 - Expected Loss figures. EIOPA should confirm if it is correct to assume that R0740 corresponds to the overall credit mVaR (as reported in S.26.09.01.02 C0020/R0170). For R0750, insurers are required to report the sum over all the exposures of their Market Value (or Exposure at Default?) times their PD times their LGD.  ","Public","Insurance Europe","Concentration risk is reported in S.26.08 R0260. S.26.10 and S.26.12 provide more detailed information.\n\nThe 1Y PD for each listed counterparty must be reported.\n\nLGD is associated with each listed exposure.\n\nFor the split by asset class average 1Y PD and average LGD shall not be weighted.\n\nR0740 is the same as S.26.09.01.02 C0020/R0170 and it is the 99.5% of the credit event distribution. R0750 is the mean of the credit event distribution."]
["Reporting","S.26.11","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nIn S.26.11, insurers are required to report data for the asset class of derivatives (eg R0070), but not for reinsurance, while in S.26.10 these two asset classes are reported together (eg R0610). In some internal models, derivatives and reinsurance are modelled under the \"counterparty default\" risk module, and not under the \"credit default\" risk module, that is applied to the bond/loan investment portfolio. EIOPA should confirm if, in these cases, the legal entity should report derivatives under S.26.11 or rather under S.26.12? \n\nEIOPA should clarify under which circumstances R0090/C01000 can differ from R0180/C0100 in S.26.11.","Public","Insurance Europe","Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nR0090/C0100 and R0180/C0100 are the same so both are not necessary. This has been addressed."]
["Reporting","S.26.12","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nThe S.26.12 template uses an asset classification that seems to be taken from the SF (Type1, Type2, …), but some internal models do not use this classification. EIOPA should clarify whether to complete the QRT, the same classification of assets as for SF should be used.","Public","Insurance Europe","Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nIf the internal model cannot produce Type 1 or Type 2 exposures in a sensible manner then the undertaking need not provide this data."]
["Reporting","S.26.13","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nCompanies that do not cover the full risk module within the internal model are not able to fulfil the data requirements, and parts that are not internally modelled cannot be provided which means that certain cross-checks with other templates (26.08), as described in the LOG-file, might fail.\n\nThe reporting requirements for this template are the same for solo companies and groups. It is not meaningful to have such detailed reporting requirements for groups, as several of the required data might not be available. If EIOPA proceeds with the implementation of this template, a simplification of the group reporting requirements should be considered.\n\nS.26.13.01.09 / C0110-C0120: The undiversified view on detailed model results (quantiles) is usually not available in internal model outputs, as it does not bring added value for analysis. The industry suggests excluding this requirement.\n\nS.26.13.01.11 and S.26.13.01.13: The requirement to provide detailed data for each man-made catastrophe scenario individually is not considered meaningful and is overly burdensome. The industry suggests allowing for aggregation of all man-made catastrophe scenarios and their combined reporting in these sections.\n\nS.26.13.01.13/C0210: The requirements for natcat model results are overly complex and burdensome. The industry suggests removing at least OEP  data, as this data only reflects single loss information rather than annual loss information, which is the target of the Solvency II evaluation.\n\nIn 26.13.01, is not clear where and with which level of granularity non-life lapse risk must be reported in cases where this risk is modelled separately from other non-life underwriting risks within the internal model framework. \n\nIn 26.13.01, it is not clear what should be done where the specific modelling of a group does not coincide with the prescriptive QRT granularity: in particular, if the internal model reporting is not done at Solvency II lines of business granularity. EIOPA should clarify whether simplifications in reporting would be admitted.\n\nFor larger entities and for the group the reporting by internal model, LoBs will turn out to be difficult to manage due to the large number of such LoBs. Furthermore, this could imply inconsistencies in reconciling internal model LoBs results with Solvency II LoBs and Total, driven by the fact that Solvency II LoBs and Total are modelled starting from internal model LoBs but using a larger number of simulations.\n\nIn 26.13.01, R0510 and R0750, written premium planned in the 12 months post the reporting reference date are not used in the internal model, and some companies instead use earned premium planned in the 12 months post the reporting reference date. Using written premium would lead to an inconsistency with the actual input of the model. It is suggested not to specify written or earned in the request and add a cell for qualitative information on the premium used.\n\nIn 26.13.01.11 and templates thereafter, it is not clear where the classes should be taken from (“set out at the LoBs row of premium risk template”). \n\nIn 26.13.01.11, it should be further clarified what is meant by exposure amount: limits at risk.\n\nIn 26.13.01, it is not clear how man-made risk should be reported in cases where the internal model models the risk within premium risk. Separating this risk is possible with proxies, but may lead to inconsistencies and double counting.\n\nIn S.26.13.01.14 and S.26.13.01.15, EIOPA is asked whether proxies are allowed in cases where the distinction between direct and accepted business is not available by peril.\n\nIn S.26.13.01.17, it is not clear if the data should be reported gross or net of reinsurance.","Public","Insurance Europe","Undertakings with partial internal models need only report the templates and data fields that correspond to the risks covered by their partial internal model. If only one risk is covered then they will only need to report this. S.25.05 can be considered as a summary template which mostly collects information from the other IM templates. And again for a partial internal model only the risks covered will be applicable. The reporting of the Standard Formula remains unchanged.\n\nGroups are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nIndividual man-made catastrophe scenarios are required in order to have a view on the risks being taken on by the undertaking.\n\nFor NatCat single loss information is important in order to monitor the size and frequency of single losses.\n\nNo attribution is required for Lapse risk. Normally it is covered under Premium risk.\n\nThe LoBs used by the internal model should be reported in the template. Additionally a mapping is requested between the LoBs used by the internal model and the Solvency II LoBs.\n\nIn S.26.13.01.11 and thereafter the classes are the ones used in the internal model. The template and LOG file has been amended. The exposure amount is the one agreed with the supervisor. This is done on purpose so each undertaking can report the value used in the internal model and is not forced to use a predetrmined measure.\n\nIn S.26.13.01.17 net of reinsurance data is requested. The LOG file has been amended."]
["Reporting","S.26.14","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nIn S.26.14.01, the information requested for life and health risks are split by life and Health Similar to Life Techniques (HSLT) business. Nevertheless the risk classification of the internal model could not be aligned to the business classification adopted for the SF calculation. In cases where there is not split between the life and health business, clarification on how to fill in the template should be provided.\n\nIn S.26.14.01, the information is required for a sub-set of underwriting risks and not all the risks included in the solo/group risk map could be reported (eg health claims risk and going concern reserve). Further clarification on the treatment of the missing risks would be appreciated.\n\nIn S.26.14.01.04, the sum of the life and health sub-modules and the diversification effect should be reported. Nevertheless, as stated above, the internal model design could not reflect the same level of diversification as under SF. Further clarification on how to fill in the template in this case would be appreciated.\n\nIn S.26.14.01, R0050 requires the values related to the catastrophe component of the mortality risk. EIOPA should confirm if, in cases where Life CAT is a separate risk, R0050 should be left empty and only R0250 has to be populated.\n\nIn S.26.14.01, R0100 requires the values related to the catastrophe component of the longevity risk to be included. EIOPA should confirm if, in cases where the component is not applicable, the cells should be empty.\n\nIn S.26.14.01, for all the risks the split by component (trend, level and volatility) is required. In all the cases where internal models assess mortality (non-CAT) risk in a unique loss distribution, implicitly accounting for the three mentioned components, EIOPA should confirm what it expects to be reported: ie can a legal entity leave the trend, level and volatility rows (R0320 to R0340) empty or is a simplified approach to split the amount in the three components expected? In the latter case, insurers would suggest the use of this information to be disclosed jointly with the level of simplifications used.","Public","Insurance Europe","Groups are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nRisks not mentioned in the template shall not be reported.\n\nClarificatrion is needed as to why the internal model design could not reflect the same level of diversification as under SF. The comment is not understood.\n\nYes. In this case R0050 shall be left empty and R0250 shall be populated.\n\nYes. If it's not applicable then it does not need to be populated.\n\nIf no split in trend, level and volatility is available and cannot be produced in a sensible manner then it should not be reported."]
["Reporting","S.26.15","Both","The industry strongly opposes standardised reporting requirements for internal model companies. ","Public","Insurance Europe","Noted"]
["Reporting","S.26.16","Both","The industry strongly opposes standardised reporting requirements for internal model companies. \n\nIt is not considered meaningful to have a QRT on the model change process, since the internal model process already prescribes detailed reporting requirements on model changes on a quarterly basis to the NSA’s (ie to avoid double reporting). The new template requires additional reporting which is potentially structured in a different way and could lead to confusion (ie different time windows on how companies look at model changes).\n\nThe new reporting requirements require that the model change process in respect of the annual calculation is finished by the QRT reporting deadline. As those processes might be set up in a different way in different insurance companies, it might not be possible to deliver the information on model changes in time for the reporting. One possibility would be to request information on model changes with a one-year shift.\n \nFurther comments:\nS.26.16.01.01/C0050: The text should be adjusted as this requirement concerns a change of the model change policy and not the model.\nS.26.16.01.03/C0240 & C0250: This requirement should be reconsidered. Providing the sum of minor model changes with SCR increase/decrease cannot be used to assess the overall impact of minor model changes, as diversification/aggregation benefits between minor model changes cannot be taken into account when using the sum.","Public","Insurance Europe","The template is intentionally less granular than the regular communication between supervisor and undertaking. There is no intention to replace that. The intention is to have a common template on a European level with some basic information regarding model changes where supervisors can quickly check the impact of a specific change or a set of changes. The common template will also assist in colleges. EIOPA acknowledges that specific governance frameworks deviate from each other and that's the reason that it requests each undertaking to report major and minor changes according to its own model change policy (MCP). The template will be reported annually and the LOG file states that fields corresponding to minor changes should provide information based on the reporting period.\n\nS.26.16.01.01/C0050: Corrected.\nS.26.16.01.03/C0240 & C0250: Diversification methods can differ so the sum is requested in order to better assess the impact of minor model changes."]
["Reporting","S.29.01","Solo","COMMENTS on S.29.01-05\nEIOPA decided to maintain the current variation analysis templates (S.29.01 excess of assets over liabilities, S.29.02 Excess of assets over liabilities – explained by investments and financial liabilities, S.29.04 Detailed analysis per period – Technical flows versus Technical provisions). In addition, a new template was introduced  (S.29.05 Detailed analysis per period – Analysis of changes of Best Estimate Non-Life,) and non-life reporting requirements were removed from template S.29.03 (Excess of Assets over Liabilities - explained by technical provisions).  \n\nThe added value of these QRTs is not clear. These QRTs were not used for discussions by the supervisor. At the same time, new and changed QRTs require significant effort. The cost-benefit analysis is therefore conceivably unfavourable. In addition, defining and introducing definitions of composites is overly complicated and the variation analysis templates should be removed, or that EIOPA should at least keep the current templates S.29.01-S.29.04, which should remain the same. The proposed changes only increase the reporting requirements, rather than reducing them as companies have requested. Finally, if EIOPA decides to maintain the templates, thresholds should be implemented. \n\nIn annex II solo instructions S.26.02 to S.36.05, EIOPA introduces another template ‘S.29.03.05 – introductory remarks: determination of the dominance of the business model for composites’. This template is not reflected in the ‘EIOPA 2020 review annotated templates’ excel file, and in the cover note EIOPA mentions this on p10 as ‘a methodology and threshold to identify the material business model for a composite insurer is also proposed’. EIOPA also notes in the cover that “the sector was generally supportive of the QRT for non-life” (ie the new template S.26.05, but which was previously consulted as S.29.06). However, the sector made those remarks under the impression that the other QRTs would be deleted and replaced.\n\nIn its proposed form, the new template S.29.05 does not achieve the objective of reducing reporting burden for undertakings and ensuring risk-based reporting of meaningful data. The highly increased granularity of the template compared to the current version, with separation between premium and claims provision and more detailed walks, all by individual lines of business, creates significant challenges. The current format of the VA template is already burdensome, as the cashflows are analysed through the internal and Solvency II systems, and with the proposed increased granularity the main challenge would be the unavailability of different characteristics or splits in different systems. To produce the data for the template, approximations would need to be made, which would require  resources and the obtained numbers would lack accuracy. Furthermore, as all the lines of business need to be covered regardless of their materiality, this is not in line with the risk-based proportionality principle.\n\nInsurance companies note that, in general, the process of completing the QRTs S.29.01-04 is slow, as it requires mostly manual labour, since it is not feasible to automate these QRTs.\n \tIt should be noted that the PRA has proposed in its recent consultation to remove the S.29 series for UK insurers (whilst EIOPA has proposed to create a new template and amend existing ones). The paper notes that ‘the information reported in the templates listed in paragraph 2.2 either has limited prudential value to [the PRA’s] supervisory approach, or could be derived from other information reported without additional burden. A number of the proposed templates* have been reported by only a few firms in the past and provide limited incremental informational value on these firms’. (*This does not just refer to S29 series templates)\n\nFurther specific comments:\n*S.29.05 - R0100: In the previous Analysis of Change (AoC) (S.29.03.01.03), there was a distinct row for non-economic assumption. EIOPA should therefore confirm whether it is correct to assume that this is now part of the actuarial assumptions in R0100.\n*S.29.05 - R0230, R0330: EIOPA is asked to clarify what the relation is between claim handling costs and allocated loss adjustment expenses (ALAE), ie whether they exclude each other or whether the one is part of the other.\n*In Annex II, for S.29.03, the label for C0100 - C0110/R0320 was amended to remove the text “net of salvage and subrogation”, while the annotated template for S.29.03.01 still has that language. This needs to be removed, also in the annotated template to align.","Public","Insurance Europe","Noted. It is worthwhile to emphasize that the Variation Analysis templates are important templates which help to better understand and quantify the main drivers of the changes of own funds. \n\nPlease note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. "]
["Reporting","S.30.01","Solo","COMMENTS ON S.30.S\n\nThe reduction of the scope of the templates and reduction of the columns are positive. At the same time however, new columns have been introduced. \n\nIn the end, EIOPA did not propose a threshold for this template, that would have accounted for stakeholder feedback that highlighted how the previously proposed threshold was very complicated to calculate. \n\nThe industry opposes any additional requirements regarding this template.\n\nSpecific comments:\nS.30.01 C0045: The industry would welcome additional information regarding the expected reported information. EIOPA is requested to provide additional definition/guidance for the reported information and examples.\nS.30.02 C0050: It is not clear how information on the code and type of code of the reinsurer should be reported, which were previously divided into two fields.\nS.30.03 C0420: The provided definition and metrics do not provide sufficient information to determine how the requested information is to differ from the values already requested in C0230 or C0240.\nS.30.03 C0430: EIOPA should elaborate on what is expected to be reported in this column.","Public","Insurance Europe","A new simple threshold has been proposed.\n\nC0045 This cell has been deleted.\n\nS.30.02 and S.30.04 C0050 Agree.Amended.  In general, reporting follows a defined scheme with a code type preceding the relevant number. Therefore, reporting of Code of reinsurer could follow \"LEI/{code}\" pattern. Please note that reporting of Codes and Types of Codes reporting is described in details in EIOPA XBRL Filling rules section IV.3 Codes and Type of Codes (https://dev.eiopa.europa.eu/Taxonomy/Full/2.6.0/Common/EIOPA_XBRL_Filing_Rules_2.6.0.pdf)\n\nC0420  It should include the maximum coverage per layer of a reinsurance treaty. The LOG has been improved.\n\nC0430 This cell has been deleted."]
["Reporting","S.31.01","Both","The proposal to introduce a currency field could be onerous. Firms find this form difficult enough already: the ability to analyse the reinsurance recoveries by counterparty is usually limited, so an element of approximation and pro-rata allocation is often employed; and introducing further analysis by currency will simply lead to more of the same. This goes significantly beyond the existing requirement set out in S.02.02.\n\nFurther specific comments: \nC0155:  \n*This information can be very difficult to obtain for legacy or small contracts, especially considering that some might run over 15+ Years. The industry would welcome potential exemptions or simplifications.\n*As of today, the amounts are reported in the balance sheet currency. In the documentation package, there seems to be a misalignment between what is written in the template in excel (“Original currency of exposure/transaction/instrument”) and what is reported in the instructions (“Where applicable, identify the ISO 4217 alphabetic code of the currency of the reinsurance recoverables”). It is not clear which currency should be used. If, as written in the instructions, it should be reported the reserves and credits in the currency in which the exposure is expressed, it is not clear which exchange rate should be used to convert the currency in which the reserves / credits are expressed.","Public","Insurance Europe","The undertaking should be able to do the analysis by currency as this information is necessary for SCR calculation among others. The need to report the counterparty on best effort basis already exists and does not justify dropping the breakdown by currency. \n\nIt should be noted that a threshold has been included for this QRT.\n\nThe amounts should be reported in the reporting currency. C0155 should identify the ISO code of the original currency."]
["Reporting","S.32.01","Group","S.32:  The template was not simplified, while NSAs suggested in the December report that ‘the template is detailed and includes information with no additional benefit’. In the currently proposed template, additional information is requested. ","Public","Insurance Europe","Please note that the proposed column on direcPlease note that column \"Direct participating undertaking ID\" is removed."]
["Reporting","S.33.01","Group","EIOPA introduces the relative contribution as a new field. In the formula given, EIOPA does not make a distinction between actual diversification benefits and the impact of intragroup transactions. It seems that EIOPA includes IGT as being part of diversification benefits. EIOPA is asked to confirm whether this interpretation is correct, and to provide more background as to why this change was proposed.  ","Public","Insurance Europe","The formula is provided for simplicity, as a proxy for diversification benefits that doesn't make a distinction between acutal diversification benefits and impact of IGTs. "]
["Reporting","S.34.01","Group","EIOPA introduces the relative contribution as a new field. However, a notional capital requirement for a holding is generally not included in the group SCR as the majority of the notional capital requirement will be subject to intragroup positions: eg the holding of the participation in all underlying undertakings. The formula therefore does not make any sense. In the further clarification, EIOPA does copy the text of the S33 template, while this is not the scope of the S33 template.","Public","Insurance Europe","The formula is provided for simplicity, as a proxy for diversification benefits that doesn't make a distinction between acutal diversification benefits and impact of IGTs. "]
["Reporting","S.36.00","Both","The IGT templates set S.36 consists of the following templates: \n \tS.36.00 IGT - Summary template\n \tS.36.01 IGT - Equity-type transactions, debt and asset transfer\n \tS.36.02 IGT – Derivatives\n \tS.36.03 IGT - Off-balance sheet and contingent liabilities\n \tS.36.04 IGT - Insurance and Reinsurance\n \tS.36.05 IGT - IGT - P&L\n\nThe alignment with the FICOD template is welcomed. The current proposal, however, is very difficult to implement in cases where groups that do not form a financial conglomerate: ie those which operate solely or mainly in the insurance sector. In order to address this: \n\nThe templates currently in place should remain unchanged for undertakings that \"operate solely or mainly\" in the insurance sector. \n\nOr alternatively:\nIn regard to the IGT, the ITS S.36.00 requires reporting of all intra-group transactions distinguishing between significant, very significant and transactions required to be reported in all circumstances. The industry recommends to only differentiate between significant and not significant intra-group transactions to ensure clarity regarding the information that has to be reported. \nThe reporting requirements which are particularities to the financial conglomerates should be eliminated for groups which are no financial conglomerates.\nIn addition, the templates need more and clearer instructions and definitions. \n\nThe timeline and corresponding administrative burden should be reasonably set as the currently foreseen implementation deadline is very short and would result in a very high administrative burden. The industry notes that even if the definitions are cleared, the technical implementation of indirect transactions is particularly difficult, given the existing systems have to be changed (ie through changes to IT infrastructure), leading to a disproportionate cost/benefit ratio. \n\nFurther detailed comments regarding the modification of IGT:\n*Some formal errors in the note should be corrected regarding the column “item” and the column describing the relevant row and column. In the template S.36.00, the number identifying the relevant columns of the template is not correct in some cases: eg R0030/C00510 instead of R0030/C0050. In the second column stating its content, the description assigning the value to the correct sector is missing: eg debt instruments instead of debt instrument from the banking sector to the insurance sector.\n*A definition of indirect transactions vs single economic operation and further instructions are needed: eg should be invoices now separately reported – if they include indirect and single transactions – even on cash basis and its one transaction?\n*The industry would question the relevance of the reporting of transactions with other sectors which are not IGTs (implementation of third-party transactions): eg IGT2/Derivatives and IGT3/Contingent Liability are per se always “indirect transactions” either intragroup or third party. It is unclear which of the options is relevant for the reporting.\n*A clear distinction between IGT1 and IGT5 is necessary: eg IGT1/Loans & Equity Type requires the field interest expenses as well as dividends, so should they also be reported in the new QRTs in IGT5 or are they replaced by the IGT1 fields (old template)?\n*Is the implementation of fields relating to sectors relevant (all insurance)?\n-The “four” sectors are not representative for an insurance business – which leads to a wrong value-chain and/or risk-analysis.\n*EIOPA should clarify the reason for dissolving/uniting IGT4 within the IGT5 P&L Template:\n-P&L Template definition questions\n-Please clarify whether the types “Internal Cost Sharing” or “Others” (old template) are included.\n*S.36.04.01 (Reinsurance Template)\n-C0090 (Single Economic Transaction) for reinsurance transactions the definition must be more concrete, as the reference to general comments supra does not suffice. The log file must explain if this means reinsurance contracts – also for co-insurance – by layer or by segment must be in future connected via transaction ID in field C0010. This will lead to a significant increase in the burden and implementation costs of reporting and is not warranted from a cost-benefit perspective.\n-In C0150 (Maximum cover by transaction), the definition for non-proportional reinsurance is missing. Further clarification is needed as to whether this means that there is no reporting requirement for non-proportional reinsurance contracts in this cell.\n*The deletion of reporting requirement by lines of business is welcomed since it reduces the complexity of the template.\n*S.36.01/S.36.02: These template fields are given a different code (eg old code C0040 in S.36.01 becomes C0031) or new data to be reported is requested in existing codes (eg C0040: sector of the investor/lender in existing code C0040: ID code of the investor/lender). This creates  a lot of additional administrative burden and costs. EIOPA should put forward another, less onerous alternative. \n*S.36.02 C0260: Revenues stemming from derivatives is new. EIOPA should clarify what this entails. Interest will be reported in FC.05 P&L, so EIOPA should elaborate further on FC.05 P&L and what the connection is with the field C0260. \n*C0080 and C0090 : EIOPA should clarify whether the fields mutually exclusive, and to provide an exact definition of an indirect transaction.","Public","Insurance Europe","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insurance groups. Reporting requirements which are peculiarities of the financial conglomerate have been removed. Please also note that S.36.00 has been removed from the final package.       \n\nAbout the distinction between significant and not significant intra group transaction, EIOPA confirms that all significant, very significant IGTs and the ones to be reported in all circumstances are to be reported on annual basis, althought the very significant IGTs and IGTs to be reported in all circumstances will  be still reported on ad hoc basis, as soon as practicable.\n\nAbout the detailed comments, some formal errors have been correted and some clarification included in the instructions.\n\nEIOPA confirms that although interest, dividends are reported in S.36.01, S.36.02  they must be reported additionally in S.36.05 P&L. The double reporting is expected to be of limited burden. While information on premiums are to be reported in S.36.04 only.\n \nFor the purpose of reporting the two fields of  indirect transactions and single economic operations are to be filled in as mutually exclusive.\nAbout the definitions, indirect transactions are normally identified as a chain of transactions shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or with entities outside of the group but ultimately risk exposure is brought back or stays within the group and impacts the solvency position of any insurance undertaking of the group. While, where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation. "]
["Reporting","S.37.01","Group","The risk concentration templates set S.37 consists of the following templates: \n \tS.37.01 Risk concentration\n \tS.37.02 Risk concentration – Exposure by currency, sector, country\n \tS.36.03 Risk concentration – Exposure by asset class and rating\n\nThe alignment with the FICOD template is welcomed. However, the templates currently in place should remain unchanged for undertakings that \"operate solely or mainly\" in the insurance sector. Reference is made to comments on section 3.70 regarding not changing the S.36 for groups that are mainly insurance groups and which do not form a financial conglomerate. The same comments as for QRT S.36 also apply to S.37.\n\nThe industry takes note of the fact that the template S.37.01 is less granular and of the clearer instructions, as suggested.\n\nThe cover note also states that “groups will be requested to present the significant (and very significant) risk concentration”. Concerning IGT, the industry recommends only to differentiate between significant and not significant risk concentration so that it is clear what information has to be reported. \n\nFurther detailed comments:\n*C0170 requires the total amount of the exposures while the solo versions for S.11 and S.03 have reporting thresholds, this causes an indirect requirement for solo companies to fully report S.11 and S.03, despite thresholds, in order to have a full data set for the group S.37 QRT.\n*C0220, C0260 and C0270 seem relevant only for groups engaging in providing credit business, but according to insurers’ understanding the column would remain empty for pure insurance groups.\n*Templates S.37.02 and S.37.03 do not seem to offer any more insight into risk concentration than that of S.06.02 reported on group level. The industry would welcome additional guidelines explaining the difference, especially considering that S.06.02 is already more detailed than required for the purpose of the new templates.","Public","Insurance Europe","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insuance groups. Please also consider that the new S.37.01 template is less granular. Morevoer, it is not desirable to have two totally different sets of tempaltes for insurance group and financial conglomerates.\n\nAbout the detailed comments, EIOPA is aware that the information reported in the set of S.37 templates can be redundant with some information reported in other templates, but the reporting for S.37 is done on a less granular basis and for the different purpose of having an overview on risk concentration."]
["Group reporting questions",null,"Group","Information on credit or insurance risk mitigation techniques (C0260): EIOPA puts forward three options to present the net value according to single counterparty. And EIOPA is asking for industry feedback on which of the three options is preferred. It is also possible to put forward other proposals. \n \tOption A – A proportional breakdown of the capacity of the treaty among counterparties.\n \tOption B – Simulations to see how the reinsurance treaty works in different scenarios.\n \tOption C – Not applying these contracts in the presentation of the net exposure and supplementing with narrative information. \n\nThe industry notes the following with regard to the proposed options:\nOption A may be ‘practical’ from an operational point of view, but is very arbitrary, artificial and does not fit the aim.\nOption B is dependent on selecting adequate and consistent scenarios. It is quite burdensome for the aim of the reporting and may impair data comparability across groups.\nOption C is currently applied in one member state. It gives the supervisor an idea of the actual reinsurance protection of the significant exposure. However, it is difficult to carry out a proper analysis. Thus, this option is also not deemed as an appropriate solution for the template which should present risk concentration.\nThe industry prefers option A, as options B and C make the reporting more complicated and burdensome by introducing scenarios or narrative information. National supervisors may instead request this detailed information on ad-hoc basis. \n\nFirst and foremost, the main common objective should be the alignment of the Solvency II and the FiCOD requirements. \nThe final draft concerning the reporting at financial conglomerate level takes into account any deduction that comes from the application of insurance and/or risk mitigation technique allowed according to the sectoral rules such as reinsurance, the use of derivatives or those detailed by chapter 4 of EU 575/2013. \nThe current consultation, referring to Solvency II, distinguishes between ‘insurance exposures’ itself of which a difference of gross and net exposure can be expected and ‘insurance exposures of the group’ that are reinsured/risk mitigated via a non-proportional reinsurance treaty, encompassing more than one counterparty. \nAs a consequence, EIOPA is already aware that it can be difficult to present the net value per single counterparty. As a result, there are more requirements at financial conglomerate level than for Solvency II and there is a deviating perspective in terms of supervising reinsured exposures. Considering the requirements as a whole, the main objective of the Solvency II review and the final report in regard to the financial conglomerates reporting is to avoid differences between Solvency II and the financial conglomerate reporting and to implement a new harmonised set of regulations. \n\nAs mentioned in the consultation, it can be difficult to present the net value per single counterparty as it is requested in the template when the insurance exposures of the group are reinsured/risk mitigated via a non-proportional reinsurance treaty. Therefore, Option A is the most feasible one in order to provide the information requested in an adequate way. \n\nAs requested in Option B, the application of simulations to see how in chosen scenarios the reinsurance treaty may work results to be really burdensome for the aim of the reporting and may impair data comparability across groups. In addition to that, it may be difficult to compare reinsurance treaties of different national regulatory decrees and policies, because the way transposing the requirements into national law may differ from country to country. \n\nThe description of the reinsurance treaty as mentioned in Option C may not be sufficient enough to display the effect of the reinsurance treaty among the counterparties. On the one hand, the description itself provides information of the treaty. On the other hand, it leaves room for interpretation and does not provide further details of how it is calculated. As a result, the description of the treaty cannot display its effect across branches and countries in a consistent manner. ","Public","Insurance Europe","Noted. The selected option for S.37.01 is option A with some changes: „proportional or otherwise justifiable break-down agreed with the group supervisor“"]
["LAC DT ",null,null,"LAC DT\nAnother set of three templates that was added to the reporting package. Information on LAC DT is already gathered and evaluated by the national supervisor (NBB). This reporting suffices and these very burdensome new templates should not be added to the QRTs.\nThe main goal of LAC DT (recoverability test reporting) is to check whether, after a loss, sufficient taxable profits are available to offset the loss. The proposed QRTs ask for information that goes beyond this purpose. The QRTs ask for a level of detail that may not present a clear added value for LAC DT calculation. For example, one of the proposed columns seem to be intended to assess the impact of DTA and DTL on the LACDT on solo level. For groups, generating this information would be even more burdensome and does not provide any further useful insights for supervisors. On group level the calculation of deferred taxes is very complex as the local tax regulations and the local tax books are very different within the group. So, it would be very complex and time consuming for the groups to calculate a consolidated group tax book. This would not bring any meaningful information for the control authorities as it would be a mix of different tax rules and tax books.","public","Assuralia","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Financial stability guidelines",null,"Both","FINANCIAL STABILITY TEMPLATES\nThe industry takes note of the deletion of some of the information in the financial stability reporting templates (FSTs): eg the annual templates. While EIOPA highlights its proposed elimination of annual FSTs, a consequence of this is the requirement of additional information in a set of QRTs for financial stability. \nProposed changes:\n*New S.14.04 and S.14.05, focusing on liquidity risk.  \n*Changes to template S.02.01 - balance sheet, for groups is changed to also include statutory accounts on a quarterly basis. It would make more sense if the S.02.01 for groups was changed in the same way. Now statutory accounts need to be verified quarterly for groups in Financial Stability  only. \n*Changes to template S.38.01: Duration of technical provisions with new duration measures. \n*Changes to template S.39.01: A few more cells added. \n\nThe inclusion of any new detail in the FSTs is not supported by the industry. In particular for the S.02.01, S.23.02 and S.39.01 which require finalised figures at group level. As the financial stability reporting deadline for groups is only seven weeks (compared with quarterly at 11), it is not realistic to expect detailed figures already by the shorter deadline.\n\nEIOPA introduces the S.14 liquidity templates. However, at the level of the group, this is a quarterly template. In order to complete the template at the level of the group, the group needs the templates at solo level. However, the solo level information is an annual template. This requirement would imply an increase in reporting frequency. EIOPA should confirm if it has identified this issue and confirm that this is the objective. \nCollecting liquidity risk information does not form part of the solvency regime and this template should therefore not be included. In the context of the non-life insurance market, the template does not match industry practice, as liquidity is managed at entity level rather than product or line of business level. Additionally, insurers tend to monitor liquidity risk by looking at how the level of liquid assets they currently hold compares to expected cash out flows (in business as usual and stressed scenarios). The information required by the template appears to track historic cash flows against current liabilities, which would not be helpful in assessing imminent liquidity risks (which inherently tend to be near term risks); at best it would seem that it could provide information on trends when analysed quarter on quarter. \n\nComments on specific templates:\n*The exact scope of templates S.14.04.11, S.14.05.11, and S.38.01.10 is not clear (groups vs individual entities and direct vs accepted reinsurance business).\nThe additions to Guidelines 14 and 15 for individual entities refer to Articles 230 and 233 of the Solvency II Directive, which relate to groups. EIOPA should confirm whether this means that these templates only apply to groups.\n*Furthermore, it is not clear whether the template S.14.05.11 applies to reinsurance entities. The field \"Line of Business\" only lists the direct business lines. It is also noted that the new versions of RSR templates S.14.01 and S.14.02 apply to direct business, and the FSTs S.14.04 and S.14.05 should be in line with them and also be limited to direct business. The template S.14.02 is very granular, requiring splitting best estimate to product classes with such split not available without extensive approximation efforts, in particular for assumed reinsurance business.\nIn the new life liquidity template S.14.04, EIOPA introduces cashed premium. This is a new data field which will create a significant administrative burden. If EIOPA goes ahead with these changes, the industry would deem it reasonable to include a proxy which can be used to complete this cell in order to allow for a proportionate approach. Further, EIOPA requests the fiscal treatment of the products in cell C0210, which duplicates the information that will be included already in S.14.01 (same cell number).\n*In the new non-life liquidity template S.14.05, EIOPA introduces new categories/subsets of LoBs. This will result in additional administrative burdens, as insurers will have to differentiate among the new subcategories, as identified by EIOPA. If EIOPA goes ahead with these changes, the industry would deem it reasonable to allow for a proportionate approach. Further, EIOPA requests the fiscal treatment of the products in cell C0210, which duplicates the information that will be included already in S.14.01 (same cell number).\n*EIOPA has added new requirements with respect to the reporting of the P&L figures in QRT S.39.01.11.02. The industry does not see the added value of the inclusion of this type of information, as the whole Solvency II information is based on economic value. This requirement will again add to the administrative burden.\n*EIOPA has introduced the technical accounts in S.39.01. This QRT built up from a solo perspective. However, according to the Directive, this is an annual requirement, and so the two are not aligned. Again, this will result in an increase in the administrative burden.\n\nQuestion put forward by EIOPA – reporting on the effective duration figures:\nOption 1 — Modified duration reported for all undertakings: Effective duration to be reported only where material optionalities are present in the technical provisions.\nOption 2 — Portfolio to be split based on presence of optionalities: Both modified and effective duration to be reported for all undertakings along with the associate best estimate for each measure.\nWhile the industry would prefer Option 1, which is the least burdensome, reporting the effective duration on top of the modified duration will cause major coordination and methodology changes, beginning with data collection from brokers, through all reporting systems and methodology policies across the full group scope without any added value. In addition, it is unclear what relevant information the effective duration provides in addition to the modified duration for national supervisors. Against this background, Option 1 is preferred without reporting effective duration. ","Public","Insurance Europe","The statutory accounts in template S.02.01 (Balance sheet) should be reported with an annually frequency and not quarterly. As stated in the errata of the Guidelines on reporting for Financial Stability Purposes, the template S.02.02.01 has been ameded by template S.02.01.01, with the inclusion of the statutory accounts in an anually frequency, correspondly to the prudential reporting.\n\nAt the same time, EIOPA acknowledges that the financial stability figures, considering the shorten reporting deadlines (7 weeks), are reported on a best effort basis, and could marginally differ from the figures reported in the prudential reporting.\n\nWe acknowledge the fact that most of the groups manage the liquidity at solo level. Nevertheless, in order to avoid a granular reporting at solo level, it was decided to include the liquidity information at group level in the Financial stability templates.\nWe also acknowledge that the CF are backward looking, instead of estimated future CF in order to reduce the burden for insurance undertakings. Further, this should allow supervisors to analyse the status of the liquidity positions and build time series to assess potential materialisation of risks. In order not to burden the companies, we request past data instead of estimations.\n\nIn addition, reinsurance undertakings are extempted to report S.14.04.11 and S.14.05.11. Guidelines have been adjusted accordingly. \nEIOPA acknowledges that new information needs to be reported for S.14.04/05, however the following changes in the reduction in frequency and granularity of the liquidity information allowing undertakings to report the new cells: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). \n\nS.39 previously collected P&L figures as part of the financail stability templates, differing from the economic value of the SII prudential reporting. The new information constitutes a high level breakdown of this P&L figure. This should not add additional burden to the undertakings, as these figures should be already include in the statutory acounts. "]
["Other",null,"Both","THRESHOLDS\nEIOPA has introduced thresholds which could result in an exemption of submission. However, in practice, the thresholds will not result in a real reduction of the burden for (smaller) insurers, because if the insurer would breach the threshold in one period, this would result in a requirement to submit the data to the NSA/EIOPA. This also implies that the insurer should have at all times a process in place to collect and submit the requested data. \nTherefore, the threshold should be valid for a longer period, or a single breach should not directly lead to a requirement to submit. \n\nConcrete example of the impact of threshold reductions\nIf the thresholds do not reduce the work burden, many companies will most likely ignore the introduced/changed threshold and therefore have no use for them. This concerns for example S.02.02 (90% to 80%), S.03.01 (rather “complex” threshold), S.11.01, S.18.01, S.19.01, S.20.01, S.21.01, S.21.03 and S.23.03. In all these cases, the IT systems for most companies already include this reporting. \nWhile the introduction of additional qualifying criteria and thresholds for a set of QRTs are welcome, these do not (overall) significantly reduce the reporting burden for the group. In particular for the group the new criteria in:\n \tS.02.02 reduces the reporting effort by ~22% for this template\n \tS.03.01 reduces the reporting effort by ~40% for this template\n \tS.11.01 reduces the burden by ~33% for this template\n \tS.18.01 does not reduce any reporting effort for this template\n \tS.20.01 reduces the burden by ~5% for this template\n \tS.21.01 reduces the burden by ~5% for this template\n \tS.21.03 reduces the burden by ~5% for this template\n \tS.23.03 reduces the burden by ~25% for this template\n \tS.24.04 reduces the burden by ~18% for this template\n \tS.29.03 and S.29.04 reduce the burden by ~30% while introducing the new S.29.05 for ~70% of the group companies","Public","Insurance Europe","Following the comments received EIOPA has extended the observation period of the threshold that trigger the reporting requirements. Please consult the final proosal."]
["Disclosure",null,"Both","Article 3a: EIOPA has introduced the requirement to include both the narrative and the QRTs in a single document (both for the solo and the group SFCR). This could be a burdensome process, as the sources of both parts of the information are different. Furthermore, the industry questions whether this \"one document\" requirement is useful for the users of the SFCR. EIOPA should abandon this requirement and leave it optional for undertakings to include both the narrative and the QRTs into one single document, or not. \n\nArticle 3a and the related amendments made to Article 6: EIOPA requires companies not to change the SFCR location on the website for at least five years. This is a very onerous requirement, as it prohibits the further development of the company’s website. In addition, the requirement does not allow for the impact of mergers/acquisitions and restructuring. The requirement should instead be such that the SFCR and QRTs can be easily located on the company website and not be hidden somewhere. These remarks also apply for the group SFCR.","Public","Insurance Europe","Please note that Article 3a and the related amendment introduced in Article 6 have been deleted. However, the proposal in the reporting instructions for submition of the undetaking's SFCR url is kept on a voluntary basis."]
["Reporting","S.06.04","Group","Response regarding Paragraph 5.2 - Sustainable investments and climate change-related risks to investments (reporting code S.06.04)\n\nEIOPA explains well why exposures to climate change risks matter for the soundness of life insurance policies. However, a collective re-orientation of capital from harmful to sustainable causes is crucial to avoid the untenable materialization of climate-related risk. Therefore, absolute financed emissions as well as the development of, for instance, carbon intensity of the insurers’ exposures, would serve the assessment of the investment portfolios better than a ratio of taxonomy eligible activities. It can also guide insurance and reinsurance companies to be more accurate in detecting carbon hot spots in their investment portfolios and support them in developing mitigation strategies.\n\nAn assessment of the data quality used by insurers for their internal risk assessments is as important as assessing the climate risk itself. The use of PCAF, as recommended by the TCFD, would support Solvency II as a more conducive framework for sustainable activities by insurance and reinsurance companies. The PCAF Standard already accounts for various levels of data quality and this scoring can also be used by insurance and reinsurance companies.\n\nA materiality threshold per definition would not suit the objective of assessing climate risks, since climate change doesn’t distinguish small from large companies. An assessment of the financed emissions of the complete investment portfolio is necessary to re-allocate funds collected with life-insurance premiums. It is indeed NACE codes A to N that are most relevant for climate change related risks.\n\nReporting physical location, however understandable from a risk-monitoring view, falls short of reporting the real problem of caused harm, let alone addressing it. Climate risk can be of such a devastating nature that the only way to mitigate it in a credible way is to put our maximum effort into prevention by ensuring that the financial industry uses its investing capability sustainably. The catastrophic floods of this summer in Germany and Belgium have proven that physical risks can occur everywhere without any warning, even in Europe.\n\nTherefore, a less complicated and more effective reporting requirement than the proposed set of requirements for investments would be reporting absolute financed emissions, as advocated by the TCFD, without materiality thresholds.\n\nA standardized reporting of climate risk for Solvency II was recommended by the TCFD and regards the use of PCAF’s Global GHG Accounting and Reporting Standard for the Financial Industry:\n• The PCAF Standard is a harmonized approach, providing all types of FIs with the starting point required to set science-based targets and align their portfolios with the Paris Climate Agreement and simplifying the comparison of GHG emissions information across financials.\n• Yearly disclosure in line with the PCAF Standard allows financial institutions easily to track progress in reducing the GHG emissions of an investment portfolio.\n• The PCAF Standard is open source and free to use, ensuring universal adoption across all types of financial institutions globally, no matter their size or geography.\n• The PCAF Standard creates transparency and accountability, enabling FIs to satisfy the growing investor demand for climate data while helping FIs, their investors and their supervisors to monitor and manage progress towards goals.\n• PCAF is entirely industry-led, and the PCAF Standard is developed by financial institutions for financial institutions. It is also built on and backed by the Greenhouse Gas Protocol, earning the “Built on GHGP” mark.\n• The use of the PCAF Standard allows stakeholders such as EIOPA to compare the disclosure reports of insurance and reinsurance companies easily as they would use the same methodologies and approaches.\n• The PCAF Standard is under constant development and new asset classes are added upon participant demand.\n\nPCAF facilitates data collection:\n• PCAF makes use of existing climate data registers as much as possible, notably where it regards smaller debtors such as SMEs and households, and processes data in a manner that serves portfolio management for all financial undertakings.\n• PCAF identifies gaps where more effort is needed to produce relevant information and updates the existing data.\n• PCAF shares methodologies, data, and estimates, which lowers the cost of setting up internal accounting systems and simplifies the challenges faced by financial undertakings in finding relevant information with respect to their climate impact.\n• PCAF encourages financial institutions to increase their own data quality regarding GHG emissions.","Public","PCAF","Noted. Carbon intensity of an investment portfolio is indeed a key and relevant input for assessing transition risk,  and at the basis of a number of the methodologies addressed in EIOPA's consultation paper on running climate change materiality assessment and using climate change scenarios in the ORSA. \n\nEIOPA tends also to be of the view that materiality tresholds for the KPIs may be of limited supervisory value."]
["Reporting","S.14.02","Group","Response regarding Paragraph 5.3. - Non-life business (reporting code S.14.02)\n\nThe insurance industry urgently needs to measure and report insured emissions. A standardized methodology to measure and disclose the greenhouse gas (GHG) emissions of insurance and reinsurance underwriting portfolios would give insurers deeper insight into the risk profile of their respective underwriting portfolios, stimulate innovative approaches to decarbonization, and create comparability for stakeholders. It would help re/insurers understand the climate impact of their underwriting decisions, laying the foundation to decarbonize their insurance and reinsurance portfolios through target setting, scenario analysis, strategy development, and individually taking concrete actions that have real-world impact through emissions reduction in the real economy.\n\nThe Partnership for Carbon Accounting Financials (PCAF) developed the Global GHG Accounting and Reporting Standard for the Financial Industry (the PCAF Standard), the first global, standardized, and transparent methodology for financial institutions to measure and disclose financed GHG emissions. The PCAF Standard, as recommended by TCFD, is already feeding into the effort to develop an Insured Emissions Standard. PCAF, in collaboration with the Net-Zero Insurance Alliance (NZIA), has launched a working group comprising leading insurance and reinsurance companies to develop the first global standard to measure and disclose insured GHG emissions. \n\nPCAF’s experience in the sector and its extensive collaboration makes it well-suited to develop the proposed global standard to measure insured emissions. As a partnership of over 160 financial institutions, PCAF will ensure that any standards developed will account for industry-wide interests and concerns, lending itself to be adopted by virtually any interested stakeholder, large or small, irrespective of membership in the NZIA. Moreover, acting as a separate body, PCAF will allow the cooperation to pool know-how and information in a manner compliant with applicable laws and regulations. Many insurers have already joined PCAF to measure and disclose the emissions of their investments but have not yet been able to do the same for their core insurance and reinsurance business. A regulatory impulse that confirms the urgency would support their efforts to develop a standardized approach as soon as possible.","Public","PCAF","We share the urgency of steering conevergency on the topic. We believe that adding these requests could help in this direction."]
["Other",null,"Both","General Comment: \nThe GDV would like to thank EIOPA for the opportunity to participate in the consultation. The revision of the QRT is welcomed by the industry. However, we would like to highlight that changing even a single QRT cell can lead to an increase in cost and burden for NSAs and stakeholders, as even small changes can cause deep interventions in the system. Even EIOPA’s own impact assessment document shows an increase in cost and burden both for NSAs and stakeholders. Particularly critical are the newly introduced QRTs.\n\nWe would further like to emphasize that in the recent consultation on the amendments of supervisory reporting and disclosure requirements EIOPAs presentation of the amendment is highly non-transparent. Due to the lack of a comprehensive overview, the changes can only be tracked with great effort. This makes it considerably more difficult and almost impossible for the industry to substantially assess the significance of the change from a technical point of view.\n\nIt is also very disappointing that EIOPA continues the lack of transparency on a very important subject: the definition of core and non-core set of QRTs. The definition applied in the final advice of the Solvency II Review is no longer used in the present consultation without any justification. At various points in the consultation documents, thresholds and criteria for individual templates are (newly) proposed in a highly non-transparent manner, which may lead to the conclusion that the non-core templates are defined on this basis. For entities, this creates an operational environment of legal uncertainty and it is disappointing that EIOPA is not striving for more transparency.\n\nIn general GDV welcomes the concept of core and non-core templates (as proposed in the final advice). It has to be ensured that the proposed thresholds are useful and are leading to a reduction of the reporting extent. However, it must be ensured that a practicable procedure is established which enables companies to determine with legal certainty and, above all, in the long term which QRTs are to be reported. It is therefore essential to designed thresholds pragmatically. They must not result from the QRT itself (no circular closure, i.e. the entity must first fill in the template to then conclude that the threshold has not been met and the QRT does not need to be reported.).\n\nThe clear reference to the proportionality principle is positive. However, it remains to be seen to what extent this will also be reflected in actual relief for entities. There is no link to the planned proportionality framework (treatment of low risk undertakings). Furthermore, the specific proportional measures are unclear.","Public","GDV","EIOPA disagrees. All changes have been introduced in track changes. The changes in the majority has been based on the QRT report published by EIOPA at the end of 2020. In addition newly introduced areas were explained in the Cover Note. In addition all changes included now are based on all the work during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations.\nImpact analysis include an assessment of the thresholds but the concrete thresholds proposals are included in the consultation package in track changes more in the individual instructions of the different templates.\nThe DPM will be available early in the 2021. The consultation included only proposals of the ITS amendments together with changes in the templates. \nRegarding IFRS 17 and the impact on S.05.01 EIOPA further clarified the instructions of the template but would like to stress that S.05.01 is not a P&L and therefore some deviation may occur (e.g. differences exists also today with IFRS 4). At ‘solo’ level IFRS 17 is expected to be applied only by a minority of undertakings and it is preferable to keep one consistent metric\nIFRS users are expected to keep track of written/earned premiums (as defined Art. 1(12) of DR) in order to calculate capital requirements under SII (e.g. S.28.02).\nRegarding the concept of core and non-core templates it still still exist where core templates are the templates that need to be reported by al undertakings and non-core are the ones with threshold that can be exempted from reporting.\n"]
["Other",null,"Both","General Comment regarding the timing:\nThe GDV remains critical of the decoupling of the quantitative reporting changes from the Level 1+2 changes. Changes to QRTs should only take place after the strategic review of the issues related to the Solvency II 2020 Level 1 and Level 2 review, in order to avoid having to change QRTs and IT systems twice within three years. All changes should be made in the context of this one major review, being the SII 2020 review.\n\nIt is important that all the reporting streams are viewed in the overall picture. At the same time as the amendments to the ITS and the Solvency II Review, changes to other reporting strands are also pending, such as the implementation of IFRS 17 and IFRS 9. The question of the consideration of sustainability aspects in Solvency II, which in turn deviate from the Taxonomy Regulation, is also an issue.\n\nThus the industry would strongly highlight that the implementation period as foreseen by EIOPA is  too tight. If EIOPA persists with its proposals, the industry believes that the implementation date will need to be delayed by at least one year from EIOPA's proposals, given the number of proposed - often material - changes. An even longer timeframe should be considered for new templates to give companies a realistic timeframe to report all new information. In addition, the new validation that comes with the new taxonomy should be non-blocking in the first year of filing (currently scheduled for 2023).","Public","GDV","EIOPA would like to clarify that the current ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations where the timeline for implementation was clear.\nNo amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \n. \n"]
["Reporting","S.01.01",null,"Industry welcomes  clearer instructions and field options as suggested.\nAnnex II of ITS on reporting does not reflect the new deferred tax templates ","Public","GDV","Please note that these templates are not included in the ITS package."]
["Reporting","S.02.01","Both","Additional information on the tax base: see comment on LAC DT in another row below.\n\nReinsurance recoverables cannot be differentiated between claims settled and claims not yet settled in any reasonable way. \nThis can easily be seen by e.g., the recent heavy rain event “Bernd” in Germany in July 2021. The usual reinsurance cover consists of a combination of catastrophe XL-contracts and stop loss-contracts. All payments made by the insurers to their customers are settled between insurers and reinsurers quarterly independent of whether a single claim is (partially) settled or not. This settlement only considers payments made on an aggregated basis for all claims belonging to “Bernd” as the catastrophe XL-contracts do so (e.g., any payments above 100M are covered by reinsurance up to 500M). In case of stop loss only aggregated payments in the period are considered. A settlement between insurers and reinsurers based on single claims is thus impossible. Reinsurance recoverables can only be determined on the level that is considered in the reinsurance contract but not on a more granular level. In case of catastrophe XL-contracts that is total amount of payments of all claims belonging to a single event. In case of stop loss-contracts that is the total amount of payments in the corresponding period. There are many more examples for the impossibility to differentiate reinsurance recoverables between those belonging to claims settled and to claims not yet settled e.g., profit sharing, sliding-scale commissions, lump-sum settlements, advancements and so on. \nOnly in very few special cases if at all this differentiation would theoretically be possible. But as for the settlement between insurer and reinsurer the information whether a claim is settled or not is irrelevant (only amount of payments is relevant), this information is usually not part of the data that is provided to the software for determining the reinsurance recoverables. And this software is not programmed to handle this kind of information. So, the data flows and the software must be reprogrammed. This would cause very high costs. This is inappropriate for an information that has no use at all and can only by determined in very few special cases if at all (see above). \nTherefore, we strongly oppose the proposed change of this reporting template. In our opinion the separation should be between reinsurance recoverables for payments already made in the past and expected reinsurance recoverables for expected future payments.","Public","GDV","Please be informed that suggested changes are intended to implement the approach presented by EIOPA in Q&A 1853. At the same time, EIOPA has taken into account the industry comments by proposing the differentiation of reinsurance cashflows based on payments made or not to policyholders by the undertaking (or vice versa) (compered to the previous approach based on claims settled or not between undertaking and the policyholders). \nThe explanation regarding item C0010/R0270 (Reinsurance recoverables) was amended to the following: \nFor Solvency II column (C0010) this cell in particular should include all expected payments from reinsurers to the undertaking (or vice versa) corresponding to payments not yet made by the undertaking to policyholders (or by policyholders to the undertaking).\nWhile, all expected payments from reinsurers to the undertaking (or vice versa) corresponding to payments already made by the undertaking to policyholders (or by policyholders to the undertaking) should be included in reinsurance receivables (or reinsurance payables). "]
["Reporting","S.02.02",null,"While the industry does not disagree with the deletion of the assets part, the resulting impact of adding ‘currency’ to S.31.01 (Share of reinsurers (including Finite Reinsurance and SPV's)) is very onerous – please refer to comments on template S.31.01.\n\nThe industry welcomes the lowering of the threshold so that the template is not required if one single currency represents more than 80% of liabilities (previously the threshold was at 90%).\n\nAdditional note: The template should consequently be called \"Liabilies by curency\" because of the deletion of the asset part.","Public","GDV","Amended. \nAdditionally, please see the appropriate EIOPA comment on the issue of adding a currency to the S.31.01 template. "]
["Reporting","S.03.01",null,"We welcome the introduction of a new threshold for the S.03.01 template. However, the template is - considering cost benefit aspects - a burdensome template and the delimitation of the required items ist still not completely transparent. Additionally, the new thresholds does not seem to be very helpful: As long as the reporting requirement is dependent from the total assets reported, it is necessary to colletct the data first to demonstrate that the threshold is not met.\n\nAdditionally the following specific question arose:\nThe QRT´s S.03.01.01 (solo) and S.03.01.04 (group) asks in the new cells for information about unlimited guarantees received (C0050/R0510) and provided (C0050/R0520). In both cases you have to choose one option from a closed list where you indicate that you have: \n(1) no unlimited guarantees received/provided, \n(2) unlimited guarantees received/provided from entities of the same group or \n(3) unlimited guarantees received/provided from entities not belonging to the same group.\n\nWhich option do you have to choose on solo and group level when two of the three options are true (e.g. a solo entity provide unlimited guarantees to entities outside the group and also to entities belonging to the same group)?","Public","GDV","EIOPA has re-analysed the impact of the proposed threshold based on solo insurer reporting S.03.01 in 2020. The impact assessment shows that if the threshold was to be implemented, 45% of solo insurers would have benefited from it (ie. 45% of solo insurers would not report S.03.01 template). \nTherefore, EIOPA believes that the implementation of the treshold in S.03.01 template will bring relief to insurers and does not see the reason to change the scope of this treshold. In addition, EIOPA has extended the observation period of the annual thresholds to release the reporting burden. Furthermore, it should be noted that the application of the threshold is not mandatory, ie. insurer may or may not use it.\nRegarding your last question, please note that an additional option was added for unlimited guarantees received/provided from/to entities of the same group and entities not belonging to the same group in S.03.01.01.03 for solo undertakings (appropriate changes for S.03.01.04.03 - groups). "]
["Reporting","S.03.02","Both","The industry welcomes the removal of these templates ","Public","GDV","Noted"]
["Reporting","S.03.03","Both","The industry welcomes the removal of these templates ","Public","GDV","Noted"]
["Reporting","S.04.03",null,"The industry suggests keeping the existing templates, and have no new S.04.03/04/05\nAs stated in the response to the 2019 consultation the industry disagrees with the replacement of S.04.01 and S.05.01. QRTs S.04.03/04/05 QRT are simply an amalgamation of S.04.01 and S.05.02, with further requirements on top – so, instead of reporting less, insurers are instead forced to incur the costs of deleting two QRTs and reporting the same information in three new QRTs, with no additional benefit for policyholders.\nParagraph 2.62 of EIOPA’s report on reporting and disclosure is incorrect: although the concept of “premiums” still exists under IFRS 17, that is not the same as earned and written premium, and neither are expected to be reported (or disclosed). Insisting that written premium should continue to be reported whilst stating that there are no additional costs for companies is not credible.\nShould EIOPA decide to proceed with these changes, the industry highlights that a threshold, for example 10% of gross written premium, is needed to avoid burdensome processes for insignificant cross border activities. This threshold would correspond with the current S.05.02 template.","Public","GDV","Supervisory experience since the introduction of Solvnecy II has shown that the existing templates do not provide sufficient information on location of risk to enable effective cross-border supervision.  Therefore, we do not consider retention of the existing templates as a viable option.\n\nThe observations on proportionality are noted.  It is not possible to introduce a threshold for template S.04.04 on location of underwriting (where information is required for cross-border statistical exchanges), but a threshold (e.g. 5% of GWP by LoB) could be considered for location of risk reporting in S.04.05."]
["Reporting","S.05.01",null,"The definition of \"balance - other technical expenses / income\" remains unclear. Technical expenses are usually available on level of lobs.\nC0010 to C0120 with R0410 and C0210 to C0260 with R1710. \"Changes in other technical provisions\": These items should be dropped. Where should the content be included in the future (in C0200 / R1200 or C0300 / R2500)?\n\nC0300/R2500 \"Balance - other technical expenses/income\": Here it is said that \"tax\" should not be considered. What is to be done with the \"fire protection tax\", which is to be paid from the collected premiums [without insurance tax] and contributes to the underwriting result at least under HGB? Is it to be considered in another position or no longer at all?\n\nC0200 / R1200 and C0300 / R2500. \"Balance - other technical expenses / income\": Should the \"fire protection tax\" be included? Should the equalization reserve still not be included?\n\nIFRS 17 marks a paradigm shift in the accounting treatment of underwriting. The two QRTs (S.05.01 & S.05.02) must not force the industry to continue with the IFRS 4 system.\n\nThe QRTs call for much more than \"just\" contributions. The QRTs S.05.01/02 are P&L based, which do not exist under SII. If the P&L is prepared according to IFRS, the QRTs should also follow this logic. Therefore, both QRTs should consider an IFRS 17 compliant reporting structure.\n\nHigh complexity and lack of transparency:\n    - No reconciliation/reconciliation between IFRS 17 items in P&L and QRT.\n    - Structural break in external reporting between IFRS and SII (RSR/SFCR)\n    - No comparability between HGB (German GAAP) and IFRS users, even if same structure is used\n\nSolvency II refers to Directive 91/674 / EEC in Directive 2015 / 245o for the QRT S.05.01. According to the current understanding of EIOPA, this must be implemented even after the introduction of IFRS 17. Under this assumption, the values ​​are to be determined in the same way as previously (because premiums paid (IFRS 17 Disclosure Statement) does not correspond either to premiums written or premiums earned)). For this reason these values cannot be taken from IFRS 17 Disclosures (current version), so it is an additional information for Solvency II. The question is whether the 91/674 / EEC Directive is really still applicable at Group level following the introduction of IFRS 17 (in the QRT, if applicable). Conversely, this is of course a contradiction to the sentence  in 2015/2450 / EEC that the figures come from the published financial statements: LOG File for S.05.01: \"Groups shall use the recognition and valuation basis as for the published financial statements, no new recognition or re–valuation is required,...\". In our view, EIOPA should clarify what IFRS Group accountants should do under SII and whether the 91/674 / EEC Directive will continue to apply after the introduction of IFRS 17. That does not really fit together. Another option would be to delete S.05 QRTs for groups.\n\n- Due to the fact, that the rows “changes in other technical provisions” are deleted (old R0410-R0500), we would now report it in R1200. Is this approach correct?\n- Shall R1300 contain “all technical expenses”, namely the incurred expenses (R0550) plus the technical expenses of (R1200), excluding the technical income reported in R1200? Or shall It also include technical income of R1200?\n- If the first applies, the check BV214 (R1300 = R0550+R1200) won’t make sense anymore.","Public","GDV","The change in other technical provisions is not included in the item \"Balance - other technical expense/income\". The instruction of the item is amended accordingly.   \n\nFor German undertakings „Fire protection tax“ is a national specificity. The mapping will be done on the national level. The equalization reserve should still not be included. \n\nEIOPA recognizes that IFRS17 will bring material changes in the recognition, valuation, presentation, disclosure of insurance contracts. However, the template S.05.01 will be kept as it is now even if IFRS insurers don´t report the written and earned premius in their accounting P&L. The main reason is to maintain consistent basis of reporting for all insurers (IFRS and local gaap users). Further reasons:\n1) Although linked to accounting, S.05.01 is not a P&L but simply requires some P&L related items to collect some volume measures to measure the performance trend and for market wide analysis;\n2) This approach is already in place today with regard to insurance contracts with no significant insurance risk, whose written premiums/claims paid are not accounted for in the IFRS P&L (according to IFRS 4) but are still to be reported in S.05.01;\n3) The mandatory disclosure of IFRS 17 on premiums/claims paid would allow undertakings to fill in S.05.01 following the current approach;\n4) Re(insurance) undertakings will have to keep track of written/earned premiums for MCR/SCR calculation.\n\nFor IFRS17 users: Written premius/claims paid will be reported in the notes to the financial statements.\n\nTotal expenses (R1300) should include the incurred expenses (R0550) plus the technical expenses from the item \"Balance-other technical expenses/income\" (R1200). The validation BV214 can be deactivated."]
["Reporting","S.05.02",null,"The LOG-Files do not reflect the adjusted position \"balance - other technical expenses / income\".\n\nIFRS 17 marks a paradigm shift in the accounting treatment of underwriting. The two QRTs (S.05.01 & S.05.02) must not force the industry to continue with the IFRS 4 system.\n\nThe QRTs call for much more than \"just\" contributions. The QRTs S.05.01/02 are P&L based, which do not exist under SII. If the P&L is prepared according to IFRS, the QRTs should also follow this logic. Therefore, both QRTs should consider an IFRS 17 compliant reporting structure.\n\nHigh complexity and lack of transparency:\n    - No reconciliation/reconciliation between IFRS 17 items in P&L and QRT.\n    - Structural break in external reporting between IFRS and SII (RSR/SFCR)\n    - No comparability between HGB and IFRS users, even if same structure is used","Public","GDV","EIOPA recognizes that IFRS17 will bring material changes in the recognition, valuation, presentation, disclosure of insurance contracts. However, the template S.05.01 will be kept as it is now even if IFRS insurers don´t report the written and earned premius in their accounting P&L. The main reason is to maintain consistent basis of reporting for all insurers (IFRS and local gaap users). Further reasons:\n1) Although linked to accounting, S.05.01 is not a P&L but simply requires some P&L related items to collect some volume measures to measure the performance trend and for market wide analysis;\n2) This approach is already in place today with regard to insurance contracts with no significant insurance risk, whose written premiums/claims paid are not accounted for in the IFRS P&L (according to IFRS 4) but are still to be reported in S.05.01;\n3) The mandatory disclosure of IFRS 17 on premiums/claims paid would allow undertakings to fill in S.05.01 following the current approach;\n4) Re(insurance) undertakings will have to keep track of written/earned premiums for MCR/SCR calculation.\n\nFor IFRS17 users: Written premius/claims paid will be reported in the notes to the financial statements. "]
["Disclosure","S.05.02",null,"The LOG-Files do not adequatly reflect the adjusted position \"balance - other technical expenses / income\".","Public","GDV","Comment is not clear. The changes introduced in the template are aligned with the changes in the LOG file."]
["Reporting","S.06.01",null,"The industry welcomes the removal of this template. ","Public","GDV","Noted"]
["Reporting","S.06.02","Both","We understand that the list of assests template S.06.02 is seen as a core template. It contains already today a comprehensive set of information, the reporting of which already requires a great deal of effort. With the new proposal many changes have been suggested to be added to this already extensive template. The introduction of these new requirements and fields means a high administrative and technical effort. This need to be considered carefully by the supervisory authority and a careful balance must be struck between the associated benefits on the one hand and the associated costs on the company side. \nSome of the new information required can hardly be considered improving the template, like:\n•\tApplicability of bail-in rules\n•\tDetailed information on property\n•\tECB add-on items (write-offs/write-downs and issue date)\n\nIn detail:\n• Field CIC 87: \nMortgage loans to directors qualify for both CIC 84 and CIC 87. Which classification should lead? Why then is the other class still required?\n• Field CIC 88: Other mortgage loans qualify for both CIC 84 and CIC 88. Which classification should be leading? Why is the other class still needed?\n• Field C0141 (write-offs/write downs): A value should not be reported mandatory unless there really is a write off or write down with regard to an asset. Depreciation and amortization with a value of EUR 0.01 only seems to serve statistical requirements. In addition the amount depends on the accounting framework of the insurance entity and as such is not comparable. \n• Field C0240 (issuer group): With this proposal the ultimate parent of the funds would have to be reported. This information is not yet available to the companies in every case and would have to be additionally requested from the fund managers. \n• Field C0292 (SCR calculation approach for CIU): This field, which links pillar 1 and 3 we see critical. These linkages are difficult to handle in the processes as the computation of a fund is not stable but depends on the data quality delivered by the external funds manager. Thus, the actual kind of computation can only be determined very late in the data collection process. In addition the administrative effort would increase.\n• Field C0295: (crypto assets): In case of funds, the information as to whether an asset is linked to crypto-assets is not yet available to the companies in every case and would have to be additionally requested from the fund managers. Each additional introduction of another field in an existing template is technically complex and requieres additional recources and a high administrative effort.\n• Field C0296/0297 (property type / property location): If the property is acquired as part of a fund, the companies currently do not have the newly requested information “property type” and “property location” in every case. It would have to be additionally requested from the fund managers. This means additional effort, whereby the added value of this information is questionable.  If at all, this query should be made via an extension of the CIC. This could also provide a reconciliation and consistency to the balance sheet (as a measure of risk). \n• Field C0301 (Long-term equity investments - LTE) : We understand the requirement to disclose whether a collective investment undertaking falls under the provisions of Art 171a Delegated Regulation 2015/35 as LTE to mean that the disclosures should only be made if the entity actually makes use of Art 171a for that investment. In some cases, the companies refrain from doing so because the determination of the fulfilment of the criteria appears to be disproportionately time-consuming.\n• C0310 - Holdings in related undertakings, including participations: the opitions in the ITS do not fit to XBRL-Taxonomy.\n• C0330: We expressly welcome the simplification of the data for this field.","Public","GDV","1)\tCIC 87 and CIC 88: The new CIC for loans and mortgages to natural persons should prevail over the others. Clarified in the instructions.\n2)\tCIC0141 (write-offs/write downs): Agreed on the relevance of the deprecation or amortization. It should be independent from the accounting framework. It corresponds to the part of the notional amount that is \"lost\" due to the impairment of the loan or non-negotiable debt securities. After considering the comments received EIOPA decided to not introduce these new cell and they have been removed from the final ITS package\n3)\tC0240 (issuer group): Please note that the requirement isn’t new. The purpose of this change is to clarify the instructions, as a result of doubts raised by some undertakings and is alligned with a Q&A on the topic.\n4)\tC0292 (SCR calculation approach for CIU) Noted. EIOPA expects that the calculation approach used is stable. If there isn’t enough regular information to use a higher level of look-through then a lower level should be applied.\n5)\tC0295: (crypto assets): Noted. EIOPA understands that this is a subject which is somehow new in the financial markets and expects that insurance undertakings report the information that is available at each moment.\n6)\tC0296/0297 (property type / property location): Please note that these items are only applicable to CIC Category 9.\n7)\tC0301 (Long-term equity investments - LTE): The understanding is correct.\n8)\tC0310 (Holdings in related undertakings, including participations): Amended\n9)\tC0330: Noted."]
["Reporting","S.06.03","Both","The EIOPA proposal regarding the fund look-through essentially provides for a continuation of the previous requirements. We very much welcome the fact that the original plan to introduce a new template QRT S.06.04 for detailed fund look-through is no longer being pursued. Instead, S.06.03 shall be kept as it is currently. From our point of view, however, there is still a need for adjustment at S.06.03.\n\nWe are still of the opinion that funds which are contained in unit-linked products where the risk is borne by the policyholder should be exempted from the look-through requirement of S.06.03. At least in cases where the insurer doesn’t have influence on the investment strategy of these funds. Insurers are dependent on data supplied by fund management companies for this purpose. The data received for each fund has to be validated and aggregated by the insurer. This means a huge amount of data which is costly to generate. At the same time insurers bear no financial risk for such funds, so that a look-through for unit-linked funds is insignificant to a risk reporting for Solvency II purposes. We are positive regarding the efforts to access the ECB statistics on the assets and liabilities of investment funds and EIOPA’s decision to wait for the AIFMD, UCITS review and the EC’s work on the supervisory data strategy as this would offer the possibility to have the information available in the future through another data flow. Particular attention should be paid to which data requirements resulting from S.06.03 on mutual funds, i.e. funds where the insurer usually has no influence on the investment strategy, which involve a lot of effort on side of the insurer, are redundant due to availability by other means.","Public","GDV","Noted. EIOPA notices the effort necessary for the collection of the data. Nevertheless, the data is necessaryfor supervisory purposes. The data should also be interesting for the insurance companies.   "]
["Reporting","S.06.03","Both","Some remarks in regard with the original planned new QRT S.06.04 for a “detailed fund look-through”: We very much welcome that EIOPA no longer considers to implement a new S.06.04 for a detailed look-through. We share EIOPA's view that the requested information is already available within the financial sector supervisory framework so that EIOPA will only have to engage the relevant authorities to ensure that both National Competent Authorities and EIOPA will have access to that information in the future. Against this background, it would be all the more surprising if respective detailed look through data of funds could be requested on an ad-hoc basis by NSAs by using the originally envisaged template S.06.04. It is understandable that the supervisory authorities need to have access to regulatory relevant funds-data given the importance that investments in UCIs can have in the portfolio of the insurance company. But as EIOPA itself states, the information is available at least in relation to EU euro countries so that EIOPA only needs to access it. \n\nAs EIOPA states rightly, the introduction of a regular template for only a temporary time horizon (due to the considerable implementation costs) is not reasonable and too costly. This must be all the more true in case of an ad hoc query. The realisation of such an ad-hoc data query would not only be costly but very difficult to carry out, since the undertakings would have to request the respective data from the fund managers of the funds, process it and only than could report the data to EIOPA. For smaller companies in particular, the effort required with such an ad-hoc query is disproportionately high. Therefore the application of the proportionality principle in case of an actual ad hoc query is of utmost importance. This should be reflected, for example, in the selection of the companies included and in the scope and level of detail of the data requested. The level of detail currently envisaged appears in any case too high to be met with reasonable effort. \n\nIn this context, we would like to point out a particularly critical element of the originally planned template S.06.04. The intended fixed limit of one month for the usable reference date is seen to be very critical and unlikely to be feasible in practice for all funds. Regularly fund managers don't have monthly reporting processes for the data deliveries but quarterly. So current deliveries – e. g. via so called Tripartite Template TPT – are regularly based on a quarterly cycle. Besides that not all data is available with a maximum delay of one month. So it doesn’t seem to be feasible for insurance companies to use only fund data which is not older than one month for this reporting. In addition, the production and delivery of such data – if possible at all – would entail a considerably amount of effort and costs. The requirement that only data with a fixed maxi-mum delay of one month are allowed. At least a maximum delay of three months should be possible. In any case, due to the required high effort of such ad hoc queries companies would need sufficient time in advance to fulfill the requirements. ","Public","GDV","Noted."]
["Reporting","S.06.04","Both","While the industry acknowledges the need for specific climate related reporting in particular in relation to transition risk and physical risk, it highlights that regarding sustainable investments, the first KPI will be requested NFRD or CSRD reporting and would as such lead to duplication of reporting requirements. In principle, insurers should only have to do sustainability reporting in one reporting format. From the industry's point of view, the CSRD is the preferred format (file-only-once-principle). This also holds true for the scope of the reporting entities. With the ongoing revision of the CSRD more insurers will have to report on Sustainability KPIs. Therefore, we are of the opinion that an extension of the duty to all Solvency II companies is not expedient, even if thresholds are applicable. We are also of the opinion that there must not be an expansion of reporting obligations due to reporting obligations at group and individual company level. Any relief granted by the CSRD (i.e. only group level reporting) should be maintainde. Furthermore, the timely aspect should be noted. Following the adopted delegated act on Article 8 Taxonomy, insurers have to report the first KPI starting from 2024. Therefore insurers in scope of the CSRD should not be forced to report this KPI at an earlier stage. In case that this or any other Taxonomy-related KPI(s) shall be included in QRT reporting at this stage or in the future, it needs to be ensured that the SII effective date is aligned with the Taxonomy Regulation and that insurers are not required to report this KPI at an earlier stage for SII purposes. We believe, that SII should not undermine any decision already taken at EU level with regard to content, scope or timing of KPIs.\n\nThe following two KPIs are new and cannot be derived from existing regulations or regulatory projects, in particular not from the delegated act on Article 8 Taxonomy. Even if, for example, transition risks are taken into account in the risk management of the companies in the known risk types, this does not mean that key figures can also be calculated about them without further ado. The indication of a mere key figure in S.06.04 is also not sufficient to enable the supervisory authority to identify affected economic activities. EIOPA has already identified relevant economic activities in the sensitivity analysis. Building on this, a common understanding could be developed on which economic activities could be complemented. This common understanding should be aligned and consistent with any other EU legislation referring to such risks (via KPI or reporting standards). With the NACE codes in S.06.02, EIOPA would then have the possibility to determine the affectedness itself and not leave this to individual methods of the institutions. This would also significantly increase the comparability of the key figures of the individual companies. ","Public","GDV","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\nAs to the methodologies for reporting the physical and transition risk, building on previous work,  EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs and builds on existing and ongoing work at EIOPA on transition and physical climate risk. The ORSA will support the reporting of the KPI for prudential purposes.\n\nWe welcome the comment on the usefulness of the NACE reporting to improve comparability of metrics. "]
["Reporting","S.07.01","Both","The industry is disappointed that neither the current threshold nor the template itself is improved. \nTemplate S.07.01 requires very detailed data for some specific instruments that in many cases has to be provided by specialised data providers. We agree with EIOPA that structured products can enclose signifi-cant risks, but this is not necessarily the case. At the same time it is questionable, if the detailed data which have to be reported via S.07.01 give the NCAs a relevant additional insight. Therefore, we are of the opinion that a simplification of this template by deleting the items C120 to C190 - as discussed in the consultation paper – would be adequate.\n","Public","GDV","EIOPA disagres and keeps the template as it is. EIOPA further discussed the possibility to improve the threshold . The proposed threshold by the industry - s defined in Annex IV — Asset Categories of this Regulation and the sum of item C0010/R0070 and C0010/R0220 of template S.02.01,– is higher than 10% has been analysed. EIOPa consider current threshold to be adequate and will keep it.EIOPA disagrees with the deletion of items C120 to C190. "]
["Reporting","S.08.01",null,"•\tDeletion of column (delta) is positive.\n•\tThe column notional amount in original currency seems to be relevant. \n•\tThe other columns should not be implemented (unique transaction identifier, currency of price) as it does not add any relevant information.\n•\tIn addition, it is noted that instead of using the information available in EMIR reporting, EIOPA is asking companies to report the same level of information (the new fields seem to just replace what is proposed to be deleted) and merely provide an EMIR identifier. \n\nThe unique transaction identifier is another example for duplicating regulatory information. Another question is, if it would be better to ues CAU instead of CA. \nFurther Guidance is needed on the following questions:\n-> Which information should be reportet for derivatives not in scope of EMIR?\n-> The price (=rate) is usually given in % and is therefore independent of the underlying currency. How does this parameter differ from C0370/currency.","Public","GDV","EIOPA explained the reasoning behind the options taken regarding how and when to take into account EMIR data, in paragraphs 2.168 to 2.176 of the Report on quantitative reporting templates (EIOPA-BoS-20/754, 17/12/2020), including the link between SII template and EMIR database.\n\nOn the use of CAU instead of CA, item C0280 will be amended in the instructions. Instead of CA – Code attributed by the undertaking, the option “Specific code” will be introduced.\n\nOn which information should be reported for derivatives not in scope of EMIR, a specific code shall be reported and the instructions will be amended to clarify it"]
["Reporting","S.08.02",null,"The industry welcomes the proposal to delete this template. ","Public","GDV","Noted"]
["Reporting","S.09.01",null,"In regard with S.09.01 it still has to be noted that Solvency II is based on an economic perspective and does not have a \"profit or loss account\". The impact of the Basic own funds is relevant. However the requested information also duplicates information already provided in the Financial statements.\nIn addition investigations of income / losses and unrealized gains / losses of non-direct managed CICs are very costly. For example : CIC 7, 8 and 9.","Public","GDV","EIOPA disagrees. The template is kept as of today without introducing additional data."]
["Reporting","S.10.01",null,"The industry is disappointed that the threshold for this template was not improved. According to field C070 in template S.06.02 the indication of the fund number is not mandatory, unless otherwise required by the national supervisory authority. This should also apply to template S.10.01, so field C050 should be adapted accordingly. The requirements of the templates must be consistent in this respect.  ","Public","GDV","Agree. Amended"]
["Reporting","S.11.01",null,"The industry welcomes the introduction of a threshold for this template.  ","Public","GDV","Noted"]
["LAC DT ",null,"Solo","As a general comment the amount of reporting required with respect to LAC DT is overly detailed and would imply an extensive effort to be prepared that is not balanced to the benefit in terms of supervisions. Furthermore, the whole set of QRT related to LAC DT seems to be prepared assuming a specific process of preparation of taxable profit before and after stress that could not be the same currently in force in each undertaking based on existing practices: as a consequence, to fill in each required information would require additional work and judgement or to adjust the process for LAC DT calculation. We also highlight that the filing of the information required would be highly subjective and hardly to compare in country (such as Italy) where more than one income taxes with different tax profit calculation exists.\nWe believe that any additional information to be provided with respect to those already included in QRT S.25 should be agreed at national supervisory level, taking in account the several differences existing in income tax law, regulations and common practices in place in each country.\n","Public","Unipol Group","The reporting of these items on an accrual basis will not facilitate the adequate supervision of liquidity risk. Moreover, the change in granularity should assist in the availability of this information. "]
["Reporting","S.12.02",null,"•\tWhile the industry welcomes the decision to keep this template unchanged, it refers to the paragraph with comments on the new templates S.04.03/04/05, thereby noting that the overall reporting burden for cross border requirements will increase substantially. \n•\tThe clarification of the definition of threshold regarding the negative technical provisions is welcomed. ","Public","GDV","Noted.  On S.04s please check the resolutions on these templates."]
["LAC DT ",null,"Solo","With respect to the threshold set for the reporting of column C0030 and C0040 of QRT S.02.01 we believe that the threshold should be set only with respect of net deferred tax assets and not also on net deferred tax liabilities. For prudential purpouses, an undertaking with a larger amont of deferred tax liabilities should be assumed to have a lower risk with respect to deferred taxes, with repect to an undertaking with a lower amount of net deferred tax liabilities.","Public","Unipol Group","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.14.01",null,"Despite strong concerns expressed by the industry in response to the reporting consultation back in 2019, a variety of extensions and changes have been proposed for this template. These changes will be burdensome and costly to implement. The industry sees that very critical.\nOn top of the extensive changes already announced in 2019, EIOPA suggests adding the following information on:\n•\tNumber of policyholders at the level of the products\n•\t“expected future commissions” differentiated also for new contracts \n•\ta yearly interest rate guarantee for the reporting year\n•\texit conditions of a product\n•\ton the amount on which the interest rate is guaranteed\nThe only justification EIOPA is providing is that this template is extensively used by supervisors.\nThe effort of determining will be burdensome and very time-consuming and the meaningfulness of the level of detail is questionable. The required data is not readily available and the determination partly only possible by approximation. The detailed consideration of the costs / commissions required is also challenging.\nThus the question arises: what is the goal, purpose and concrete added value for the assessment of the solvency and risk situation?\n\nThe comments previously made in the context of the 2019 consultation on this template remain valid:\nIn future, the premiums written per product are to be further broken down into additional 3 dimensions: at the level of single premiums/current premiums, at the level of sales channels (direct/via credit institutions/other) and at the level of portfolio/new business. Such a granular breakdown is currently not available, and could only be delivered at great expense, if at all. The large number of dimensions whose purpose and goals are not comprehensible are leading to a big effort.\nNeither the commissions paid at product level nor the required breakdown of commissions into existing and new contracts are currently available. This information could only be obtained with additional effort, and implementation is not feasible at present. Against this background, industry believes this requirement is not acceptable. The reasons for EIOPA’s decision to introduce a sales view for many templates is unclear. Many new data queries are not possible because data with this level of granularity is not available in the companies. It would be appreciated if EIOPA could further explain the supervisory purpose of these new requirements?\nThe reporting on the expected future premiums of new contracts in the FY is burdensome. Implementing the reporting requirement involves a great deal of effort, as additional model points and projection calculations would be necessary.\n\nDetailed questions: \n(C0061 to C0063): Distribution of the written premiums according to \"distribution channels\" (direct, credit institution, other insurance distributors). According to this we have the following question: Are sales via sales force partners still direct or are sales force partners already \"other insurance distributors\"? Distribution channels should be more clearly defined, especially with respect to \"other insurance distributors.\nIs it correct that the template is no longer to be created for the “accepted reinsurance business”?\n\n(C0071-C0073): This Detail consitutes significant additional expense for companies. The definition of commission does not correspond with BaFin's wording in its queries on payments to intermediaries. Therefore:\no Significant effort is to be expected (again) on the part of the companies. \no Ambiguities regarding the definition are to be expected.\no The differentiation between commissions from single-premium and ongoing premium business is new and will probably have to be redrafted.\nFurther, commissions are one part of a cost line item and provide insight into insurers' business models. It stands to questions what would be the concrete added value for the assessment of the solvency and risk situation? And if this can be handled with reasonable effort?\n\n(C0078): A further and extremely challenging look at future commission values again increases the effort considerably. In addition, data from the annual reports must be linked with projection data on commissions. These values (discount rate would have to be specified uniformly) are not available as raw data and would have to be determined first.\nTherefore, the question is allowed: What is the objective of this query, what additional value added in terms of solvency and risk situation should be determined?\nIf a \"forward\" view seems to be necessary, it might be sufficient to look at the contribution amount.","Public","GDV",{"$f":"+G197","v":"EIOPA notes that the new information required goes along with implementation efforts. Though, the additional information is considered necessary and should - at least in parts - already be available. E.g. the information on the yearly interest rate guarantee should be known to each undertaking, the same holds for the amount on which the interest rate is guaranteed, which may even be a local statutory figure.  Also, approximations are allowed for some of the figures required to reduce the burden. \n\nIn view of the concerns expressed and the implementation effort required, EIOPA however decided to limit the set of newly introduced information:\n-  Information on the amount of  premiums written by distribution channels is essential to allow for an assessment of relevance of sales channels. Currently availble soruce of information on distribution channels are limited. The added information allows to determine the business models used to commercialise certain products and possible concentration risks. EIOPA notes that the new information required may be a burden. However this information is deemed necessary to assess concentration risks and determine the changing distribution patterns - i.e., more reliance on own channels. Moreover, information on written premium by distribuition channels should be already available to insurance undertakings as they should know the channels through which they are writing premium/selling certain products to monitor risks arising from distribution. This information for several Member States and in a more granular manner (i.e., more granulirity in terms of distribution channels) is published annually by InsuranceEurope itself showing that for several markets this information is available. Aware of the possible burden to undertakings, to strike a balance between supervisory needs and and limiting the reporting burden EIOPA has reduced the number of new cells by reducing the granularity required on premiums written by distribution channel, no longer requiring a split between regular and single premiums.  \n- Commissions represent a key information on products being extensively used for understanding insurance undertakings' business model and sales strategy, including to identify whether the possible higher commissions could raise solvency issues and/or increase mis-selling which in turn could lead to solvency risks. This includes information on expected future commissions to allow an assessment of the commissions paid during the whole life-time of the contract. EIOPA also notes the burden to the industry but also notes that the information on commissions paid during the year should be already available as it should be calcualted for both pricing purpose and when commissions are paid to intermediaries. The information on expected future commissions is part of the calculation of the best estimate liabilities, approximations can be used to determine the necessary information. To strike the balance between supervisory needs and possible burden to the industry EIOPA dropped the breakdown between commissions for new contracts for single and regular premium products and no longer requires the information on expected future commissions for new contracts.\n- Information on expected future premiums is important to assess the volume of the business across the whole life-time of the contract and provide a volume measure to which the commissions are compared (i.e. to determine a sensible commission rate). We acknowledge the additional burden on undertakings and the necessity for approximations and simplifications. Also, to reduce the burden, the information does no longer be separately provided for new business.\n- Further, to reduce the burden the information on number of surrenders during the year was simplified and no differentiation for new contracts is required.\n"}]
["Reporting","S.14.02",null,"New Template Non-Life business – policy and customer information:\n\n• The proposed QRT s.14 non-life will require a lot of work for almost no added benefit.  If EIOPA would decide on asking additional information on non-life, a possible alternative to be considered could be an extension of existing templates to cover information for the largest total number of single risks by sum insured. \n\n• In fact, the QRT is not needed for prudential reasons and Solvency II reporting should remain limited to prudential reporting only. The insurance sector deems it inappropriate to use QRT-prudential reporting for conduct of business/consumer protection purposes.\n\n• The template requests several datapoints for products split across 27 categories which is deemed inappropriate and will be burdensome and costly to implement. This would introduce a new, third categorization to Solvency II, on top of the existing two categorizations systems: lines of business and branches. It would be burdensome to make another product classification, in addition to the LOBs and the internal classifications that are currently being used. Some member states are already reporting information on these branches to their NSA. As such, any new reporting based on different categories will be burdensome to implement and will not be useful as it lacks the required history for analysis. It is also expected that the new QRT will not replace existing national reporting. Beyond that, the proposed product categories are more granular or are split up differently than the homogeneous risk groups regularly used in the calculation of the technical provisions. So many undertakings are not able to fulfil the requirements of template S.14.02.\n\n• The description uses \"Risk Classes\" and \"Subclasses\", but a definition or a reference is missing. Therefore the description is unclear. It also contains logical errors, e.g. Product category 10 \"Building insurance: Insurance products covering damages to a building, different from what already covered under product categories 9, 10 and 11\". The fact that the exclusion also includes the product category 10 leads to an irresolvable contradiction. \n\n• The product categories 15, 24, 25 should not be separated. Where is \"risk class 13, subclass III\" defined? \n\n• It's not clear, when a product is to be reported as main product and when as an add-on. \n\n• The requested data is in some cases not available, such as the written premiums by distribution channels (in contrast to statistical premiums). \n\n• To monitor climate risk, EIOPA proposed to introduce two new cells: Proportion of premiums covering climate-related perils (0-100) and Allowance for climate-risk prevention measures in product design (Y/N) this information overlaps with the taxonomy screening criteria applied to report the taxonomy aligned underwriting activities under the NFRD/CSRD. As insurers under the NFRD will already have to disclose the sustainability of their underwriting activities based on detailed criteria, it is key that any newly proposed requirement is consistent with and fully considers the ongoing Taxonomy requirements under the NFRD, as well as its timing and scope of application. However, the requirement “Proportion of premiums covering climate-related perils” would neither reflect Taxonomy eligibility (as currently understood) nor Taxonomy alignment nor the result of looking at one specific TSC (see TSC 3.1: “Insurance products sold under the insurance activity offer coverage for the climate-related perils where the demands and needs of policyholders require so”); therefore, even for CSRD companies, it would translate into an additional reporting burden without any indication for an incremental information value. Also, it would add complexity and confusion as to why, for SII purposes, different metrics related to the Taxonomy are deemed as relevant than for Taxonomy reporting itself, especially given that it is anyway questionable why this should form part of prudential reporting. Where Taxonomy-related reporting is intended, maximum alignment should be sought and deviations should be minimized wherever possible, i.e. CSRD companies should be able to comply at Group-level via cross-referencing, while other companies (incl. subsidiaries) should be exempted.\n\nIt should be emphasized that these requirements would relate to a Solo-level QRT only, calling the proposals to include Taxonomy-related disclosures even more into question.\n\nGenerally, the purpose of reporting certain contents twice is questionable. A more granular and inconsistent reporting with the taxonomy is to be refused strongly.\n\n• (C0070-C0090) per product code - information on gross premiums written differentiated by distribution channels: Significant additional work for many companies. The data allow insights into the strategic orientation of the companies. The goal, purpose and concrete added value for the assessment of the solvency and risk situation remain unclear.\n\n• (C0100) per product code - details of commissions paid during the year - total: Considerable additional work for the companies due to the establishment of the new query. The definition of commissions is likely to lead to many queries and demarcation problems, especially in non-life. And again: What is the goal, the purpose and what is the concrete added value for the assessment of the solvency and risk situation.\n","Public","GDV","EIOPA is aware of the additional burden which this template may require and it has carefully assessed the information to limit requests. However, significant gaps exist on data on non-life insurance liabilities for products. These gaps were further highlighted with the pandemic and in relation to NatCat event. \n\nTo reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n\n\nMore guidance on how o report add on  vs. basic products have been now reported in the instructions.\n\nIn relation to the questions being raised as to the prudential need of having a product by product reporting for non-life insurance products, it is important to note that the information is limited and it will help NCAs in better understanding product structures and issues around products which could have a prudential re-percussion. In particular taking into account that it is difficult to have visibilty on the product categories specified given they either fall under multiple lines of business or multiple products fall under the same line of business. Moreover, recent crisis events highlighted the supervisory needs to have an overview of the number of products and their features rather than just collecting information a line of business basis. For example, because of information being collected on an insufficient level of granularity, when the COVID-19 crisis materialized many supervisors had not visibility of how many business interruption or travel insurance products were being sold and which undertakings were mostly exposed limiting the possibility to assess the prudential of the crisis. Similarly, looking at the increased risk of climatic catastrophic events it is important that supervisors have information on which products cover (and to what extent) climate change related risks to then assess possible prudential impact. \n\n\nMoreover, the annual collection of product related information would limit ad hoc requests from supervisors which are often burdensome and uncoordinated. It would also limit the risks that new reporting requirements are being developed at the national level to fill the gap on product related information. \n \nFor what concerns  the presence of infiormation by distribution channel we deem proportionate of relavance to collect this inforation as  of relevant supervisory value to analyse distribution patterns and assess possible concentration risks. We also deem possible to gain this breakdown of information.\n\nFinally in relation to the commission information, the definition is alligned to the proposed S14.01 information.\n"]
["Reporting","S.14.03",null,"New Template Cyber Risk:\nAs stated in response to the 2019 consultation on supervisory reporting and public disclosure, we acknowledge that there is merit in including cyber risks in the scope of the Solvency II reporting package, in order to better understand this emerging risk. The industry also agrees that information on underwritten cyber risks should be reported on an annual basis.\n\nHowever, the german industry does not agree that EIOPA’s objective of a ‘deeper understanding of cyber risk’, as indicated in the 2020 Solvency II Opinion, necessitates the detail of reporting envisaged by the draft template.  Furthermore, it is questionable whether companies can report on cyber risks with data of the level of granularity requested by EIOPA in the draft template. This was already indicated by the results of the 2018 stress test on cyber, during which participating companies had difficulties providing the requested data, a point acknowledged by EIOPA in its report on QRTs as part of the December 2020 Opinion on the Solvency II review. The industry also questions whether certain requested information, such as target market details and cyber coverage in the product category, would add value to the supervisory efforts to understand the cyber insurance market. Reporting requirements which generate superfluous data and offer no useful insights should be avoided at all costs as they are inherently disproportionate.\n\nSimilarly, the industry is concerned that the draft template, as it stands, would significantly increase the burden on a significant number of entities, especially those with only a limited cyber insurance portfolio. While the EU cyber insurance market is growing, it is still at an early stage of development, representing only a very small fraction of non-life premiums in EU markets. Requiring companies to provide detailed reports on their cyber insurance business, whatever its size, would therefore be disproportionately burdensome – both in terms of costs and resources – considering the size of the market. This is especially true given that the information requested in the draft cyber template is more detailed than what is requested for other non-life product categories, for example [S.21.02]. Therefore, at this point in time, we oppose the introduction of a template for reporting cyber risks with the level of detail proposed in the consultation paper. The introduction of a detailed template on underwritten cyber risks in general should be delayed until such a time as when the cyber insurance market grows to a size and market share that justifies such reporting.   \n\nConsidering this, GDV has the following comments on the draft template:\n\n– Reporting should be subject to the principle of proportionality based on the size and complexity of exposures, translating into reduced reporting for undertakings with simple, non-complex risk profiles. Therefore, we regret that EIOPA no longer proposes to apply a threshold to the cyber reporting template (as was included in the report on QRTs accompanying the Opinion on the 2020 review). Given the level of detail contained in the draft template, only companies for which cyber is a significant line of business should be required to report on their business. With this in mind, EIOPA should adopt a reporting threshold by reference to gross written premiums set at least at 10% to ensure reporting requirements apply only to market participants with a larger presence in the cyber insurance market. Detailed reporting requirements which are not subject to a threshold are also likely to disincentivise new entrants into the cyber insurance market, standing contrary to EIOPA’s stated aim of encouraging the growth of the market.\n\n– Cyber risk products should be clearly defined e.g., as insurance policies that cover loss caused by an information security breach. An information security breach means an impairment of the availability, integrity, or confidentiality of electronic data of the policyholder or of information processing systems which are being used by the policyholder. \n\n– Only affirmative cyber risk products should be reported.\n\n– The draft template requires cyber as add-on coverage to be reported (C0040), however only standalone cyber products should be included in the scope of reporting. Given the wide variety in the type of add-on cyber coverages, which can range from single clauses to extensive cyber add-ons, it is not feasible to report on cyber as add-on coverage without such reporting amounting to a considerable burden on companies. It is also not immediately obvious what value this type of information would add to a cyber insurance market analysis.\n\n– Reporting should be limited to direct business, as corresponding figures from active reinsurance business could not be adequately reported or would not be comparable. Example: Number of claims for reinsurance quotas not available, claims payments only available for pure cyber quotas, but not for mixed contracts International standards for a uniform taxonomy for recording exposure and damage data must be taken into account.\n\n– The requirement to include information on the target market (C0020) is excessive and it is unlikely to add any value to the supervisory analysis. \n\n– As it currently stands, the reporting line ‘description of risks included in the coverage (C0060)’ is overly detailed and it is unlikely that it will be possible for many companies to report such information in practice. As a point of comparison, the existing QRT on non-life underwriting risk [S.21.02] only requires the 20 biggest single underwriting risks to be listed, a more proportionate approach. \n\n– The draft template requires product categories to be reported separately (C0030), however cyber insurance products are generally combinations of different product categories and, as such, are difficult to unbundle and separate. Instead, companies should only be required to report on which of the three categories of coverage (first party loss, third party loss, or costs and related services) are included in a product.\n\n– A separate reporting for every currency (C0070) is excessive. There should be an appropriate threshold. \n\n– A cyber product, as a combination of different product categories, usually has several insured sums as well as possible additional sub-limits. These different sums cannot be aggregated reasonable, and it is therefore unlikely that it will be possible for many companies to report their sum(s) insured (C0080).\n\n– Insurers usually have a combination of different reinsurance coverages (quota share, XL…) that cannot be aggregated reasonable. It is therefore also unlikely that it will be possible for many companies to report their sum(s) reinsured (C0100).\n\n– The requirement to provide information on the number of claims (C0110; C0130) is also excessive with no evident value that this information would offer.  \n\n– The requirement to report the technical provisions (C0140) should be replaced by the reporting of case-by-case-reserves as the former do not exist in this granularity at product level and would have to be allocated down to the cyber product categories, leading to spurious degrees of accuracy.","Public","GDV","EIOPA acknowledges the difficulties in being initialy able to provide the requested information, but doesn not see as a valid justification the fact that undertakings might not be able to derive the requested information from the data on underwritten policies. information on lines of business impacted, premiums and technical provsions represent the basic information that constitutes the basis for good risk management practices. Furthermore, delaying the application of the reporting until the market further develops might not only make things more difficult, but also compromise the necessary monitoring of market development for such emerging risks. With regard to proportionality, thresholds have been established to the template in line with the ones already included in the 2020 review opinion. On information sharing and feedback to the market, EIOPA will embed this objective in the implementation of the Cyber Underwriting Strategy in the context of EIOPA being a facilitator in the market development for cyber risks.\nOn the granularity of the information required in the single cells, EIOPA believes it is time to focus for undertakings on identifying the key elements of cyber products as included in the proposed template. EIOPA strongly believes that this level of granularity shoud not only be provided from a reporting point of view, but also from the risk management point of view."]
["Financial stability guidelines",null,null,"In particular, S.14.02, S.14.03, S.14.04 and S.14.05 will lead to a very high effort. It would be very burdensome to report these templates 7 weeks after reporting reference date on such a granular level.\n\nThe two new templates 'S.14.04.11 Liquidity risk for life business' and 'S.14.05.11 Liquidity risk for non-life business' have to be reported each quarter and require information on a product level basis in open list form. Although most data required for reporting should be available, the initial effort to implement these QRTs is huge. In addition to that, there are some cells where the information is not directly available e.g. best estimate on a product level for non life. Furthermore it is unclear how these QRTs can help to assess liquidity risk. We strongly suggest not to implement these new templates.\n\nIf the intention to introduce these template is maintained nevertheless, at least a test run should be conducted by supervisors. In that way, firstly, supervisors could see if undertakings are able to fill in the data and secondly, if they can draw any conclusions from the received data. \n\nIn addition, the concept of proportionality must also be adequately reflected. Simplifications are needed for the implementation of the requirements. \n\nS.14.04.11: \nLiquidity information (life) on product level: Cash flow related information might be burdensome to report on such a granular level, other items (e.g. best estimate) might not be available at product level art all (e.g. because of collective FDB). \n\nHere, additional information is recorded for each product, some of which is not available in this granularity (costs, best estimate). The preparation causes considerable effort and in the end is not as meaningful as expected for some key figures - since they are only broken down. The quarterly reporting (on product level) is very critical. Effort and potential benefit are not in balance by any means. Aggregated values at total portfolio level appear to be perfectly adequate for the intended supervisory purpose and could be provided with moderate effort.\n\nInformation on payment flows at the product level could only be determined (approximately) with a great deal of effort, especially for reporting during the year. For some key figures (administrative expenses, best estimate, net reinsurance flows), lump-sum coding would have to be applied, which would contradict the expected granular information content.\n\nThe special features of health insurance should be taken into account.\n\nS.14.05.11: \nIn light of the exceptional circumstances of the ongoing Covid-Crisis, we can understand the current attention of macroprudential supervisors to potential liquidity risk in the insurance sector. Thus, the industry supports the current analyses conducted by EIOPA and NSAs such as the EIOPA-Liquidity analysis that started in 2020 during the Covid-Crisis and the data request by BaFin because of heavy rain event “Bernd”. \n\nHowever, in our view, regarding the business model of insurers and the already existing supervisory framework, liquidity risks are very moderate in the insurance industry and not a major source of potential systemic risk. The aforementioned EIOPA-Liquidity analysis confirms that the liquidity risk at the solo undertaking level is in general very low in the insurance industry. Thus, the industry does not see any need for the proposed additional regular reporting. Also, the proposed division in the product categories does not give meaningful insights regarding liquidity. \n\nFurther, we would like to point out that if undertakings are aware of liquidity problems, they already have to conduct an ad-hoc ORSA, which delivers thorough insights for the company and the supervisor.\n\nWe note that some undertakings might not be able to fill in the data in cell C0180 Best Estimate and cell C0300 Net Reinsurance flows because of a different structure of homogenous risk groups that makes it impossible to transfer the data to the proposed product categories. Another problem, that affects the results of cell C0300 is the frequency of reinsurance settlements and accounting, which often is less than quarterly.","Public","GDV","EIOPA acknowledges that whilst liquidity may be less of a concern than some other risks due to the business models, supervisors need to monitor the risk\nand assess the potential materialisation of the risk. Moreover, liquidity is mentioned among the relevant exposures for systemic risk in the IAIS hollistic framework (Information are also collected in the context of individual insurance monitoring (IIM)).\n\nFurther, EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information in order to reduce the burden for undertakings: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). Thus, most of these figures should be available in the capital reporting and should not require an excessive additional burden."]
["Reporting","S.15.01",null,"The insurance industry welcomes the proposal to remove these templates.","Public","GDV","Noted"]
["Reporting","S.15.02",null,"•\tThe insurance industry welcomes the proposal to remove these templates.","Public","GDV","Noted"]
["Reporting","S.16.01",null,"•\tThe industry welcomes clearer instructions as suggested.","Public","GDV","Noted"]
["LAC DT ",null,"Solo","We highlight that the information required in QRT S.XX.02-03, are in general overly costly to provide even if prepared on a \"best effort\" basis. Such unreasonable balance between cost and clear prudential usefulness is most evident in the requirement to:\ni) splt written premiums (R0210-220);\nii) split profits in current and new business (R0320-0330 and R0390-0400);\niii) reconcile taxable profit before and after temporary differencs (R0340-0370);\niv) provide the information reported in Taxation - Projections table (S.XX.02.01.04).\nWe therefore propose to delete the whole QRT S.XX.02-03 or, at least, to strongly simplify the information requested to reduce the implementation costs required.","Public","Unipol Group","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.17.02",null,"•\tWhile the industry welcomes the decision to keep this template unchanged, it refers to the paragraph with comments on the new templates S.04.03/04/05, thereby noting that the overall reporting burden for cross border requirements will increase substantially. \n•\tThe clarification of the definition of threshold regarding the negative technical provisions is welcomed. \n•\tThe extension of the scope of this template to reinsurance makes it more burdensome to report. \n•\tThe industry  welcomes the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions.\n•\tIt should also be noted that when the original templates were being drafted and exposed for consultation, it was pointed out to EIOPA that there was an inconsistency between S.17.02 and S.12.02 with respect to indirect business, but EIOPA did not amend the template following these comments. As such companies are now facing additional costs for these changes, which could have been avoided if industry comments were taken into account. ","Public","GDV","On S.04s comment please refer to the resolutions provided on the templates in the dedicated section.\nThe comment on clarification of the threshold definition is noted. However, please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold.\nOn the comment on the scope of the template to reinsurance market please note that the ITS amendment intorduced is based on the Report on quantitative reporting templates - part of the SII Review 2020 published in December 2020 at EIOPA web site (https://www.eiopa.europa.eu/content/opinion-2020-review-of-solvency-ii_en);. The proposals in the report are based on EIOPA's proposal and the public consultation done in 2019 and reflects the feedback received. As such EIOPA disagrees of removing the reinsurance of this template.\nOn the inconsistency between S.17.02 and S.12.02 the comment is not clear as both the QRT document mentioned above and the Consultation paper in 2019 - EIOPA - BoS-19-305 do not contain such reference.\n "]
["Reporting","S.18.01",null,"•\tThe proposed change to add ‘total recoverable from reinsurance’ for some LOBs will be burdensome to implement. \n•\tWhile the industry  takes note of the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions, it believes a threshold of 80% would be appropriate, with the proposed 90% threshold, smaller LoBs would have to be included. ","Public","GDV","On the \"total recoverable from reinsurace\" amendment, please note that it is is based on the Report on quantitative reporting templates - part of the SII Review 2020 published in December 2020 at EIOPA web site (https://www.eiopa.europa.eu/content/opinion-2020-review-of-solvency-ii_en). All proposals in the report are result of the  EIOPA's proposal and public consultation in 2019 reflecting he feedback received. Considering this EIOPA confirms the addition of \"total recoverable from reinsurance\".\nOn the threshold EIOPA disagrees of changing it to 80% and keeps it to 90%."]
["Reporting","S.19.01",null,"•\tThe industry welcomes clearer instructions as suggested.\n•\tProposed changes will mean a reduction in the template reporting requirement, which is positive. \n•\tWhile the industry  takes note of the improved threshold, it deems an 80% threshold to be appropriate. The industry highlights that with the proposed 90% threshold, smaller LoBs would have to be included. ","Public","GDV","Noted. However, as regards to the threshold EIOPA disagrees of reducing it to 80% and keeps the 90% as publicly consulted."]
["Reporting","S.20.01",null,"While the industry  takes note of the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions, it believes a threshold of 80% would be appropriate, with the proposed 90% threshold, smaller LoBs would have to be included. ","Public","GDV","EIOPA disagrees of reducing the threshold to 80% and keeps the 90% as publicly consulted based on the impact assessment."]
["Reporting","S.21.01",null,"While the industry  takes note of the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions, it believes a threshold of 80% would be appropriate, with the proposed 90% threshold, smaller LoBs would have to be included. ","Public","GDV","EIOPA disagrees. Based on the impact assessment the threshold is kept as publicly proposed of 90%."]
["Reporting","S.22.01","Both","• The volatility adjustment (VA) and matching adjustment (MA), are two key elements of the Solvency II Directive. Requiring companies to disclose the impact of MA or VA next to the transitionals can be confusing for policyholders and it may give the impression that long-term guarantees measures might be a potentially movable or ancillary element of the framework that might at some point exist or not. The industry considers that such a message would be highly detrimental to all stakeholders.\n•\tFurthermore, the proposed calculation of the impact for the ratios is misleading. The impact of transitionals on eligible own funds divided by the impact of transitionals on SCR or MCR will not show the effect the transitionals have on the solvency ratio. The wrong calculation specification should be corrected.","Public","GDV","Noted. The proposal has been removed from the disclosure template."]
["Reporting","S.23.01","Both","•\tChanges at solo level: \n•\tThe industry takes  note on the proposed change regarding foreseeable dividends, which should be reported in full in one time in the quarterly reporting, and no longer added incrementally from quarter to quarter. \n•\tThe industry welcomes the further clarifications made to the instructions. \n\nchanges at group level\n•\tThe industry  takes note of the changes proposed regarding ‘non-available own funds’ \n•\tThe industry takes note of the changes proposed regarding ‘minority interests at group level’ \n•\tThe industry is disappointed with the increase of the reporting requirements regarding total available own funds, for which many additional datapoints are added. ","Public","GDV","Noted. The additional information about non available Own funds is deemed essential for supervisory analysis and it should be avaialable to the groups."]
["Reporting","S.23.02","Both","•\tChanges at solo level: \n•\tThe industry welcomes the deletion of the information related to ‘excess of assets over liabilities, which was not announced in EIOPA’s report on quantitative reporting templates, published together with the EIOPA opinion on the 2020 review. \n•\tChanges at group level: \n•\tThe industry notes that for groups EIOPA did not suggest the deletion of the information related to ‘excess of assets over liabilities.  ","Public","GDV","Noted"]
["Reporting","S.23.03","Both","•\tThe industry welcomes the inclusion of a threshold for this template, both for solo and group template. ","Public","GDV","Noted"]
["Reporting","S.23.04","Both","•\tChanges at solo level: \n•\tThe industry welcomes the inclusion of a threshold for this template, both for solo and group template. \n•\tChanges at group level: \n•\tThe industry welcomes the inclusion of a threshold for this template, both for solo and group template. \n\n•\tWhile the industry  takes note of the changes proposed regarding ‘non-available own funds’, it opposes any additional increase in granularity for this template. ","Public","GDV","Increase of granularity in the group template is necessary to supervise the application of availability rules at group level."]
["Reporting","S.25.01","Both","•\tNote that this template is only applicable for SF undertakings/groups. \n•\tThe proposed changes when it comes to including diversification benefits are burdensome.\n\nR0060/C0030 (Net solvency capital requirement diversification) and R0060/C0040 (Gross solvency capital requirement diversification): In the additional insertion \"including diversification within each risk module\" it is unclear whether the \"including\" refers to \"Amount\" or to \"net risk modules\", i.e. should only the diversification within the BSCR or the sum of all diversifications (also those within the risk modules) be reported here.","Public","GDV","The clarification is there to explain that the diversification should include all applicable levels within each module and between each module component that forms the Basic SCR."]
["Reporting","S.25.05","Both","\n•\tEIOPA notes in para 2.411 of its report on quantitative reporting templates, published together with the EIOPA opinion on the 2020 review that “the template allows for great flexibility” and that “data reported is agreed between each undertaking and the group and the NCA”. For the sake of comparability undertakings will now have to report the burdensome new template S.25.05. \n•\tThe industry suggests that the current templates are maintained.","Public","GDV","Paragraph 2.411 of the report on quantitative reporting templates refers to the exisitng templates S.25.02 and S.25.03 which will be discontinued."]
["LAC DT ","Other","Solo","Annex to cover note (LAC DT)\nWe oppose the introduction of the new set of deferred tax templates as the current information reported in S.25 is sufficient. \nThe new detailed information on the LAC DT is introducing new provisions and new requirements not defined in the Solvency framework. The set of templates require firms to follow a certain methodological approach for the calculation of the loss absorbing capacity of deferred taxes, however there are some heterogeneities of approaches. By requiring companies to provide such detail, EIOPA is forcing insurance companies to choose that approach.\nAs part of the supervisory review process, NCAs could request further information from firms with large LAC DT amounts but on an ad-hoc basis and not by dissecting the figure in the regular reporting as EIOPA is currently proposing.\nIf EIOPA decides to go ahead with these templates, they should be significantly streamlined and a threshold should also apply to S.XX.01.\n","Public","Amice","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.26.08","Both","The industry deems it inappropriate to introduce a new internal model specific template when entity specific templates already exist (S.25.03). These templates were specifically designed to fit to the structure of the undertaking’s internal model and to fulfil NSAs’ requirements. This cannot be achieved by a standardized temple as it is never going to fit to every internal model.\nImplementation will have significant cost implication without adding any value to the reporting. As the template cannot fit exactly to the structure of an entity’s internal model, there will always be fields reported empty or an approximated way. This will only serve as a source of misinterpretation of the result / structure of an entity’s internal model. Moreover already existing entity specific templates describe the entity’s risk profile much better.\n","Public","GDV","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting","S.26.09","Both","GDV opposes to introduce this new template. There is no need for the requirement of results for various VaR for supervisory purposes. ","Public","GDV","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting","S.26.13","Both","GDV opposes to introduce this new template. Distribution data is not required for regular supervisory reporting. ","Public","GDV","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting","S.26.14","Both","GDV opposes to introduce this new template. Distribution data is not required for regular supervisory reporting. ","Public","GDV","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting","S.26.15","Both","GDV opposes to introduce this new template. Distribution data is not required for regular supervisory reporting. ","Public","GDV","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting","S.29.01",null,"EIOPA originally wanted to replace the four S.29 QRTs with two others. Now EIOPA has changed its mind and wants to keep the four QRTs (on-demand), modify one of them and include an additional one. Therefor EIOPA’s proposal on the QRT on variation analysis s.29 is unreasonable.\nThe QRTs S.29.0X cause already significant effort in analysis and creation. The additional effort for the implementation of the proposed new QRT will even be more burdensome. There is no benefit for the industry or supervisor given in this analysis and the cost-benefit is therefore conceivably unfavourable. Even EIOPA sees it as very labour and cost intensive and without the insights supervisors need.\nThe industry proposes either to not change anything at all or to eliminate operating figures or QRTs. Undertakings use for validation purposes different numbers and figures. This holds particularly for undertakings using an internal model. The mandatory breakdown according to materiality thresholds takes additionally the choice from the industry to enter the available numbers suitable to their business. Thus, it would be more beneficial to leave the form of the variation analysis individually to the undertakings.\nAs shown in the past the industry wants to support the development to achieve useful QRTs.","Public","GDV","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.03",null,"The QRTs S.29.0X cause considerable effort in analysis and creation. Changes there generate considerable additional work. The recommendation of the industry is the omission of key figures or QRTs. The mandatory breakdown according to materiality thresholds deprives companies of the option of entering the business in a way that is easier/more suitable from the existing figures.","Public","GDV","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05",null,"The text in the headings in the consultation paper and the Excel template do not seem to match. For example, for S.29.05 the column C0060 is named “Gross of reinsurance-Non-Life annuities” in the paper and “Gross of reinsurance-Claim provision” in the template.\nTherefore, it is not clear how non-life undertakings should handle their non-life annuities. It is added to S.29.05 but the instructions are vaguely.\nThe table S.29.05.01.06 does not add up. The sum of R0250 to R0310 is not the value of R0320 because there are actual payments included that are not part of the best estimate. Therefor there will be differences to the non-life best estimate.\nWill undertakings with dominant life insurance business be rid of the obligation to fill QRT S.29.05?","Public","GDV","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.31.01",null,"•\tThe proposal to introduce a currency field could be onerous. Firms find this form difficult enough already: the ability to analyse the reinsurance recoveries by counterparty is usually limited, so an element of approximation and pro-rata allocation is often employed; introducing further analysis by currency will simply lead to more of the same. This goes significantly beyond the existing requirement set out in S.02.02.","Public","GDV","The undertaking should be able to do the analysis by currency as this information is necessary for SCR calculation among others. The need to report the counterparty on best effort basis already exists and does not justify dropping the breakdown by currency. "]
["Reporting","S.32.01",null,"The template is already detailed and includes information with no additional benefit. In the proposed template even additional information are requested.\nThe industry cannot understand the added value of the column \"Direct participating undertaking ID\" as in our view the clarity of the QRT S.32.01 as a kind of overview of the undertakings of the group is lost.\nIn our view the cost benefit ratio of this additional information is not appropriate.\nIs the name of the direct participating undertaking to be included as well?\nThe industry also takes a critical view of the disclosure of shareholdings for the purpose of capital investment. These companies usually invest in complex investment networks on several levels in order to be able to take into account tax and regulatory requirements of investors of different nationalities. However, these companies are usually not influenced by the parent company either through the management bodies or in any other way. Depending on the look-through, these investments are mapped as equity risk or risk of the corresponding underlying and treated in various other QRTs. Therefore we would suggest removing these companies from the reporting of S.32.01.","Public","GDV","Please note that column \"Direct participating undertaking ID\" is removed.\n"]
["Reporting","S.33.01",null,"In the past, the QRT was only to be filled with information on companies included in group reporting using the D&A method. In the future, the QRT would have to be filled in for all included (re)insurance comanies, regardless of the calculation method. However, at the time of group reporting, the requested data, at least for the EEA companies, should already be available to the supervisory authorities at solo reporting level.","Public","GDV","Noted"]
["Reporting","S.36.00","Group","The industry  welcomes the alignment of the intragroup transaction templates (S.36) and the risk concentration templates (S.37) with the FICOD templates \n\nIn regard to the IGT, the ITS S.36.00 require the reporting of all intra-group transactions distinguishing between significant, very significant and transactions required to be reported in all circumstances. We recomment only to differenciate between significant and not significant intra-group transactions so that it is clear what information has to be reported.\n\nThe cover note also states that „groups will be requested to present the significant (and very significant) risk concentration“. According to our comment concerning IGT, we recomment only to differentiate between significant and not significant risk concentration so that it is clear what information has to be reported.\n\nThere can be found some formal errors in the note that should be corrected in regard to the column\n„item“ and the colum describing the relevant row and column. In the template S.36.00 the number identifying the relevant colums of the template is not correct in some cases, p. e. R0030/C00510 instead of R0030/C0050. In the second column stating its content the description assigning the value to the correct sector is missing, p. e. debt instruments instead of debt instrument from the banking sector to the insurance sector.\n\nHow should the two thresholds for \"significant\" and \"very significant\" IGTs as agreed with the supervisor be handled? Any significant transaction within a group must be reported. Why do we then need the very significant threshold? Will there be any further simplification, meaning that for example transactions between small non-insurance entities within a group needn't be reported?\nIdentical transactions are now being reported in more than one S.36. QRT. This leads to an increased effort to adjust internal processes.\nIs the differentiation in the QRTs S.36.0X between 'indirect transactions' and 'single economic operations' is a closed list? Do you have to decide between these two options?\n\nThe timetable should take into account that the software producers have sufficient lead time to be able to support the first report with the new templates.","Public","GDV","Please note that this template has been removed from the final package.\n\n\nAbout the distinction between significant and not significant intra group transaction, EIOPA confirms that all significant, very significant IGTs and the ones to be reported in all circumstances are to be reported on annual basis, althought the very significant IGTs and IGTs to be reported in all circumstances will  be still reported on ad hoc basis, as soon as practicable.\n"]
["Reporting","S.36.01","Both","In the general comments (e.g., S.36.01) the wording changes from 'This section relates to annual submission of information for groups' to 'template relates to information groups shall provide at least annually'. Does that mean EIOPA has plans to request this information in the quarterly reporting? Because of the tight schedule in the quarterly reporting that would cause a huge effort. \nIs the delivery of a Single-Economic-Operation (SEO) expected analogous to FICOD reporting? Is a daily monitoring obligation of the exposures as in FICOD reporting also envisaged here?","Public","GDV","EIOPA confirms that all significant, very significant IGTs and the ones to be reported in all circumstances are to be reported on annual basis, althought the very significant IGTs and IGTs to be reported in all circumstances will  be still reported on ad hoc basis, as soon as practicable."]
["Reporting","S.36.03","Both","Can EIOPA provide a closed list for financial sector of provider (C0040)? What in detail is supposed to be included at indirect transactions (C0080)? Is there a difference between transaction and operation (C0090)? What is supposed to be included in Single economic operation (C0090) and revenues stemming from the off BS item (C0190)?","Public","GDV","Agreed and a closed list has been implemented. \nEIOPA confirms that where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation."]
["Reporting","S.36.04","Both","The scope of the QRT is significantly expanded. In addition to information on group-internal reinsurance, information on all group-internal insurances is requested. This leads to additional costly data collection within the group. It is welcomed that in the future only significant transactions must be reported.\nIn the QRT S.36.04 (new) now 'all […] intra-group transactions between entities in the scope of the group supervision related to internal insurance […]' have to be reported instead of the 'internal reinsurance intra-group transactions' that have to be reported in the 'old' S.36.03 until now. That means an increased effort to implement.\nWhat in detail is supposed to be included at indirect transactions (C0080)? Are there examples available? What are \"Single economic operations\" (C0090)? Are there a detailed explanation and some examples?\nS.36.04.01 applies for insurance and reinsurance companies. At some points there are only explanations for the reinsurance part. Are explanations for insurance companies available as well?\nThe instruction for “net Receivables” (C0160) is interpretable in different ways. Are there more detailed information available?","Public","GDV"," \nEIOPA confirms that the S.36.04 will include information on intragroup insurance.\nFor the purpose of reporting the two fields of  indirect transactions and single economic operations are to be filled in as mutually exclusive.\nAbout the definitions, indirect transactions are normally identified as a chain of transactions shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or with entities outside of the group but ultimately risk exposure is brought back or stays within the group and impacts the solvency position of any insurance undertaking of the group.(description in the log to be amended if definition confirmed). While, where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation. "]
["Reporting","S.36.05","Both","In this QRT information on significant transactions that affecting net income are to be reported. The collection of the required data leads to a significant additional effort. \nA lot of IGTs will be reported already in S.36.01 - S.36.04. As it is already stated in the LOG file of S.36.05 (\"Although interest, dividends and premiums are reported in S.36.01, S.36.02 and S36.04 they must be reported additionally in S.36.05 P&L), why do we need a double reporting of these transactions?","Public","GDV","EIOPA confirms that although interest, dividends are reported in S.36.01, S.36.02 they must be reported additionally in S.36.05 P&L. The double reporting is expected to be of limited burden. While information on premiums is to be reported in S.36.04 only."]
["Reporting","S.37.01","Group","The industry  welcomes the alignment of the intragroup transaction templates (S.36) and the risk concentration templates (S.37) with the FICOD templates \n\nThe cover note also states that „groups will be requested to present the significant (and very significant)\nrisk concentration“. According to  IGT, the industry recomment only to differenciate\nbetween significant and not significant risk concentration so that it is clear what information has to be\nreported.\n\nAs mentioned by EIOPA all three considered options for the information on credit or insurance risk mitigation techniques have pros and cons. \nOption 3 could be a possible solution but the description of the reinsurance treaty may not be sufficient enough to display the effect of the reinsurance treaty among the counterparties. On the one hand, the description itself provides information of the treaty. On the other hand, it leaves room for interpretation and does not provide further details of how it is calculated. As a result, the description of the treaty cannot display its effect accross branches and countries in a consistent manner. A qualitative descriptions about reinsurance-exposures should be part of the narrative reports like RSR or ORSA and should not be asked again in the QRT.\nAn alternative could be option 1 with some changes. For example, instead of „proportional break-down“ the wording could be changed to „proportional or otherwise justifiable break-down“.\nIn principle, it seems reasonable to consider the credit risk to reinsurers in context with risk concentration. The probability of occurrence of an insurance event, which would be the basis for the exposure, should be taken into account. This would also make the exposure definition consistent with, for example, the measurement of credit risks in the investment area (market value). \nOption 2 demands de facto a partial internal model for every undertaking. That seems excessive.\n\nAbove all, the main objective in gerneral should be the alignment of the requirements under Solvency II and that ones at financial conglomerate level. The final draft concerning the reporting at financial conglomerate level reflects any deduction that come from the application of insurance or risk mitigation technique allowed according to the sectoral rules such as reinsurance, the use of derivatives or those detailed by chapter 4 of EU 575/2013. This document reffering to Solvency II distinguishes between insurance exposures itself of which a difference of gross and net exposures can be expected and insurance exposures of the group that are reinsured/risk mitigated via a non-porportional reinsurance treaty, encompassing more than one counterparty. As a consequence, EIOPA is already aware that it can be difficult to present the net value according to single counterparty. As a result, there can be found both more requirements at financial conglomerate level than that ones requested under Solvency II and a deviating perspective in terms of supervising reinsured exposures. Under the perspective of the requirements as a whole, the main objective of the Solvency II review and the final report in regard to the financial conglomerates reporting is to avoid differences between Solvency II and the financial conglomerate reporting and to implement a new harmonised set of regulations. \n\nIn S.37.01, C0110 until C0230, there are different kind of external exposures/instruments which have to be reported. It can be possible that a bond is listed in EUR, whether the reinsurance contract against the same external entity is in USD. Which currency must be reported in C0240 ?\n\nA \"full balance sheet approach\" is expected for all three templates. Does this requirement only refer to directly held exposures or are indirect exposures within funds to be looked through as far as possible?","Public","GDV","Noted. Based on the inputs received, the selected option for S.37.01 is option 1 with some changes: „proportional or otherwise justifiable break-down agreed with the group supervisor“"]
["Reporting","S.37.02","Group","For what reason EIOPA needs the QRT S.37.02? All information \"\"Exposure by currency\"\", \"\"Exposure by Sector\"\" and \"\"Exposure by country\"\" can simply be received by filtering in S.37.01 for the needed information which are already included there. It is very burdensome to implement new QRTs although the information is already available in other templates!\nWhat does „C0030/exposure net” means?\nShould a reduction through currency hedging be taken into account for the \"Exposure after insurance risk mitigation technique and exemptions (net amount)\"?\nWhen presenting by country, should the nominal country or the country at risk be shown?\n\nIf needed examples for the questions are available.","Public","GDV","S.37.02 will be including all exposures, not only the significant ones.\nCurrency hedging can be taken into account.\nThe country is supposed to be the nominal one. "]
["Reporting","S.37.03","Group","For what reason EIOPA needs the QRT S.37.03? The information about Equity can simply be received by filtering in S.37.01 for the needed information which are already included there. Furthermore we believe that most of the information regarding bonds seperated into ratings can be taken from Group QRT S.06.02. There are values per type of bond and rating available which can then be compared to total assets on Group Balance Sheet S.02.01. It is very burdensome to implement new QRTs although the information is already available in other templates!","Public","GDV","Information requested in the new template S.37.03 are not necessarily reported in other templates. For instance Equity reported in S.06.02  serve different purpose, the granular reporting is mainly based on fully consolidated data, while S.73.03 will be including also exposures from undertakings consolidated in accordance with Article 335, paragraph 1, (d), (e) and (f). "]
["Financial stability guidelines",null,null,"S.38.01.10 (modified and effective duration for life/non-life TP, depending on otiponality of contracts):\n\nReporting effectives durations is associated with considerable effort and should only be optional.\n\nIf, however, both modified and effective durations are to be reported:\n\nFor some products (e.g. annuities stemming from non-life insurance), „remaining contractual maturity“ and „effective duration“ need clarification.\n\nReporting a modified duration for all undertakings as proposed in option 1 (modified duration reported for all undertakings; effective duration to be reported only where material optionalities are present in the technical provisions) requires additional effort that is needed in order to calculate each duration on an indivudual basis as a standardised approach does not apply in this case. Option 2 (portfolio to be split based on presence of optionalities: Both modified and effective duration to be reported for all undertakings along with the associate best estimate for each measure) instead allows a standardised calculation of the durations so that this option should be preferred.\n\nWhy is index and unit linked business excluded when calculating the effective duration of life technical provisions? Unit linked business contains material options and guarantees and should from our point of view be part of the calculation.","Public","GDV","From the feedback received, Option 1 will be implemented. Therefore effective duration will only be required to be calculated in addition to the modified duration when material optionalities are present in the technical provisions. \nRegarding the unit-linked business, this proposal is an adaption of the current S.38 template which already excludes unit linked business - the additional burden of adding unit linked business to the template was not deemed worthwhile from a risk based perspective."]
["LAC DT ","Do you agree with the proposed threshold?","Solo","Cover note – Annex to cover note (LAC DT) \nSee our comments above.\n","Public","Amice","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["LAC DT ","Do you agree with the proposed threshold?","Solo","IRSG understands that these templates were until now only requested on an ad-hoc basis by certain national supervisors. Introducing extensive additional reporting burden for all undertakings in scope of Solvency II seems unreasonable. IRSG opposes the introduction of these new templates and considers current S.25 information to be sufficient for the purpose. Ad-hoc requests of individual supervisors should not increase the reporting obligations of the full market and be only executed on a case-by-case basis by the national supervisor if the situation necessitates it, in which case the conditions for reporting should be clearly defined.\n","Public","IRSG","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Financial stability guidelines",null,null,"•\tThe industry takes note of the deletion of some of the information in the Financial Stability reporting templates. While EIOPA highlights its proposed elimination of annual FSTs, a consequence of this is the requirement of additional information in a set of QRTs for financial stability. \n•\tProposed changes:\n•\tNew S.14 templates, focusing on liquidity risk.  \n•\tNew template S.02.01 - balance sheet, for groups \n•\tNew template S.38.01 – Duration of technical provisions. \n\nThe inclusion of any new detail in the QRT is not supported by the industry. In particular for thcS.02.01, S.23.02 and S.39.01 which require finalized figures on Group level. As the financial stability reporting deadline for groups is only 7 weeks (compared with quarterly at 11) it is not realistic to expect detailed figures already by the shorter deadline.\n\n•\tQuestion put forward by EIOPA– reporting on the effective duration figures:\n•\tOption 1 - Modified duration reported for all undertakings; Effective duration to be reported only where material optionalities are present in the technical provisions.\n•\tOption 2 - Portfolio to be split based on presence of optionalities: Both modified and effective duration to be reported for all undertakings along with the associate best estimate for each measure.\n•\tWhile the industry would prefer option 1, which is the least burdensome, it highlights that reporting effective duration on top of the modified duration will cause major coordination and methodology changes beginning with data collection from brokers, through all reporting systems and methodology policies across the full group scope without any added value. ","Public","GDV","EIOPA acknowledges that the financial stability figures, considering the shorten reporting deadlines (7 weeks), are reported on a best effort basis, and could marginally differ from the figures reported in the prudential reporting.\n\nFrom the feedback received, Option 1 will be implemented. Therefore effective duration will only be required to be calculated in addition to the modified duration when material optionalities are present in the technical provisions. "]
["Financial stability guidelines",null,"Group","The entry point afg (Annual Financial Stability reporting Group) is missing in the annotated templates. Will this entry point be omitted in the future?","Public","GDV","Yes, the annual entry points have been removed from the Financial Stability reporting package."]
["Financial stability guidelines",null,"Group","S.38.01\nReporting of the effective duration in the changed QRT S.38.01.10 causes a huge effort including elaborate stochastic projections with no adequate benefit. Furthermore, the definition of optionalities is not entirely clear.\nOption 1 is the preferred solution by the industry.","Public","GDV","From the feedback received, Option 1 will be implemented. Therefore effective duration will only be required to be calculated in addition to the modified duration when material optionalities are present in the technical provisions. "]
["Financial stability guidelines",null,"Group","S.39.01.11: The name for code C0010/R0050 \"Taxes Paid\" is very misleading. According to the LOG text, these are not taxes paid, but the sum of tax expense and extraordinary result.","Public","GDV","Agreed. The for code C0010/R0050 has been amended as \"Taxes expenses\". Guidelines and annotated templates have been adjusted accordingly."]
["Financial stability guidelines",null,"Group","S.02.01.01: As part of the financial stability reporting, information on statutory accounts is required on a quarterly basis. This leads to a significant additional effort in quarterly reporting and requires the conversion of existing processes, as the preparation of statutory accounts was previously performed at a later stage as part of the annual reporting.","Public","GDV","The statutory accounts in template S.02.01 (Balance sheet) should be reported with an annually frequency and not quarterly. As stated in the errata of the Guidelines on reporting for Financial Stability Purposes, the template S.02.02.01 has been ameded by template S.02.01.01, with the inclusion of the statutory accounts in an anually frequency, correspondly to the prudential reporting."]
["Financial stability guidelines",null,"Group","S.14.04: Here, additional information per product is recorded, some of which is not available in this granularity (costs, best estimate). The preparation causes considerable effort and in the end is not as meaningful as expected for some key figures - since they are only broken down.","Public","GDV","EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information in order to reduce the burden for undertakings: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category)."]
["Financial stability guidelines",null,"Both","S.14.04 Liquidity risk for life business (new, Quarterly FS Reporting): Quarterly reporting (at product level!) is to be classified as very critical. Effort and potential benefit are out of proportion. Aggregated values at total portfolio level appear perfectly adequate for the intended supervisory purpose and could be provided with moderate effort.\n\nInformation on cash flows at the product level could only be obtained (approximately) with a great deal of effort, especially for reporting during the year. For some key figures (administrative expenses, best estimate, net reinsurance flows), lump-sum coding would have to be applied, which would run counter to the expected granular information content.","Public","GDV","EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information in order to reduce the burden for undertakings: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category).Thus, most of these figures should be available in the capital reporting and should not require an excessive additional burden."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?",null,"With the ongoing revision of the CSRD more insurers will have to report on Sustainability KPIs. Therefore, we are of the opinion that an extension of the duty to all Solvency II companies is not expedient, even if thresholds are applicable (please refer to our detailed comment on S.06.04 on this Excel sheet).\n\nThere should be no reporting requirements if the entity is part of a group that itself or a mother entity already reports the S.06.04.","Public","GDV","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\n"]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ",null,"With the ongoing revision of the CSRD more insurers will have to report on Sustainability KPIs. Therefore, we are of the opinion that an extension of the duty to all Solvency II companies is not expedient, even if thresholds are applicable (please refer to our detailed comment on S.06.04 on this Excel sheet).\n\nThere should be no reporting requirements if the entity is part of a group that itself or a mother entity already reports the S.06.04.","Public","GDV","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\n\nEIOPA confirms that this information is to be reported both at group and solo level."]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?",null,"With the ongoing revision of the CSRD more insurers will have to report on Sustainability KPIs. Therefore, we are of the opinion that an extension of the duty to all Solvency II companies is not expedient, even if thresholds are applicable (please refer to our detailed comment on S.06.04 on this Excel sheet).\n\nThere should be no reporting requirements if the entity is part of a group that itself or a mother entity already reports the S.06.04.","Public","GDV","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\n\nEIOPA confirms that this information is to be reported both at group and solo level."]
["LAC DT ","Do you agree with the proposed threshold?","Both","Deffered taxes templates : The 10% threshold of the SCR triggering the filling of detailed information might be low in a volatility  context of Solvency II balance sheets. Several measures can be taken in order to address this issue :\n- Increasing the threshold, for instance to 20%\n- Considering an average over serveral years (for example if the average over 3 or 5 years is higher than 10%)\n- A combination of those two suggestions (for example if the average over 3 years is higher than 10% OR if the year N value is higher than 20%) [this is the measure seeming like the most relevant to us]","Public","FNMF","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments."]
["Reporting","S.17.02","Solo","We generally welcome the amendmends, leading to the inclusion of reinsurance business in S.17.02. Nevertheless, since S.17.02.01.02 is covering direct business and proportional reinsurance in total no clear distinction between direct business and reinsurance can be made. In order to overcome this: Could S.17.02.01.02 be limited to direct business only and an additional sub-template (in the structure of S.17.02.01.02/03) be added to capture only proportional reinsurance (i.e. splitting direct business / proportional reinsurance / non-proportional reinsurance in 3 sub-templates)? Another possiblity is re-adding the Z-axis \"Business Type\" which was deleted in the LOG-file for S.17.02.01.02.  If proportional reinsurance can be singled out, template E.03.01 could be deleted.","Public","ECB","Agree. Z-xis \"Business Type\" was re-added."]
["Reporting",null,null,"In relation to the following proposed amendment to the Solvency II Directive:\n(47) in Article 112, paragraph 7 is replaced by the following:\n‘7. After having received approval from supervisory authorities to use an internal model, and each time they report the result of a calculation of the Solvency Capital Requirement pursuant to Article 102(1), insurance and reinsurance undertakings shall provide the supervisory authorities with an estimate of the Solvency Capital Requirement determined in accordance with the standard formula, as set out in Subsection 2.’","Public","GDV","Please note that the comment relates to amendments of the SII Directive while the current package is not proposing any chnages to the reporting related to Article 112."]
["Financial stability guidelines",null,"Group","S.02.01.01 - there is a proposal to present the statutory balance sheet in the financial stability reporting.  As the financial stability reporting deadline for groups is only 7 weeks after end of the quarter, there is a risk that statutory figures will be far from the final data (especially when the 4Q/year end data is to be considered - there can be no complete data at all within 7 weeks after the year end). Nevertheless, even more dubious is that for quoted companies  the data should not be sent outside, before their publication. Reportiong to EIOPA via national supervisor means  that these data will be processed at a number of points. Additionally, if an insurer consolidates publicly quoted banks (we are a such  financial conglomerate in Poland, that is a real life case) the legal considerations become even more complex in that respect. \nS.23.02 in relation to the part Excess of assets over liabilities - attribution of valuation differences - because of the above we do not like to report these form under financial stability in a very short deadline.","Public","PZU","Noted. The figures are not published. Furthermore, EIOPA acknowledges that the financial stability figures, considering the shorten reportinf deadlines (7 weeks), are reported on a best effort basis, and could marginally differ from the figures reported in the prudential reporting.\nFurther, the deadlines for accounting might differ among countries, as there is no harmonised framework."]
["Financial stability guidelines",null,"Group","S.14 - introducing new templates for life and non-life reporting when no S.14 standalone reporting is required on quarterly basis will impose additional significant burden. In case when the group is to report these forms under financial stability then individual entities will have to prepare these forms within a very short deadline of 7 weeks after the end of each quarter. Similar forms (but not the same) are reported by individual entities only annually within the deadline of 20 weeks after the end of the year.","Public","PZU","Noted. In order to reduce the burden for insurance undertakings, EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). Thus, most of these figures should be available in the capital reporting and should not require an excessive additional burden.\n\nAt the same time, EIOPA acknowledges that the financial stability figures, considering the shorten reporting deadlines (7 weeks), are reported on a best effort basis, and could marginally differ from the figures reported in the prudential reporting.\n"]
["Financial stability guidelines",null,"Group","All changes in financial stability forms and reporting forms quarterly instead of annually will impose an additional burden instead of simplifying the reports, therefore we recommend further careful consideration in that respect.","Public","PZU","Please be aware that not all templates are quarterly frequency; i.e. both S.14, S.38 & S.39 are semi-annual. Other templates have also been completely removed i.e. S.40."]
["Reporting","S.32.01","Group","C0081 - Direct participating undertaking ID - it is a new cell for the undertaking which holds a participation in the related undertaking. What should be introduced when two or more undertakings hold one participation? Should be they all listed in one cell C0081 with one total of their holdings in % capital share in the column C0180? This comment pertains also to S.32.01.22 for disclousure.","Public","PZU","Column C0081 on Direct Participating Undertaking is removed"]
["Reporting","S.34.01","Group","C0085 Contribution of solo (notional) SCR to group SCR - in the guidelines the formula has been introduced to calculate this contribution in the same way as in S.33 for the insurance and reinsurance undertakings for which capital requirement is calculated on the basis of consolidated data while the contribution to the group SCR of the related undertakings from other financial sectors shall be calculated as the sum of the proportional share of the capital requirement or notional capital requirement of each related undertaking.","Public","PZU","The new column is to be filled only for IHC and MFHC.The purpose of this column is to collect the information on the contribution from IHC and MFHC to the group SCR similarly as for the insurance undertakings, consistently with the formula included in EIOPA GLs on group solvency calculation. "]
["Reporting","S.05.02","Group","As this template is still requested annually for groups, individual entities belonging to a group also need to fill this form even if  it is no longer required for standlaone reporting purpose. An uniform approach woild be recommended.","Public","PZU","S.05.02 is kept at group level, acknowledging thta it will be mainly based on consolidated accounts."]
["Reporting","S.36.00","Group","The alignment of all S.36 templates with the FICOD templates is a good idea but there are still some technical differences - for example different sequence of columns which should - in our opinion - be uniform, otherwise it causes additional unneccessary work.\nThe definition of indirect transactions and single economic operation and further instructions for these cells (description of specific examples) is to be addedd. ","Public","PZU","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insuance groups. Reporting requirements which are peculiarities of the financial conglomerate have been removed, e.g. the S.36.00 is simplified for insurance groups.       "]
["Reporting","S.06.02","Both","C0141-Write-offs/write-downs - loans and corporate bonds under SII are valued at fair value, what kind of write-offs does this cell refer to (there no writeoffs if FV is used)? Does the cell refer to write-offs as defined in IFRS 9 (if yes - in such a case are only ECL (expected credit losses) or also write-offs for impaired assets in basket 3 to be presented)?","Public","PZU","It should be independent from the accounting framework. It corresponds to the part of the notional amount that is \"lost\" due to the impairment of the loan or non-negotiable debt securities\nPlease note that following the comments received EIOPA decided to not introduce this change. As a result this proposal is not included in the final ITS package"]
["Reporting","S.13.01","Solo","C0045/R0010-R0330 Future cash–flows used in the Best estimate, Insurance with profit participation (gross), Cash in–flows — Total recoverable from reinsurance (after the adjustment)\n\n\tThe cash–flows are the ones stemming from future \n\tdiscretionary benefits regarding line of business, as \n\tdefined in Annex I to Delegated Regulation (EU) \n\t2015/35, Insurance with profit participation (gross).\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES","Public","FSAssist","Agree. Replaced by \"The future cash–flows undiscounted from amounts recoverables from reinsurance and SPVs/Finite Re, including ceded intra group reinsurance, including future reinsurance premiums. Amount shall be reported net of adjustment for counterparty default risk.\""]
["Reporting","S.13.01","Solo","C0085/R0010-R0330 Future cash–flows used in the Best estimate, Index linked and unit–linked insurance gross), Cash in–flows — Total recoverable from reinsurance (after the adjustments)\n\n\tThe cash–flows are the ones stemming from Future \n\tguaranteed benefits regarding line of business, as \n\tdefined in Annex I to Delegated Regulation (EU) \n\t2015/35, Index linked and unit–linked insurance \n\t(gross).\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES","Public","FSAssist","Agree. Amended with \"The future cash–flows undiscounted from amounts recoverables from reinsurance and SPVs/Finite Re, including ceded intra group reinsurance, including future reinsurance premiums. Amount shall be reported net of adjustment for counterparty default risk.\""]
["Other",null,"Both","General comments on the timeline:\n\n- EIOPA's planning leads to many challenges. The timeline should be reviewed and aligned to the timing of the 2020 Review (Level 1 and 2 changes) and should not anticipate its outcomes. We would like to see the additional Solvency II reporting requirements coming into force together with the further requirements of the 2020 Review.\n\n- From an overarching perspective, EIOPA's proposals for Solvency II reporting should also be linked to further developments in other reporting requirements. There must be an alignment in terms of contents and timing, e.g. with regard to the EU Taxonomy (ESG) and IFRS 9/IFRS 17.\n\n- Furthermore, the timing for implementation is too short as there are too many new tabs and details that are requested that would need to be incorporated into the reporting and data source systems. For many firms, the people needed are those who are still working on IFRS 17 - the current timelines will create a conflict of resource planning and IT bottlenecks. 2023 is therefore not feasible. \n\n- Also with regards IFRS 17, from a technology perspective it will be challenging and costly to maintain two versions of reporting systems and to ensure the QRT amendments are introduced first, before the IFRS 17 reporting changes. As the IFRS 17 changes are already developed in the test system environment, SII QRT amendments should not become effective for reporting periods before 2024.","Public","European Insurance CFO Forum & CRO Forum","EIOPA would like to clarify that the current ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations where the timeline for implementation was clear.\nNo amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \n. \n"]
["Other",null,"Both","General comments on the process:\n\n- As industry we note that the timing and timelines associated with this consultation, in conjunction with the burdensome nature of the consultation, have made it impossible to go through the consultation at a level of detail that it warrants. In addition, multiple other concurrently running consultations and processes associated with Solvency II (e.g. ongoing Solvency II review and opinions from the European Commission) have further inhibited a detailed analysis of this consultation. As a result we believe it to be premature to draw solid conclusions from the input received on this consultation.\n\n- EIOPA should provide a comprehensive list of all changes introduced and a background explanation of the reason for the change, in particular for the ones that were not included in the Opinion issued in December 2020. The cover note does not provide a comprehensive view.\n\nFor example, for S.01.02 Annex II shows inclusion of new row C0010/R0260 Direct URL to download the SFCR. However, this relates to the taxonomy changes for Q4 2020; since no amendment to the ITS was published at the time, EIOPA is using this opportunity to capture any gaps/changes from the past. Without a background explanation it can be confusing to understand why this change is not highlighted in the annotated template (as it was introduced in Taxonomy 2.5.0).\n\nIn addition, there is no explanation for the changes to the ECB QRTs. It is not clear why there is a separate annex to the cover note published for the deferred taxes reporting, and why the templates were not integrated within the annotated template file – the S.02.01 is particularly confusing as the annotated template contains one version, and the annex to the cover note contains a different version.\n\n- The validation file should be included as part of the consultation package as it facilitates a comprehensive review, since the definitions in Annex II do not always provide the information on the relationship between different data elements.","Public","European Insurance CFO Forum & CRO Forum","EIOPA disagrees. The current ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations.\nAll ITS amendments are performed in track changes and the templates consulted included a colour coding allowing to see the new cells, the deleted ones etc. The cover note doesn't aim to provide a comprehensive view of all the changes proposed in the amendments but rather to focus on the new areas not part of the QRT report used as a basis of the ITS amendments.\nEIOPA disagrees with the comment that the SFCR URL is a new proposal not included in EIOPA's SII Review 2020. The proposal infact is included in the Report on QRTs available on EIOPA's website - https://www.eiopa.europa.eu/document-library/opinion/opinion-2020-review-of-solvency-ii_en\nECB add-ons follow a separate process and a now in EIOPA's remit. Regarding the LAC  DT templates please note that EIOPA decided to not include them in the current ITS amendments package."]
["Other",null,"Both","General comments on functional topics:\n\nWe disagree with EIOPA's assertion that there will be less reporting on balance. For our members, the burden of Solvency II reporting increases significantly despite already being very extensive and burdensome. In our opinion the deletion and simplifications EIOPA has planned so far is not enough.\n\nSome specific examples:\n- QRTs S.05.01 and S.05.02 have local GAAP figures which are not needed under Solvency II. The figures can be taken from other reports and/or we believe that information within these QRTs are not necessary (for example IFRS 17 figures in S.05). See more detailed comment below.\n- QRTs S.25 introduce templates requiring standardized and granular reporting for Internal Model (IM) companies. This will be both extremely burdensome, because of the highly specific nature of IMs, and unnecessary, since model changes are already properly reported to NSAs. We consider this to be an example of QRTs being introduced just to collect data, rather than for supervisory purposes.\n- QRTs S.36.00, S.36.05, S.37.02 and S.37.03 are new QRTs which consist of information already available in other QRTs. From our point of view, it makes no sense to implement these QRTs (although it maybe makes sense to align it with Financial Conglomerate reporting requirements).\n- While we are in favour of the deletion of the Annual Financial Stability (FS) reporting, the quarterly FS reporting is much more complex and costly (new S.38.01, local GAAP column in S.02.01, new S.14 QRTs, etc.).\n- New LAC DT QRTs were added / are part of the ITS consultation without any information to the insurance industry and without any consultation since summer 2019.\n- New QRT S.06.04 was added / is part of the ITS consultation without any information to the insurance industry and without any consultation since summer 2019. A lot of figures will have to be reported twice (for Solvency II and for ESG reporting).","Public","European Insurance CFO Forum & CRO Forum","EIOPA acknowledges the comments received. As this comment relates to a number of templates please consult the resolutions proposed on individual templates comments."]
["Reporting","S.01.01","Solo","There is inconsistency between the annotated template for the RFF variant, SR.01.01, and the ITS Annex II. In the template, there is still a row R0850. This should be now R0855 as per the changes indicated in Annex II.","Public","European Insurance CFO Forum & CRO Forum","Agree. Amended"]
["Reporting","S.01.02","Both","This section not only relates to annual submission, but also to quarterly submission. In cells C0010/R0255 and C0010/R0255, the “Direct URL to the webpage where the Solvency and Financial Condition Report is disclosed” and the “Direct URL to download the Solvency and Financial Condition Report” are required. The instructions of these cells indicate that it shall “Include the direct URL to the page where the Solvency and Financial Condition Report (SFCR) corresponding to the reporting reference date as filled in R0081 will be published.\" This instruction is mistaken as there is no R0081.\n\nIn addition, what should be indicated for quarterly templates, the URL of the N-1 annual SFCR or the foreseen URL of the future SFCR?","Public","European Insurance CFO Forum & CRO Forum","The templates have been revised and the information is required only on an annual base. C0010/R0081 Financial year end is the column to which the instructions refered. The instructions have been further clarified."]
["Reporting","S.05.01","Group","It is true that the concept of the premium continues to exist under IFRS 17 disclosure requirements. However, it is the premium received that will be reported. This will be done in the reconciliation tables of technical provisions within the cash flow block (IFRS 17.105a(i)). This is not exactly the same as premiums written, as is required here.\n\nSolvency II refers to Directive 91/674/EEC in Directive 2015/2450 for the QRT S.05.01. According to the current understanding of EIOPA, this must be implemented even after the introduction of IFRS 17. Under this assumption, the values are to be determined in the same way as previously (because premiums paid (IFRS 17 Disclosure Statement) does not correspond either to premiums written or premiums earned)). For this reason these values cannot be taken from IFRS 17 Disclosures (current version), so it is an additional information for Solvency II.\n\nThe question is whether the 91/674/EEC Directive is really still applicable at Group level following the introduction of IFRS 17 (in the QRT, if applicable). Conversely, this contradicts the requirement in 2015/2450/EEC that the figures come from the published financial statements (LOG File for S.05.01: \"Groups shall use the recognition and valuation basis as for the published financial statements, no new recognition or re–valuation is required...\").\n\nEIOPA should clarify what IFRS groups should do under Solvency II and whether the 91/674/EEC Directive will continue to apply after the introduction of IFRS 17. Another option would be to delete the S.05 QRTs for groups. The issue hasn’t been raised in the latest EIOPA consultation (BoS-21/002), although EIOPA had proposed in its previous consultation (BoS-19/465) to remove the first QRT S.05.01, but not QRT S.05.02.\n\nOther comments:\n- The rows “changes in other technical provisions” (old R0410-R0500) are deleted - should we would now report it in R1200?\n- Should R1300 contain “all technical expenses”, namely incurred expenses (R0550) plus the technical expenses of R1200, excluding the technical income reported in R1200? Or shall It also include technical income of R1200? If the former, BV214 (R1300 = R0550+R1200) will not work anymore.","Public","European Insurance CFO Forum & CRO Forum","EIOPA recognizes that IFRS17 will bring material changes in the recognition, valuation, presentation, disclosure of insurance contracts. However, the template S.05.01 will be kept as it is now even if IFRS insurers don´t report the written and earned premius in their accounting P&L. The main reason is to maintain consistent basis of reporting for all insurers (IFRS and local gaap users). Further reasons:\n1) Although linked to accounting, S.05.01 is not a P&L but simply requires some P&L related items to collect some volume measures to measure the performance trend and for market wide analysis;\n2) This approach is already in place today with regard to insurance contracts with no significant insurance risk, whose written premiums/claims paid are not accounted for in the IFRS P&L (according to IFRS 4) but are still to be reported in S.05.01;\n3) The mandatory disclosure of IFRS 17 on premiums/claims paid would allow undertakings to fill in S.05.01 following the current approach;\n4) Re(insurance) undertakings will have to keep track of written/earned premiums for MCR/SCR calculation.\n\nFor IFRS17 users: Written premius/claims paid will be reported in the notes to the financial statements. \n\nThe change in other technical provisions is not included in the item \"Balance - other technical expense/income\". The instruction of the item is amended accordingly.   \n\nTotal expenses should contain all technical expenses, incurred expenses (R0550) and the technical expenses from the item R1200, excluding the technical incme. The validation BV214 will be deactivated. "]
["Reporting","S.06.02","Both","- C0141 Write-offs/write-downs: A value should not have to be mandatory reported unless there really is an write off or write down with regard to an asset. Depreciation and amortization with a value of EUR 0.01 only seems to serve statistical requirements.\n\n- C0190: It makes sense to show the lengths and widths on the liabilities side in order to evaluate insurance risks, and to look at the location of a property in risk management in order to identify natural disasters. To what extent a risk assessment is to be evaluated by data in S.06.02 is not clear.\n\n- C0294: Why cannot such necessary information be requested via an extension of the CIC in connection with the issuer country? Are there no other technical possibilities for EIOPA to extract the information from S.06.02?\n\n- C0295: Is this field also to be applied to the fund envelope in S.06.02? Obtaining this information for funds is a major effort considering that it is currently already the case that some non-EU fund companies are struggling to provide the TPTs. In addition, the following still applies: Insurance companies are risk-averse investors, so it is questionable whether an investment in crypto-currency would be in accordance with the investment strategies and the asset liability management of insurance companies. The requirement to report investments in crypto-currency certainly makes sense in the banking world, but should not be applied to the insurance industry on a one-to-one basis. It is also questionable how high the volume of crypto-currencies in European insurance companies really is. As far as only a value \"None\" is reported in a new additional field, this does not lead to a higher protection of the insured persons.\n\n- C0296: If at all, this query should be made via an extension of the CIC. This could also provide a reconciliation and consistency to the balance sheet (as a measure of risk). In addition, the question arises whether it should also apply this field to the fund envelope in S.06.02. Obtaining this information for funds involves a lot of effort, considering that it is currently already the case that some non-EU fund companies are struggling to provide the TPTs. Information procurement is to be designed.\n\n- C0297: If this information is already available in the INDICATIVE TEMPLATES FOR INDICATORS ON THE RESIDENTIAL REAL ESTATE SECTOR (EUROPEAN SYSTEMIC RISK BOARD) why is there a new query in S.06.02. There is a risk of data inconsistency due to different interpretations in different reportings.\n\n- C0330: We expressly welcome the simplification of the data for this field.","Public","European Insurance CFO Forum & CRO Forum","1)\tC0141 (write-offs/write downs): Agreed on the relevance of the deprecation or amortization. It should be independent from the accounting framework. It corresponds to the part of the notional amount that is \"lost\" due to the impairment of the loan or non-negotiable debt securities Please note that following the comments received EIOPA decided to not introduce this change. As a result this proposal is not included in the final ITS package\n2)\tC0190 (item title): EIOPA explained the reason to add this requirement in paragraph 2.124 of the “Report on quantitative reporting templates”, following ESRB Recommendation of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real state data gaps(ESRB/2019/3).\n3)\tC0294 (Regional Governments and Local Authorities (RGLA)): Due to the structure of the CIC codes, it is not possible to have additional positions to capture this new data need. EIOPA has carefully considered the options – changing CIC structure or add an additional item – and conclude that the additional item would have a smaller impact overall.\n4)\tC0295: (crypto assets): Noted. EIOPA understands that this is a subject which is somehow new in the financial markets and expects that insurance undertakings report the information that is available at each moment.\n5)\tC0296/0297 (property type / property location): Please note that these items are only applicable to CIC Category 9. The data collected from insurance undertakings through these two items is to fulfil the requirement of ESRB and so there’s no additional source. \n6)\tC0330: Noted."]
["Reporting","S.06.04","Both","General comments\nWhile the wish to receive specific climate related reporting, in particular in relation to transition risk and physical risk is understood, it is also key that requirements already foreseen under the Taxonomy Regulation are taken into account. In addition, to fulfilling these proposals, consideration should be given to availability of data, and it should be ensured that the same information is not reported twice. For taxonomy-aligned investments: CSRD would be the preferred format, and it is considered that the entities in scope of CSRD and the timing would be appropriate for sustainability reporting. The scope of the DA on Article 8 Taxonomy under NFRD should not be extended to all Solvency II companies. Regarding timing, EIOPA should take into consideration other sustainability initiatives and it should not require the reporting of taxonomy-alignment indicators before 2024 as envisaged in the CSRD.\n\nRegarding indicators on physical and transition risks, the regular QRTs is not an appropriate way to collect that data. The reporting should aim at collecting standardised data, thus allowing meaningful aggregation. As the indicators on physical and transition risks would be based on the outcome of idiosyncratic scenario analysis, they cannot be appropriately aggregated. The European Commission’s legislative proposal on Solvency II will render long-term climate change scenario analysis mandatory in the ORSA. We believe that the ORSA is a more natural recipient of the outcome of own analysis than QRT.","Public","European Insurance CFO Forum & CRO Forum","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\nEIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs and builds on existing and ongoing work at EIOPA on transition and physical climate risk. The ORSA will support the reporting of the KPI for prudential purposes.\n"]
["Reporting","S.06.04","Both","Specific comments\n- R0010/C0010: This is a KPI that must be reported at the company level anyway and therefore for all assets from 2023. The reporting obligation here extends to all companies that have to submit a non-financial statement. The separate reporting of this KPI here would therefore be redundant.\n\n- R0020/C0010: The choice of methodology for determining the transitory risk is left to the company, so the question arises: if each company uses its own method and the results are therefore not comparable, why not limit point R0020 / C0010 to mere reporting of the NACE codes? These are uniform and therefore comparable.\n\n- R0030/C0010: Same comment as for R0020 / C0010 (due to lack of comparability due to free choice of method). In addition, it is not clear here what the \"property\" means. If the geographical coordinates of the company are to be reported for the determination of the physical risks of an investment in a company, this has no meaning at all about the physical risks of the company as a whole.\n\nIn addition, EIOPA should clarify the following:\n• Are the required KPIs (R0020 and 0030) only the portion of investments at risk exposure or the physical / transition risk impact of the investments?\n• Shall it be reported as a total or a sub-total per NACE code?\n• It is not clear whether/when impact on liabilities shall be considered: EIOPA mentioned that “Requirements on liabilities will be developed in due course - some limited information is proposed to be included in S.14.02 for non-life.”","Public","European Insurance CFO Forum & CRO Forum","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\n\nOn the transition and physical risk KPI, the reporting of the KPI will inform supervisors' risk assessesment before it allows comparison with other undertakings. Good practices are starting to emerge and will consolidate over time. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for the risk assessment. The consultation and pilot exercise on the guidance (March 2022) is an opportunity to test and further discuss good practices.\n\nAs to the specific questions we confirm that the KPI on thransition risk is to be calculated as proportion  of the Solvency II value of investments exposed to transition risk, in relation to total of investments. The KPI on physical risk is to be calculated as a proportion of of the Solvency II value of property exposed to physical risk, in relation to total of property. Please note that the instructions have been clarified. NACE is to be reported by assets and in the calculation of the KPI is to be considered as a total.\n\nEIOPA will consider at a later stage the options for reporting transition or physical risk on liabilities, building also on the implementation of the new reporting requirements proposed under S.14.02 for non-life and EIOPA's analysis in 2022 on physical risk."]
["Reporting","S.14.03","Solo","Specific comment\n- Column C0040 is defined by the portion of \"Cyber Coverage\" for the particular Product Category. What is, on your opinion, the best metric measure to calculate the portion (e.g. Gross Premiums, Insured sum, Best Estimate, Expected losses)?","Public","European Insurance CFO Forum & CRO Forum","Noted. Sum insured should be the criteria used. EIOPA will clarify this in the instructions\n"]
["Reporting","S.14.04","Group","Do we understand correctly that C0290 and C0300 is reported on a net basis (assumed minus retroceded) whereas C0180 is only on gross basis? What is the main conclusion of that inconsistant information? Also, some information of the LOG file and the Annotated Templates differ with regard to content.","Public","European Insurance CFO Forum & CRO Forum","C0290 is reported on a gross basis, similarly to the rest of the information in the template. By contrast, C0300 is to be reported on a net basis as the balance of cash flows (cash in minus cash out) allows to monitor the liquidty position of insurance undertakings, as well as to reduce the reporting burden for them. Templates and guidelines have been adjusted accordingly."]
["Reporting","S.14.05","Group","Do we understand correctly that C0290 and C0300 are reported on a net basis (assumed minus retroceded) whereas C0070 and C0180 are only on gross basis? What is the main conclusion of that inconsistant information? Also, some information of the LOG file and the Annotated Templates differ with regard to content.","Public","European Insurance CFO Forum & CRO Forum","C0290 is reported on a gross basis, similarly to the rest of the information in the template. By contrast, C0300 is to be reported on a net basis as the balance of cash flows (cash in minus cash out) allows to monitor the liquidty position of insurance undertakings, as well as to reduce the reporting burden for them. Templates and guidelines have been adjusted accordingly."]
["Reporting","S.14.05","Group","The Product Category (C0010) should be reported using a closed list. With the different \"risk types\", a clear definition of what should be included/excluded is necessary and this is to be concluded in agreement with the supervisory authority. According to the Annotated Template, the information is \"optional\" only. What code should be used then?","Public","European Insurance CFO Forum & CRO Forum","In order to reduce the burden for insurance undertakings, EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information: S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category)."]
["Reporting","S.23.01","Solo","In reference to the additional text relating to foreseeable dividends (R0720/C0060):\n- Why is this only amended in the solo QRT guidance on QRT s.23.01 and not in the group guidance?\n- Is it necessary to do this in the QRT guidance? Should it not be part of an article with definitions in the SII Delegated Acts, or perhaps by amending Guideline 2 in EIOPA's Guidelines on classification of own funds?","Public","European Insurance CFO Forum & CRO Forum","EIOPA considers the proposal is in line with the Q&A n the reporting of foreseable dividends."]
["Other",null,"Both","General comments\nWhen approving internal models, we run through a time-consuming and complex application phase. The reason for this is that an internal model is undertaking specific and there are a wide range of diverse ways of modelling and implementing the risk categories, correlations, model structure and so on.\n\nWhen implementing a pre-defined QRT for internal model figures it is assumed that one can compare different models from different insurance companies, but it is not in the case of Internal Model. Because of the complexity of the models, one needs to know what the basics of the model are, like the methods, the assumptions, and the used distributions. The probability of misinterpretation of the figures in such a granularity in this Internal Model QRT is quite high.\n\nInternal models based on Monte Carlo simulations always struggle to produce stable estimators for high quantiles. This holds even more true since internal models are optimized to produce the Solvency II SCR based on 99.5%. This could lead to significant deviations between different models or even the same model, but different model runs. Because these deviations can be misleading it should be avoided to report quantiles above 99.5% or below 0.5%.\n\nIn strict contrast to the standard formula, internal models are highly individual and customized to the specific business and risk structure of an insurance company. This leads to the fact that detailed drilldowns and interim results (like risk factors, correlations, and different quantiles of (sub-) risk categories) are hardly comparable. They are often misleading, because they do not cover other mathematical properties of the model (non-linear or functional dependencies, underlying assumptions, embedding of the internal model in a broader sense into the risk management system of the company etc.) as well as individual traits of the company's insurance and asset portfolio, its governance system and risk strategy.","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Other",null,"Both","General comments (cont.)\nThe 10 newly introduced templates requiring standardized reporting for Internal Model companies expect granular and mostly irrelevant information, which does not fit the specific structure of internal models, thereby requesting estimations that would in all likelihood lead to results that do not make sense.\n\nWe oppose results from standardized reporting on internal models to be used as a basis for comparison between companies or as a basis for assessing the evolution of internal model capitalisation over time. Some of the data requests would even dictate how to model certain risks which is against the freedom of modelling risks recognised in the Solvency II directive.\n\nIn addition, the level of granularity requested is often not available and EIOPA should make clear for every field that no data is to be expected if not readily available in the model. EIOPA should also better consider the case of reinsurance activities. Reinsurers manage portfolios consisting of heterogenous risks, with less granular data on every underlying product than the cedents, and requesting to single out sub-portfolios for the sake of the QRT reporting is disproportionate.  \n\nWe are also of the opinion that the QRT reporting package is not a suitable platform to report model changes. The national supervisors are already properly included in their reporting process on a quarterly basis and there is no additional need to double report them in an annual QRT set.\n\nEventually the additional data request is so extensive that it would require for internal model users to engage into a major  and costly IT system project unlikely to be completed for YE2022 reporting. As a result, the first year of application should be postponed and the implementation phased-in.   ","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups.\n\nRegarding the MCP template the intention is to have a common template on a European level with some basic information regarding model changes where supervisors can quickly check the impact of a specific change or a set of changes. The common template will also assist in colleges. EIOPA acknowledges that specific governance frameworks deviate from each other and that's the reason that it requests each undertaking to report major and minor changes according to its own model change policy (MCP). The template will be reported annually and the LOG file states that fields corresponding to minor changes should provide information based on the reporting period.\n\nEIOPA is proposing to postpone the first year of application by a year."]
["Other",null,"Both","Although not included in EIOPA's proposals, we note that the European Commission's draft level 1 changes require regular reporting of an estimate of the standard formula SCR for internal model users. The industry wishes to underline that regular reporting of standard formula QRTs for internal model users is very burdensome. Because the IM users will have to report new IM QRTs, such a requirement would be misleading from our point of view.","Public","European Insurance CFO Forum & CRO Forum","Please note that the comment relates to amendments of the SII Directive while the current package is not proposing any changes to the reporting related to Article 112."]
["Reporting","S.25.01","Both","What does the change in wording for R0060/C0030-C0040 (“amount of the diversification effects between Basic SCR risk modules, including diversification within each risk module…) mean?\n\nShould all diversification effects within submodules and across risk modules be shown here? Please pay attention to the nodes to other QRTs (e.g. S. 26.01), as the data for risk categories will then deviate.","Public","European Insurance CFO Forum & CRO Forum","The clarification is there to explain that the diversification should include all applicable levels within each module and between each module component that forms the Basic SCR."]
["Reporting","S.25.05","Both","Generally, the information required through the template can be provided but not fully. Internal models are undertaking specific and thus not all the risk components mentioned in the template can be mapped one to one on our internal model. With the different \"risk types\", a clear definition of what should be included/excluded is necessary and this is to be concluded in agreement with the supervisory authority. However, this may make it very undertaking-specific again and renders the entire QRT incomparable with respect to the information disclosed by other companies, thus making the entire exercise futile and against the intended purpose. template.\n\nSome clarification is required regarding the column C0060 “Consideration of the future management actions regarding technical provisions and / or deferred taxes”. Is it just an indication or an estimate of the amount? The latter would be problematic, as it is not available mathematically but also difficult to compare in terms of content.\n\nWe also fail to understand as to why is a USP queried in S.25.05.21 - isn't it more relevant to standard formula?","Public","European Insurance CFO Forum & CRO Forum","USPs do not exist in 2.6.0 for S.25.02.21 or S.25.03.21. Corrected"]
["Reporting","S.26.08","Both","This template is quite comprehensive as it requires the risk categories to be presented at the most granular level. Due to the intrinsic feature of every internal model that it is highly undertaking specific, not all the required risk categories are distinguishable as per the template requirements. Thus, any failure to fill the template arising from inability of the model to provide the required risk category segregation could be misunderstood that these risks are not modelled although they are contained in other risk categories and cannot be separated.\n\nFurther clarifications are needed, e.g. regarding the column C0060 “Consideration of the future management actions regarding technical provisions and / or deferred taxes”. Is it just an indication or an estimate of the amount? The latter would be problematic, as it is not available mathematically but also difficult to compare in terms of content. Some local supervisors request a similar template, but the new template would trigger a new round of discussion and clarifications and in the end the disclosed information would still be incomparable to other undertakings.","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups.\n\nC0060 has existed since the adoption of Solvency II in QRTs S.25.02 and S.25.03 for internal models. It is not a new column."]
["Reporting","S.26.09","Both","The reporting is far too detailed, even if some of it could be provided. We therefore do not support this template.\n\nIt seems that only static stresses (i.e., only for t=0) are requested, so that no additional model runs would be necessary to fill in the templates. However, holistic analysis of the template points to an unnecessary increase in the number of sensitivities/scenarios that undermines the intent of the internal model and does not reflect the undertaking specific risk situation.\n\nIn addition, due to model limitations and the effort involved, some firms find it difficult to:\n- fill in all the risk categories as level 2 components (therefore, the definition of diversification is not comparable between entities and groups); and\n- differentiate between with and without transitional disclosures and/or VA for individual risks.\n\nLastly, we would like to understand the logic behind categorizing the impact in terms of assets and liabilities and further subcategorization into with and without unit linked.","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups.\n\nRisks in unit linked products are usually borne by the policyholder so EIOPA/NCAs want to understand the extent to which unit linked products affect the sensitivities of the portfolio."]
["Reporting","S.26.10","Both","Reporting is far too detailed, even if some of it could be provided. Therefore, we do not support this template.","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups."]
["Reporting","S.26.11","Both","Some of our members will not be able to provide the information required (e.g. no separation possible for financial and non-financial instruments).","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.12","Both","Some of our members will not be able to provide the information required (e.g. no separation possible for financial and non-financial instruments).\n\nOthers will only be able to provide part of the required information, as the deviation between type 1 and 2 exposure is orientated by the standard formula but not applied in the internal model. Thus, row R0130 to R0190 cannot be filled. Also, the exposure weighted probability of default is not equivalent to those used in the internal model.","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.13","Both","The template is quite complex and would require substantial effort to fill the required cells although only partially e.g. the table covering measures net of reinsurance recoverables cannot be filled. However, we are pleased with the positive changes in the scope\ni. No more nominal data.\nii. No more durations.\niii. No more expenses.\niv. Less quantiles.\nv. No more loss ratios.","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.14","Both","The template is quite complex and would require substantial effort to fill the required cells although only partially.\n\nWe have the following observations:\n1) It is questionable if columns C0010 to C0060 (volume measures) can be divided into categories trend, level, volatility and catastrophe meaningfully.\n2) Splitting the SCR into trend, level, volatility and catastrophe requires enormous implementation effort.\n3) Equally valid for deviation of lapse risk into increase, decrease and mass lapse.\n4) Spitting Health risk (R0310 and following) into proposed subcategories requires enormous implementation effort.\n5) Unclear if medical expense (R0420) in Health QRT can be filled meaningfully.\n6) How should one particularly deal with risk aspects that are not modelled (materiality) or modelled together with others and cannot be separated?\n7) Why is the statement of the balance sheet sizes / insured sums, etc. only provided for selectively? Then what is the added value of it? How do you deal with premiums etc. that are exposed to multiple risks?","Public","European Insurance CFO Forum & CRO Forum","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\n7) Sum insured is provided where it can be reported. For premiums that are exposed to multiple risks the undertaking should try to split them in a meaningful way. If that's not possible then they should be reported in the field where they are more relevant in terms of size. The NCA will be aware of this."]
["Reporting","S.26.15","Both","We do not agree with the requirement to report according to Basel categorization and would strongly prefer to stick with internal classification. So far for insurers there is no regulatory requirement to report alongside Basel classification. Internal categorization is an essential part of the regulatory approved internal model. A reallocation of capital to Basel categories would require model changes and adjustments in internal steering which are not deemed to be valuable. Also, column Probability distribution is not straightforward to fill as up to three distributions per scenario are used (small, large, and mega loss)","Public","European Insurance CFO Forum & CRO Forum","Internal classification (scenarios) is required in C0020 even when the Basel II classification is used. There are two questions (C0010/R0010 and C0010/R0020) which ask if the undertaking is using Basel L1 and L2 classification. The mapping to the Basel II classification is required if the undertaking is using this classification (could be using only L1) or if it exists. It is not mandatory."]
["Reporting","S.26.16","Both","We do not understand the rationale behind the QRT for model changes. The internal model is highly customized to an insurance company and thus neither the model nor the associated changes can be compared with the other (re)insurers to derive any meaningful information.\n\nAny model change, major or minor, is governed through the model change policy and is first approved internally before it is submitted for supervisory approval. Every company has thresholds and procedures in its model change policy that have been agreed with the local supervisor taking into account the specificities of each internal model and risk profile; industry should not be forced to one reporting format but rather keep the required flexibility in this area. The proposed changes do not solve any issues but only create new operational ones. This can be better addressed in the communication between supervisors rather than yet adding another template to the QRTs Any new QRT would trigger further discussion with supervisors regarding the proposed deliverables and would mean additional effort without any justification.\n\nHowever, if EIOPA is determined to go ahead with the proposed QRT then at least the risk categories shown should correspond to the respective model change policy. If EIOPA prefers to have a fixed number of Columns this should correspond to those risk categories according to SII RL Art. 101, which are part of the capital requirement:\n(a) non-life underwriting risk;\n(b) life underwriting risk;\n(c) health underwriting risk;\n(d) market risk;\n(e) credit risk;\n(f) operational risk.\n\nError in template on major model changes:: SCR & EOF before and after model change are compared to one cell in another template which corresponds to the total SCR & EOF at year end.\n\nOn minor model changes, some members will not be able to provide:\n- the combined impact on the SCR (and on EOF) of all the minor model changes at Year End N, as they instead estimate the impact over the SCR at FY N-1 on a standalone basis.\n- separate reporting of model changes with positive and negative impacts on the SCR, where supervisors request absolute value impacts.","Public","European Insurance CFO Forum & CRO Forum","Regarding the MCP template the intention is to have a common template on a European level with some basic information regarding model changes where supervisors can quickly check the impact of a specific change or a set of changes. The common template will also assist in colleges. EIOPA acknowledges that specific governance frameworks deviate from each other and that's the reason that it requests each undertaking to report major and minor changes according to its own model change policy (MCP). The template will be reported annually and the LOG file states that fields corresponding to minor changes should provide information based on the reporting period.\n\nThe risk categories reflect the new QRT's structure. Article 101 of Solvency II lists the minimum number of risks that should be covered. Internal models can be more granular than this.\n\nError in template on major model changes. C0180 and C0200 compare the SCR and C0220 and C0230 compare the OF before and after the changes. Please send clarifications regarding this comment because it is not well understood.\n\nOn minor model changes, if the model supports the production of such data in a sensible manner, then it has to be reported. On the second point, if NCAs ask for the absolute amount then the expectation is that it should be possible to break it down to positive and negative changes.\n\n"]
["Reporting","S.29.01","Both","Data requested may not be available due to how different lines of business are managed differently impacting data that is kept (e.g. based on accident year vs underwriting year)","Public","European Insurance CFO Forum & CRO Forum","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.03","Solo","In the Annex, the label for C0100 – C0110/R0320 was amended to remove the text “net of salvage and subrogation”, while the annotated template for S.29.03.01 still has that language. This should also be removed in the annotated template to align to Annex II.","Public","European Insurance CFO Forum & CRO Forum","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Both","Some of the data may be be able to be provided (e.g. on expected claims paid during the period)","Public","European Insurance CFO Forum & CRO Forum","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.30.01","Solo","C0045 Description of operation of the facultative reinsurance item: please explain in detail what is supposed to be included here. What is the difference to C0080 Description risk?","Public","European Insurance CFO Forum & CRO Forum","This cell has been deleted."]
["Reporting","S.30.03","Solo","• C0420 Coverage of a layer covered by reinsurance: please explain in detail what is supposed to be included here.\n• C0430 Oder of claims within the reinsurance program please explain in detail what is supposed to be included here.\n• C0440, C0450, C0460 Minimum / maximum / expected commission: Which commission is to be included here? Overriding commission? Profit commission? Reinsurance commission?\n","Public","European Insurance CFO Forum & CRO Forum","C0420  It should include the maximum coverage per layer of a reinsurance treaty. The LOG has been improved.\nC0430 This cell has been deleted.\nC0440, C0450, C0460 Total commissions paid to the reinsurer."]
["Reporting","S.32.01","Group","C0081 Direct participation undertaking ID: Is the name of the direct participating undertaking to be included as well?","Public","European Insurance CFO Forum & CRO Forum","Column C0081 on Direct Participating Undertaking is removed"]
["Reporting","S.36.00","Group","How should the two thresholds for \"significant\" and \"very significant\" IGTs as agreed with the supervisor be handled? Example: The significant threshold is EUR 50m; whether the very significant threshold is EUR 100m.\n\n- We have a transaction between Group entity A and B of EUR 60m. The significant threshold is reached, but not the very significant one. Does that mean that all transactions over EUR 50m must be reported anyway? Why do we then need the very significant threshold?\n- Will there be any further simplification, meaning that for example transactions between small non-insurance entities within a group needn't be reported?","Public","European Insurance CFO Forum & CRO Forum","EIOPA confirms that the significant IGTs are supposed to be reported regularly, on annual basis and that the very significant IGTS and IGts to be reported in all circumstances will  be still reported on ad hoc basis, as soon as practicable."]
["Reporting","S.36.03","Group","• C0040 financial sector of provider: please provide a closed list\n• C0080 indirect transaction please explain in detail what is supposed to be included here. Is there a difference between transaction and operation (C0090)?\n• C0090 Single economic operation please explain in detail what is supposed to be included here.\n• C0190 revenues stemming from the off BS items: please explain in detail what is supposed to be included here.","Public","European Insurance CFO Forum & CRO Forum","On C0040 noted. Please consult the final package proposals. \nFor the purpose of reporting the two fields of  indirect transactions and single economic operations are to be filled in as mutually exclusive.\nAbout the definitions, indirect transactions are normally identified as a chain of transactions shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or with entities outside of the group but ultimately risk exposure is brought back or stays within the group and impacts the solvency position of any insurance undertaking of the group. While, where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation. \nAn off balance sheet item such as contingent liabilities is a potential obbligation that once it is executed become on balance sheet. Revenues can be in case of decrease from Year T-1 to Year T of contigent liabilities (e.g. from 100 to 80, you have a 'revenew' of 20) or in case of total derecognition (e.g. from 100 to 0)."]
["Reporting","S.36.04","Both"," - Please provide a track change version\n - Which items are to be reported additionally under the review?\n - What is the impact of \"significant, very significant, transactions to be reported in all circumstances\"? What does this mean\n - C0030 identification of the provider: Has the name changed only? Or are there changes in the content of this data field? \n - C0060 identification code and type of code of the issuer: Has the name changed only? Or are there changes in the content of this data field?\n - C0020 investor name: Has the name changed only? Or are there changes in the content of this data field?\n - C0050 issuer name: Has the name changed only? Or are there changes in the content of this data field?\n - C0070 financial sector of provider: please provide a closed list\n - C0100 effective date: to be deleted? Please confirm\n - C0140 value of transaction: to be deleted? Please confirm \n - C0160 maximum possible value of contingent liability not included in SII BS: to be deleted? Please confirm\n - C0170 maximum value of LoC guarantees: to be deleted? Please confirm","Public","European Insurance CFO Forum & CRO Forum","Noted. The final ITSs will be also provided in track changes.Information on Contingent liabilities is now requested in the new S.36.03 template. Please consult the final package with additional changes and clarifications. \n"]
["Reporting","S.36.05","Group","A lot of IGTs will be reported already in S.36.01 - S.36.04. As it is already stated in the LOG file of S.36.05 (\"Although interest, dividends and premiums are reported in S.36.01, S.36.02 and S36.04 they have to be reported additionally in S.36.05 P&L), why do we need a double reporting of these transactions?","Public","European Insurance CFO Forum & CRO Forum","EIOPA confirms that although interest, dividends are reported in S.36.01, S.36.02  they must be reported additionally in S.36.05 P&L. The double reporting is expected to be of limited burden. While information on premiums are to  be reported in S.36.04 only,"]
["Reporting","S.37.01","Group","In S.37.01, C0110 until C0230, there are different kind of external exposures/instruments which have to be reported. It can be possible that a bond is listed in EUR, whether the reinsurance contract against the same external entity is in USD. Our question is which currency must be reported in C0240 ?","Public","European Insurance CFO Forum & CRO Forum","It should be separate line if it is not possible to present in a single one"]
["Reporting","S.37.02","Group","Why does EIOPA need the QRT S.37.02? All information \"Exposure by currency\", \"Exposure by Sector\" and \"Exposure by country\" can simply be received by filtering in S.37.01 for the needed information which are already included there. It is very burdensome to implement new QRTs although the information is already available in other templates.","Public","European Insurance CFO Forum & CRO Forum","All information on \"Exposure by currency\", \"Exposure by Sector\" and \"Exposure by country\" can not be received by filtering in S.37.01 since S.37.02 will be including all exposures, not only the significant ones.\n"]
["Reporting","S.37.03","Group","Why does EIOPA need the QRT S.37.03? The information about Equity can simply be received by filtering in S.37.01 for the needed information which are already included there. Furthermore we believe that most of the information regarding bonds separated into ratings can be taken from Group QRT S.06.02. There are values per type of bond and rating available which can then be compared to total assets on Group Balance Sheet S.02.01. It is very burdensome to implement new QRTs although the information is already available in other templates.","Public","European Insurance CFO Forum & CRO Forum","Information requested in the new template S.37.03 is not necessarily reported in other templates. For instance Equity reported in S.06.02  serve different purpose, the granular reporting is mainly based on fully consolidated data, while S.73.03 will be including also exposures from undertakings consolidated in accordance with Article 335, paragraph 1, (d), (e) and (f). "]
["Financial stability guidelines",null,"Group","There are differing views on this topic exist across our membership. Each company's position will depend on its specific business model.","Public","European Insurance CFO Forum & CRO Forum","Noted"]
["Sustainable finance questions",null,"Both","General comments:\n\nWe fully acknowledge the need for climate-related reporting, in particular in relation to transition risks and physical risks, and strongly welcome EIOPA’s efforts to implement prudentially relevant and proportionate reporting requirements following the ongoing regulatory developments.\n\nWhile we do not generally oppose additional requirements for QRT reporting, including on sustainability matters, we suggest to limit, as much as possible the extensions that do not come along with a sufficient incremental information value and / or are not deemed necessary for Solvency II (SII) purposes to keep the reporting overload within a reasonable range.\n\nAs the sustainability reporting landscape evolves rapidly, including with view to respective regulatory requirements, it is absolutely essential that all EU sustainability reporting requirements are aligned and consistent across all relevant legislations with respect to all relevant dimensions, including content, scope and timing:","Public","European Insurance CFO Forum & CRO Forum","Noted."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?","Both","Only undertakings in scope of the NFRD / CSRD should be required to report the KPI and this should be in the Non-Financial Statement (NFS), not in the QRT (or only via cross-referencing). In case this will form part of QRT reporting, it should only be the case at Group-level for companies in scope of the NFRD / CSRD. For companies not subject to the NFRD / CSRD, there should be no new requirement for reporting this information. Otherwise, this should only be the case subject to a materiality assessment.","Public","European Insurance CFO Forum & CRO Forum","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ","Both","In case this will form part of QRT reporting, it should only be the case at Group-level for companies in scope of the NFRD / CSRD and if material – where such information is provided at Group-level via other formats (e.g., management report), cross-referencing should be sufficient. For companies not subject to the NFRD / CSRD, there should be no new requirement for reporting this information.","Public","European Insurance CFO Forum & CRO Forum","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?","Both","In case this will form part of QRT reporting, it should only be the case at Group-level for companies in scope of the NFRD / CSRD and if material – where such information is provided at Group-level via other formats (e.g., management report), cross-referencing should be sufficient. For companies not subject to the NFRD / CSRD, there should be no new requirement for reporting this information. ","Public","European Insurance CFO Forum & CRO Forum","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Group reporting questions",null,"Group","Question to Stakeholders: S.37.01 (C0260) Information on Credit or insurance risk mitigation techniques\n\nThere are differing views on this topic exist across our membership. Each company's position will depend on its specific business model.","Public","European Insurance CFO Forum & CRO Forum","Noted. Based on the inputs received, the selected option for S.37.01 is option 1 with some changes: „proportional or otherwise justifiable break-down agreed with the group supervisor“"]
["Reporting","S.13.01","Solo","C0125/R0010–R0330 Future cash–flows used in the Best estimate, Other life insurance (gross), Cash in–flows — Total recoverable from reinsurance (after adjustment)\n\n\tThe cash–flows are the ones stemming from Future \n\tguaranteed benefits regarding line of business, as \n\tdefined in Annex I to Delegated Regulation (EU) \n\t2015/35, other life insurance (gross).\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES","Public","FSAssist","Agree. Amended with \"The future cash–flows undiscounted from amounts recoverables from reinsurance and SPVs/Finite Re, including ceded intra group reinsurance, including future reinsurance premiums. Amount shall be reported net of adjustment for counterparty default risk.\""]
["Reporting","S.13.01","Solo","C0165/R0010–R0330 Future cash–flows used in the Best estimate, Annuities stemming from non–life contracts (gross), Cash in–flows — Total recoverables from reinsurance (after the adjustment)\n\n\tThe cash– flows are the ones not included in Future \n\tpremiums and not including investment returns, \n\tregarding line of business, as defined in Annex I to \n\tDelegated Regulation (EU) 2015/35, Annuities \n\tstemming from non–life contracts relating to \n\tinsurance obligations, including health insurance \n\tobligations.\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES (same as Other cash in-flows)","Public","FSAssist","Agree. Amended with \"The future cash–flows undiscounted from amounts recoverables from reinsurance and SPVs/Finite Re, including ceded intra group reinsurance, including future reinsurance premiums. Amount shall be reported net of adjustment for counterparty default risk.\""]
["Reporting","S.13.01","Solo","C0205/R0010–R0330 Future cash–flows used in the Best estimate, Accepted reinsurance (gross), Cash in–flows — Total recoverable from reinsurance (after the adjustment)\n\n\tThe cash– flows are the ones not included in Future \n\tpremiums and not including investment returns, \n\tregarding line of business, as defined in Annex I to \n\tDelegated Regulation (EU) 2015/35, Accepted \n\treinsurance (gross)\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES (same as Other cash in-flows)","Public","FSAssist","Agree. Amended with \"The future cash–flows undiscounted from amounts recoverables from reinsurance and SPVs/Finite Re, including ceded intra group reinsurance, including future reinsurance premiums. Amount shall be reported net of adjustment for counterparty default risk.\""]
["Reporting","S.13.01","Solo","C0245/R0010–R0330 Future cash–flows used in the Best estimate, Health Insurance(gross), Cash in–flows — Total recoverable from reinsurance (after the adjustment)\n\n\tThe cash– flows are the ones not included in Future \n\tpremiums and not including investment returns, \n\tregarding line of business, as defined in Annex I to \n\tDelegated Regulation (EU) 2015/35, Health \n\tinsurance (gross).\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES (same as Other cash in-flows)","Public","FSAssist","Agree. Amended with \"The future cash–flows undiscounted from amounts recoverables from reinsurance and SPVs/Finite Re, including ceded intra group reinsurance, including future reinsurance premiums. Amount shall be reported net of adjustment for counterparty default risk.\""]
["Reporting","S.13.01","Solo","C0290/R0010–R0330 Future cash–flows used in the Best estimate, Health reinsurance (gross), Cash in–flows - Total recoverable from reinsurance (after the adjustment)\n\n\tThe cash– flows are the ones not included in Future \n\tpremiums and not including investment returns, \n\tregarding line of business, as defined in Annex I to \n\tDelegated Regulation (EU) 2015/35, Health \n\treinsurance.\n\n\tTHIS DOES NOT APPEAR TO BE THE CORRECT DESCRIPTION FOR TOTAL RECOVERABLES (same as Other cash in-flows)","Public","FSAssist","Agree.Amended."]
["Reporting","S.25.01","Both","QRT log files for R0070 / C0050: the description seems not meaningful as intangibel asset risk is explicitly excluded in the calculations shown in 'general comments'.","Public","Munich Re","Agree. The LOG and templates have been amended"]
["Reporting","S.26.01","Both","QRT log file for R0205/C0034 and R0205/C0035: it is stated that the values shall not include recoverables from reinsurance and SPVs. Is this maybe a copy&paste error as the respective values in R0231 etc. shall be reported net of reinsurance recoverables consistently to all other liabilities in QRT 26.01.","Public","Munich Re","Agree. The LOG has been amended."]
["Other",null,"Both","• Timing and Processing – introduction all changes from year Q4 2022 reporting is too ambitious, taking into account all the arguments emphasized by Insurance Europe. We agree that “For new templates an even longer time frame should be considered in order to have a realistic timeframe for undertakings to report all the new information. In addition, if implemented according to plan, the new validation coming with the new taxonomy should be not blocking in the first year of submission (currently planned for 2023)”.","Public","Polish Chamber of Insurance  ","Please note that the implementation date has been extended following the comments received."]
["Other",null,"Both","• Taxonomy – “Further concerns of the industry include: firstly, for a complete review the validation file should be published as part of the consultation package since the definitions in Annex II do not always provide the information on the relationship between different data elements, especially newly introduced ones. Secondly given that the log files were only available in pdf, companies were forced to cross reference with the annotated templates to check whether definitions were changed. And finally, the new taxonomy and DPM needs to be available for the IT process, which EIOPA has not released.”","Public","Polish Chamber of Insurance  ","Please note that the taxonomy will be publicly consulted at the beginning of next year and enough time will be given to stakeholders to provide their comments."]
["Reporting","S.06.02","Both","“Many changes have been suggested to be added to an already extensive template, which will be burdensome and costly to implement. Some of the new information required can hardly be considered improving the template,” which has become more complex over time. “Industry would ask EIOPA not to proceed with its proposals to expand this template since it is already very extensive.” Moreover, the industry takes note of EIOPA’s suggestion not to move forward with the mandatory reporting of the item “fund number”, EIOPA allows for an NSA optionality in completing this field. ","Public","Polish Chamber of Insurance  ","EIOPA sees the point of the request and despite that would like to have more harmonisation in the reporting NSAs can request additional information regardless whether it is explicitly mentioned in the instructions or not. In addition this isn't a new requirement and the change in the instructions aims to clarify it's applicability, that is, to clarify what was the meaning of \"not mandatory\"."]
["Reporting","S.06.04","Both","We agree with: “The industry acknowledges the need for specific climate related reporting, in particular in relation to transition risk and physical risk. However, it highlights that the reporting should not anticipate requirements which are already foreseen under the Taxonomy Regulation. Similarly, it should avoid duplication of information as much as possible, so that the burden of reporting is limited.” “With respect to the new indicators on physical and transition risks, the industry notes a more in-depth and extensive assessment should be carried out.”","Public","Polish Chamber of Insurance  ","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Reporting","S.08.01","Both","Many changes have been suggested to be added to an already extensive template, which will be burdensome and costly to implement. Some of the new information required can hardly be considered improving the template, which has become more complex over time. Industry would ask EIOPA not to proceed with its proposals to expand this template since it is already very extensive.  Moreover, the industry takes note of EIOPA’s suggestion not to move forward with the mandatory reporting of the item “fund number”, EIOPA allows for an NSA optionality in completing this field.","Public","Polish Chamber of Insurance  ","Noted. Changes introduced are considered important for improving the reporting"]
["Reporting","S.14.01 ","Both"," Life obligations analysis – Changes proposed to that QRT are burdensome and costly to implement. We especially agree with Insurance Europe’s remarks:\n- “Premiums written per product are to be further broken down into additional 3 dimensions: at the level of single premiums/current premiums, at the level of sales channels (direct/via credit institutions/other) and at the level of portfolio/new business. Such a granular breakdown is currently not available, and could only be delivered at great expense, if at all. In fact, it is questioned whether the breakdown for premium and commissions in three dimensions is relevant for prudential reasons. The risk of a product is not affected by its sales channel or whether it is new business, single premium/current premium.”\n- “Information on commissions paid at product level and required breakdown of commissions into existing and new contracts are currently not available. This information could only be obtained with additional effort, and implementation is not feasible at present.”\n","Public","Polish Chamber of Insurance  ",{"$f":"+G272","v":"EIOPA notes that the new information required goes along with implementation efforts. Though, the additional information is considered necessary and should - at least in parts - already be available. E.g. the information on the yearly interest rate guarantee should be known to each undertaking, the same holds for the amount on which the interest rate is guaranteed, which may even be a local statutory figure.  Also, approximations are allowed for some of the figures required to reduce the burden. \n\nIn view of the concerns expressed and the implementation effort required, EIOPA however decided to limit the set of newly introduced information:\n-  Information on the amount of  premiums written by distribution channels is essential to allow for an assessment of relevance of sales channels. Currently availble soruce of information on distribution channels are limited. The added information allows to determine the business models used to commercialise certain products and possible concentration risks. EIOPA notes that the new information required may be a burden. However this information is deemed necessary to assess concentration risks and determine the changing distribution patterns - i.e., more reliance on own channels. Moreover, information on written premium by distribuition channels should be already available to insurance undertakings as they should know the channels through which they are writing premium/selling certain products to monitor risks arising from distribution. This information for several Member States and in a more granular manner (i.e., more granulirity in terms of distribution channels) is published annually by InsuranceEurope itself showing that for several markets this information is available. Aware of the possible burden to undertakings, to strike a balance between supervisory needs and and limiting the reporting burden EIOPA has reduced the number of new cells by reducing the granularity required on premiums written by distribution channel, no longer requiring a split between regular and single premiums.  \n- Commissions represent a key information on products being extensively used for understanding insurance undertakings' business model and sales strategy, including to identify whether the possible higher commissions could raise solvency issues and/or increase mis-selling which in turn could lead to solvency risks. This includes information on expected future commissions to allow an assessment of the commissions paid during the whole life-time of the contract. EIOPA also notes the burden to the industry but also notes that the information on commissions paid during the year should be already available as it should be calcualted for both pricing purpose and when commissions are paid to intermediaries. The information on expected future commissions is part of the calculation of the best estimate liabilities, approximations can be used to determine the necessary information. To strike the balance between supervisory needs and possible burden to the industry EIOPA dropped the breakdown between commissions for new contracts for single and regular premium products and no longer requires the information on expected future commissions for new contracts.\n- Information on expected future premiums is important to assess the volume of the business across the whole life-time of the contract and provide a volume measure to which the commissions are compared (i.e. to determine a sensible commission rate). We acknowledge the additional burden on undertakings and the necessity for approximations and simplifications. Also, to reduce the burden, the information does no longer be separately provided for new business.\n- Further, to reduce the burden the information on number of surrenders during the year was simplified and no differentiation for new contracts is required.\n"}]
["Reporting","S.14.02","Both","we agree that “The template requests several datapoints for products split across 27 categories which is deemed inappropriate and will be burdensome and costly to implement. It would be burdensome to make another product classification, in addition to the LOBs and the internal classifications that are currently being used”. Moreover policy and customers information seems to be highly burdensome and partially overlapping with existing local supervisory new contracts reporting.","Public","Polish Chamber of Insurance  ","To reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n\nMoreover the purpose of introducing a single template at the European level is also to limit ad hoc information requests and/or the proliferation of diferent national reporting requirements. "]
["Reporting","S.14.03 ","Both","The most preferable solution is that “the introduction of a detailed template on underwritten cyber risks should be delayed until such a time as when the cyber insurance market grows to a size and market share that justifies such reporting.” The introduction of a new QRT S.14.03 Cyber risk should be conditioned by quite high threshold and the expected scope of this risk should be clearly unified. ","Public","Polish Chamber of Insurance  ","EIOPA disagrees. Delaying the application of the reporting until the market further develops might not only make things more difficult, but also compromise the necessary monitoring of market development for such emerging risks. Please note that thresholds have been introduced to the template."]
["Reporting","S.29.01","Both","needs clarification from the non–life companies’ perspective due to the high level of annuities portfolios as a Polish insurance market specificity or should remained unchanged.","Public","Polish Chamber of Insurance  ","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.23.01 ","Both","We strongly support Insurance Europe, that the definition of foreseeable dividend should be defined in such a way, which prohibits to subtract expected likely and foreseen current year dividend before it is earned through P&L. Foreseeable current year dividends should be accrued incrementally as current year profit emerges, which is the only reasonable solution from the economic point of view. Recognition of foreseeable dividend amount “in full” should be mandatory once its amount was announced/approved during a year or at the end of accounting year.","Public","Polish Chamber of Insurance  ","EIOPA disagrees. The proposal is in line with the Q&A on the reporting of foreseable dividends. See Q&A 1701"]
["Reporting","S.36 ","Both","Taking into account the Insurance Europe’s remarks we agree that „The templates currently in place should remain unchanged for undertakings that \"operate solely or mainly\" in the insurance sector”.","Public","Polish Chamber of Insurance  ","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insuance groups. Reporting requirements which are peculiarities of the financial conglomerate have been removed. Please note that S.36.00 is removed from the package."]
["Reporting","S.37.01","Both","Taking into account the Insurance Europe’s remarks we agree that “However, the templates currently in place should remain unchanged for undertakings that \"operate solely or mainly\" in the insurance sector.”","Public","Polish Chamber of Insurance  ","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insuance groups. Reporting requirements which are peculiarities of the financial conglomerate have been removed. Please note that S.36.00 is removed from the package."]
["Financial stability guidelines",null,"Both","we agree that:\n- “Collecting liquidity risk information does not form part of the solvency regime and the industry believes that this template should not be included. In the context of the non-life insurance market, the template does not match the industry practice as liquidity is managed at entity level rather than product or line of business level.”\n- “EIOPA introduces the S.14 liquidity templates. However, on the group level this is a quarterly template. In order to complete the template on the level of the group, the group needs the templates at solo level. However, the solo level information is an annual template. This requirement would imply an increase in the reporting frequency.”\n","Public","Polish Chamber of Insurance  ","EIOPA acknowledges that whilst liquidity may be less of a concern than some other risks due to the business models, supervisors need to monitor the risk\nand assess the potential materialisation of the risk. Moreover, liquidity is mentioned among the relevant exposures for systemic risk in the IAIS holistic framework (Information are also collected in the context of individual insurance monitoring (IIM)).\n\nWe are aware that most of the groups manage the liquidity at solo level. Nevertheless, in order to avoid a granular reporting at solo level, it was decided to include the liquidity information at group level in the Financial stability templates.\n\nIn order to reduce the reporting burden for insuarnce undertakings, EIOPA proposes the reeduction of frequency for the liquIdity templates (S.14.04/05) to be reported semi-annually (instead of quarterly) ."]
["Other",null,"Both","• The Insurance Europe’s proposal (point 4.2 Thresholds): “Therefore, the threshold should be valid for a longer period, or a single breach should not directly lead to a requirement to submit.” Maybe such comment could be added: if the insurer reaches a threshold at the end of a quarter or year (depends on the QRT’s reporting frequency), it should report the QRT for the next quarter / year (unless the threshold is not reached in the next quarter / year)?","Public","Polish Chamber of Insurance  ","Noted. Please consult the final package as EIOPA extended the thresholds period."]
["Reporting","S.02.01","Both","• We noted that in the ITS in the QRT S.02.01 there are significant changes in definitions of insurance / reinsurance receivables and payables. According to the new definitions all amounts i.e. due and past due should be reported in this items, whereas upon introduction of the SII reporting only past-due amounts were reported in Solvency II column (due amounts were included in technical provisions / reinsurance recoverables).","Public","Polish Chamber of Insurance  ","Noted. Please be informed that suggested changes are intended to implement the approach presented by EIOPA in Q&A 1853."]
["Reporting","S.12.01","Both","EPIFP\n\nWhile EIOPA presented the removal of the transitional information as a simplification to both S.12.01 and S.17.01, it is adding more reporting requirements regarding EPIFP. EIOPA noted that it ‘considers that to provide meaningful insights, EPIFP information should be available at least at Line of Business level.’ It is, however, unclear what these meaningful insights would be. \n\nRecommendation: If EIOPA proceeds with requiring this information, a threshold should be introduced: eg 10% of own funds. In addition, EIOPA should check whether this reporting requirement is not already covered by the Regular Supervisory Report (RSR) report as specified in DA Article 309(6) which appears to closely mirror the new QRT requirements. EIOPA must clarify why two sets of EPIFP reporting are needed. ","Public","Insurance Europe","EPIFP represents the profitability embeded in future premiums. Knowing this figure by LOB would help supervisors to better understand the structure of the business of the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually. \nThe information included in the RSR is frequently included in the QRTs as the objective of both reports are different. In any case, this shows that the information is relevant and undertakings are able to provide it, so it should not create any relevant buden for the undertakings."]
["Other",null,"Both","Some columns / rows in QRTs which are not mandatory (for example “fund number” in S.06.02) should remain non-mandatory and not depend on national supervisory authority decisions (despite S.21.03). Reporting of some parameters would result in more detailed breakdown of data (completely different level of aggregation), more numerous rows, significant increase of time- and labour-intensity.","Public","Polish Chamber of Insurance  ","Noted"]
["Other",null,"Both","General question to thresholds included in definitions to particular QRTs: is it company's right or obligation to report data taking into consideration thresholds included in particular QRTs?\n(e.g. sometimes the company prefers to report data for all LOBs instead only for some material LOBs - will such situations be treated as an error?)","Public","Polish Chamber of Insurance  ","Thresholds should be treated as 'at least' requirements, but not as restrictions prohibiting the submission of more data. In case a company wants to report data for all LOBs it won't be treated as an error."]
["Reporting","S.06.02","Solo","Column C0070 \"Fund number\" - fund number should still remain non-mandatory and not depend on national supervisory authority decision. Particularly it is important in case of funds (asset portfolios) supporting life products, because reporting of this parameter would cause considerably more detailed breakdown of data (completely different level of aggregation), more numerous rows in the template (even ten times more) and significantly increased time- and labour intensity to reconcile values (i.a. Total Solvency II amount) during preparation of the template.","Public","Polish Chamber of Insurance  ","On the fund number, there is no additional requirement. The objective is to clarify the applicability and provide the adequate framework for the current practice in some jurisdictions."]
["Reporting","S.06.02","Solo","Column C0290 \"Bail-in rules\" - this new column is not related to other parameters reported in the template, adding new extra data concerning another directive would cause more time- and labour intensity, while added value is relatively low. Moreover, current description of this column is insufficient to report data correctly.","Public","Polish Chamber of Insurance  ","This items provides information on the existence of potential contingencies impending upon the asset, due to the possibility of it being used as part of the recovery process of the issuer. The characteristics of this contingencies can be found in the Directive 2014/59/EU (the Bank Recovery and Resolution Directive - BRRD)"]
["Reporting","S.06.02","Solo","Column C0294 \"Regional Governments and Local Authorities (RGLA)\" - this new parameter is redundant, because according to the description of this field, it concerns CIC 13 and 14 in reference to ITS (EU) 2015/2011, whereas according to planned changes in Annex IV to the Implementing Regulation (EU) 2015/2450, assets classified as CIC 13 nad CIC 14 are fully, unconditionally and irrevocably guaranteed by regional and local authorities listed in Article 1 of Comission Implementing Regulation (EU) 2015/2011 of 11 November 2015. In practice, in case of Poland almost all assets classiefied as CIC 13 and 14 are listed in mentioned article 1 and would be decribed as \"1 - Listed on the ITS\" and there would be few assets (13 and 14) classified in a different way.","Public","Polish Chamber of Insurance  ","Noted. The argument demonstrates that there may be a portion of assets not covered in the \"ITS\""]
["Reporting","S.06.02","Solo","Column C0301 \"Long-term equity investment\" - reporting this new parameter could cause more detailed breakdown of data and increased time- and labour intensity to prepare the template. Moreover, how data data should be reported (how many rows) in section \"Information on positions held\" (where ID codes cannot be duplicated), if the same asset (the same ID code) would be potentially classified in the same template in C0301 both as \"1 - Yes\" and \"2 - No\" (two rows in section \"Information on assets\")?","Public","Polish Chamber of Insurance  ","Agree. Amended."]
["Reporting","S.06.02","Solo","Column C0381 \"Issue date\" - new parameter is redundant, because it would cause duplication of data reported under SII. Column with issue date (with the same requirements) in relation to SII ID codes is already reported quarterly in different template to the national supervisory authority to fulfill requirements of ECB.","Public","Polish Chamber of Insurance  ","Please note that this requirement is an extention of the ECB requirement, now applicable to all insurance undertakings - there is no duplication."]
["Reporting","S.08.01","Solo","Column C0070 \"Fund number\" - fund number should still remain non-mandatory and not depend on national supervisory authority decision. Particularly it is important in case of funds (asset portfolios) supporting life products, because reporting this parameter would cause more detailed breakdown of data (different level of aggregation), more numerous rows in the template and significantly increased time- and labour intensity to reconcile values (i.a. Solvency II value) during preparation of the template.","Public","Polish Chamber of Insurance  ","On the fund number, there is no additional requirement. The objective is to clarify the applicability and provide the adequate framework for the current practice in some jurisdictions."]
["Reporting","S.08.01","Solo","Column C0041 \"Unique Transactions Identifier\" - this new additional parameter from EMIR reporting is not related to other parameters reported in the template, adding new extra data concerning another directive would cause more time- and labour intensity, while added value is relatively low. Moreover, such data as UTI are not reported by the undertaking to the national supervisory authority in any way, so there is probably no data binding. Such data as UTI are reported by the undertaking only to CCP (in Poland KDPW).","Public","Polish Chamber of Insurance  ","EIOPA explained the reasoning behind the options taken regarding how and when to take into account EMIR data, in paragraphs 2.168 to 2.176 of the Report on quantitative reporting templates (EIOPA-BoS-20/754, 17/12/2020), including the link between SII template and EMIR database."]
["Reporting","S.06.04","Solo","Could you, please, specify more details about filling rules of this new template? Could you add precise information about requirements concerning calculation of \"Sustainable investments\", \"Climate change-related transition risk - KPI\" and \"Climate change-related physical risk - KPI\" - for instance which NACE codes and property locations should be taken into account? Current description of all required fields is insufficient to report data correctly.","Public","Polish Chamber of Insurance  ","Noted. On the sustainable investment KPI: EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\n\nOn the transition and physical risk KPI, good practices are starting to emerge and will consolidate over time. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for the risk assessment. The consultation and pilot exercise on the guidance (March 2022) are an opportunity to test and further discuss good practices."]
["Reporting","S.12.02","Solo","\"When this amount is higher than 90 % but lower than 100 % then only R0010, R0020 and R0030 shall be reported\" - we understand that we check this condition on total values (i.e. total technical provisions for home country / total technical provisions), not for each LOB separately.\nMoreover, we understand that we need to report one or more lines of business to achieve 90% of coverage of the life technical provisions (i.e. material lines of business, not one \"material line\"...).\nShould the \"Line of business be selected using a decreasing order of technical provisions\" similarly to requirements included in S.20.01?\nCan the Company report data for all lines of bussiness (not only material, i.e. without taking into consideration the threshold) or it will be treated as an error? Maybe relevant information could be included in the final ITS.","Public","Polish Chamber of Insurance  ","EIOPA confirms your interpretations. You can report data for all lines of business and this will not be treated as a mistake. However, please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold."]
["Reporting","S.13.01","Solo","In S.18.01 there is a threshold according to which the Company can report only data for material lines. Why there is no similar requirement in S.13.01?","Public","Polish Chamber of Insurance  ","EIOPA discussed the possibility to introduce a threshold to S.13.01. However based on the feedback received and the impact assessment EIOPA decided not to introduce a threshold."]
["Reporting","S.14.01","Solo","We understand that for annuities stemming from non–life columns C0041, C0051, C0052, C0053, C0210, C0075, C0076, C0077 , C0078, C0200, C0260, C0261, C0270, C0280, C0142 are not applicable (there are no specific provisions in the draft).","Public","Polish Chamber of Insurance  ","Indeed all the cells relating to surrender are not valid for annuities from non-life colleagues. This will be clarified in the LoG File."]
["Reporting","S.14.01","Solo","Please clarify what should be provided in C0261 if the contracts within one product have different guaranteed rates for contract signed in different periods.","Public","Polish Chamber of Insurance  ","Typically it would be expected that product categories carry different guaranteed rates. Though, in case varying guaranteed rates are observed for one product category, an average rate should be calculated based on the amount on which the rate is guaranteed (C0280)."]
["Reporting","S.14.01","Solo","Does the amount on which interest rate is guaranteed (C0280) should be understood as technical provisons for accounting purpose calculated with the current technical rate (which may be lower than the rate in a contract with a policy holder ) or is it to be a mathematical provision calculated using the rate from the contract?","Public","Polish Chamber of Insurance  ","The amount on which the interest rate is guaranteed should reflect the contractual amount that is the basis to determine the actually guaranteed value which can be e.g. the sum of past premiums paid. The specifications of the contract should be considered in this respect. For a \"classical life insurance product\", this amount can be equal to the mathematical provisions calculated using the rate from the contract and may in certain cases be identical to a balancce sheet position in local statutory accounts. However, please note that the local statutory regualtions are not relevant in the first place to determine the amount in question."]
["Reporting","S.14.01","Solo","C0075, C0076, C0077, C0078, C0190 - can approximations be applied to fill in data per product in those columns (similarly as for C00180)?","Public","Polish Chamber of Insurance  ","Indeed, approximations are possible, clarifications will be provided in the LoG File. "]
["Reporting","S.14.02","Solo","Should this QRT be reported when non-life business is insignificant? Could you please introduce a threshold in this QRT? (for example TP non-life / total TP)","Public","Polish Chamber of Insurance  ","The template has been significantly simplified and thus threshold has been assessed as not needed."]
["Reporting","S.14.02","Solo","Wouldn't it be possible to use already existing segmentations into LINES OF BUSINESS or classes used internally by the undertakings?\nAnother segmentation can lead to confusion, especially when category names and descriptions seems inconsistent with existing names and descriptions of the Line of business or classes e.g.\nCategory: 17 - Income Protection: All products falling under \"risk class 16\" with the exception of what is covered under product category 14 and 20 have name similar to Line of Bussiness: (2) Income protection insurance but it mainly consists of risk from Class: 16. Miscellaneous financial loss (and line of bussines of the same name (12) Miscellaneous financial loss).","Public","Polish Chamber of Insurance  ","Lines of business are not sufficiently granular as many product categories fall into different lines of business or vice-versa. This template will increase supervisory visibility on products as the pnademic highlighted the need to increas visibility on products to assess and quantify risks for undertakings for specific products. \n\nTo reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n"]
["Reporting","S.14.02","Solo","- C0010 - \"All non-life products commercialized should be reported under the product category which best corresponds to the product taking into account the product characteristics and coverage.\" - is it possible to change the classification of single product to product category or should it be consistent over time? \n- C0032 - for example one product is included in two product categories - should this product be presented in two product categories?\n- C0035 - what should be reported in this column if we have only \"add-ons\" in non-life? (empty?)\n- C0070, C0080, C0090 - can gross written premiums according to local GAAP be reported (similarly to S.04, S.05).\n- C0100 - maybe commissions expenses (accrued) can be reported (similarly to S.04, S.05), instead of commissions paid\n- C0120 and C0130 - what does it mean: \"regardless of whether they are sold with an add-on\". If the product category is reported in 2 rows (with an add-on and without an add-on) - should the number of insured / properties be reported only in one row? What should we report if we have only \"add-ons\" in non-life?","Public","Polish Chamber of Insurance  ","\nC0010 - we deem important to mantain a coherence during time. Moreover increasing the granularity to single product rather than product category would result in not standardized reporting as the type of product change by manufacturer.\nC0032 - yes should be unbundle accordingly\nC0035 - only the add-on should be reported as product \nC0070, C0080, C0090 - yes it should be similar to S.04 and S.05\nC0100 - the comission we are looking for are the one defined in the instruction and alligned to S.14.01 hence they should include any form of monetary benefits which is paid to an insurance distributor by any other person than the customer or a third party acting on behalf of the customer, in relation to insurance distribution activities.\nC0120 and C0130  - if the product is sold with add-on the main feature should be disclosed and then flagged the cell corresponding to add - on . If only add-o are sold these are de facto the non life product hence should be reported in teh relevant product category "]
["Reporting","S.14.03","Solo","- C0090 - can Premiums written according to Local GAAP (similarly to other templates) be reported instead of premiums earned?\n- C0140 - best estimate and TP as a whole?","Public","Polish Chamber of Insurance  ","Noted. EIOPA will clarify this in the instructions"]
["Reporting","S.16.01","Solo","In the QRT S.19.01 currencies threshold is modified (e.g. from 3% to 10%) - please introduce the equivalent change to the QRT S.16.01","Public","Polish Chamber of Insurance  ","EIOPA analysed the possibility to change the threshold but based on the impact assessment and considering that any other change will not make a technical difference decided to keep the template as it is."]
["Reporting","S.17.02","Solo","\"When this amount is higher than 90 % but lower than 100 % then only R0010, R0020 and R0030 shall be reported\" - we understand that we check this condition on total values (i.e. total technical provisions for home country / total technical provisions), not for each LOB separately.\nMoreover, we understand that we need to report one or more lines of business to achieve 90% of coverage of the non-life technical provisions (i.e. material lines of business, not one \"material line\"...).\nShould the \"Line of business be selected using a decreasing order of technical provisions\" similarly to requirements included in S.20.01?\nCan the Company report data for all lines of bussiness (not only material, i.e. without taking into consideration the threshold) or it will be treated as an error? Can relevant information be included in the final ITS?\nWe noted that in the projected QRT there is no cell Z0020 (business type), while in the draft of ITS there is a reference to Z0020 in cell C0020 to C0130/R0100.","Public","Polish Chamber of Insurance  ","EIOPA confirms your interpretations. You can report data for all lines of business and this will not be treated as a mistake. However, please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold.\nPlease also note that by mistake Z0020 has been removed but now brought back."]
["Reporting","S.18.01","Solo","We understand that we need to report one or more lines of business to achieve 90% of coverage of the non-life technical provisions (i.e. material lines of business, not one \"material line\"...).\nShould the \"Line of business be selected using a decreasing order of technical provisions\" similarly to requirements included in S.20.01?\nCan the Company report data for all lines of bussiness (not only material, i.e. without taking into consideration the threshold) or it will be treated as an error? Can relevant information be included in the final ITS?","Public","Polish Chamber of Insurance  ","EIOPA confirms your interpretations. You can report data for all lines of business and this will not be treated as a mistake. It has been clarified in the ITS. "]
["Reporting","S.21.01","Solo","We understand that we need to report one or more lines of business to achieve 90% of coverage of the non-life technical provisions (i.e. material lines of business, not one \"material line\"...).\nShould the \"Line of business be selected using a decreasing order of technical provisions\" similarly to requirements included in S.20.01?\nCan the Company report data for all lines of bussiness (not only material, i.e. without taking into consideration the threshold) or it will be treated as an error? Can relevant information be included in the final ITS?","Public","Polish Chamber of Insurance  ","EIOPA confirms your interpretations. You can report data for all lines of business and this will not be treated as a mistake. It has been clarified in the ITS. "]
["Reporting","S.30.01","Solo","C0030 - Risk identification code - The description of the item does not correspond to the changes in the form (20 largest facultative reinsurance exposures instead of 10) - it should be updated.","Public","Polish Chamber of Insurance  ","Noted. Amended"]
["Reporting","S.30.01","Solo","C0045 - Description of operation of the facultative reinsurance item - \"Describe of the operation of the facultative reinsurance item.\"\nWhat description should we give? Please provide us an example.","Public","Polish Chamber of Insurance  ","This cell has been deleted."]
["Reporting","S.30.03","Solo","C0420 - Coverage of a layer covered by reinsurance - \"Include the coverage of a layer as an amount covered by reinsurance.\"\nWhat value should we enter in this position? What is the difference to the C0230 - Maximum cover per risk or event?","Public","Polish Chamber of Insurance  "," It should include the maximum coverage per layer of a reinsurance treaty. The LOG has been improved."]
["Reporting","S.30.03","Solo","C0430 - Order of claims within the reinsurance program - \"Include the order of claims within the reinsurance program.\"\nWill this item be selected from the list? ","Public","Polish Chamber of Insurance  ","This cell has been deleted."]
["Reporting","S.36.01","Both","S.36.01-S.36.05 - Please provide a clearer definition of: indirect transactions and single economic operation. It would be much appreciated that some examples will be also provided, i.e. which kind of transactions should be treated as indirect/direct transactions and moreover which should be treated as single economic operation. ","Public","Polish Chamber of Insurance  ","For the purpose of reporting the two fields of  indirect transactions and single economic operations are to be filled in as mutually exclusive. About the definitions, indirect transactions are normally identified as a chain of transactions shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or entities outside of the group but ultimately risk exposure is brought back or stays within the group and impacts the solvency position of any insurance undertaking of the group.(description in the log to be amended if definition confirmed). While, where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation. "]
["Reporting","S.36.01","Both","Please provide a clearer information about distinction between S.36.01 and S.36.05. For example, in case of dividends please indicate what should be reported in S.36.01 and what should be reported in S.36.05 (we believe that the same information should not be reported in both QRTs).","Public","Polish Chamber of Insurance  ","EIOPA confirms that although interest, dividends and premiums are reported in S.36.01, S.36.02 and S36.04 they must be reported additionally in S.36.05 P&L. The double reporting is expected to be of limited burden."]
["Reporting","S.36.04","Both","Should accepted reinsurance also be reported in this QRT?\nShould the column C0170 be empty in case of transaction type \"reinsurance\"? (because for reinsurance columns C0150 and C0160 should be filled in)","Public","Polish Chamber of Insurance  ","Eiopa confirms that accepted reinsurance should be reported.\nEIOPA confirms that the column C0170 would be empty in case of transaction type \"reinsurance\" and for reinsurance columns C0150 and C0160 should be filled in."]
["Reporting","S.36.05","Both","- Please provide a clearer definition about the column C0100 - Type of transaction. It will be much appreciated if you could provide examples what should be treated as: fees, commission, interest, dividends, others (please explain in which category we should report internal cost sharing or costs from rental agreements)?\n- Should reinsurance transactions be reported in this template? (in C0110 there is an option \"6 - Insurance / reinsurance\" in the closed list) If so, please explain what exactly should be reported in C0140 for reinsurance (we believe that the same information should not be reported in S.36.04 and S.36.05)","Public","Polish Chamber of Insurance  ","Type of transactions  include now costs/revenues from internal cost sharing or from rental agreement, while rinsurance and reinsurance transactions are not be reported here but only in S.36.04. "]
["Reporting","S.37.02","Group","If templates S.37.02 and S.37.03 remain in the final ITS please consider below remarks: \n- can QRTs S.37.02 and S.37.03 be based on the same significant exposures as reported in S.37.01? In our opinion only significant exposures should constitute the basis for additional analyzes, not all exposures (as mentioned in the sentence “The tables shall be based on all the exposures (full balance sheet) after credit or insurance risk mitigation technique and exemptions (net amount)\"). Moreover please be aware, that in S.37.03 in second part of report (S.37.03.04.02) in cell Z0010 type of bond should be indicated. Combining those two descriptions is confusing;\n- please provide more information about the \"sector\". It will be much appreciated if you could add also some examples;\n - where is the \"other\" category in this QRT mentioned in the sentence: \"In case the country, sector or currency is not relevant the figures may be reported under an “Other” category\"?","Public","Polish Chamber of Insurance  ","S.37.03 - cell Z0010 type of bond: a clear closed list is already offered .\nThe instructions in S.37.02 provides a closed list of options for sectors.\nOthers can be entered as the name for the last category, for total remanining exposures"]
["Reporting","S.37.03","Group","If templates S.37.02 and S.37.03 remain in the final ITS please consider whether QRTs S.37.02 and S.37.03 can be based on the same significant exposures as reported in S.37.01? In our opinion only significant exposures should constitute the basis for additional analyzes, not all exposures.","Public","Polish Chamber of Insurance  ","It was extensivelly discussed in the JCFC TF, but finally this proposal was not adopted. The reason is that the exposures which are above the threshold for significant exposures towards counterparty are limited and do not reflect the exposures by country, currency etc. In that approach the S.37.02 and S.37.03 is not necessary from groups as it would be possible to have such data from S.37.01. "]
["Financial stability guidelines",null,"Both","S.14.04 & S.14.05 - please consider deleting those templates from the quarterly reporting - too detailed information required for FS quarterly, while S.14.01 & S.14.02 are required only annually.\nIf those templates finally are required:\n- maybe gross or net written premium (acc. to local GAAP) can be reported instead of cashed premium net?\n- Net Reinsurance flows - cash flows from the period should be reported or maybe the net balance (i.e. Reinsurance receivables minus Reinsurance payables) at the reporting period?","Public","Polish Chamber of Insurance  ","In order to reduce the burden for insurance undertakings, EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). \n\nFurther,\n- Cashed premium is considered necessary for the adequate supervision of liqiudity risks, moreover, gross and net written premium  already collected in different templates. \n- The Net reinsurance flows should reflect the actual cashflows as at the reference date."]
["Reporting","S.12.01","Solo","EIOPA decided to make this template more burdensome by adding further reporting requirements on EPIFP without any real further justification. The potential benefit of this additional requirement is not understandable. \n\nEPIFP is also reported in the QRT S.23, and so EIOPA should clarify whether the reporting in S.12 would be gross of tax. And, as this information is now presented in S.12, should QRT S.23 report the EPIFP net of tax, as it is included in the own funds?","Public","Insurance Europe","EPIFP represents the profitability embeded in future premiums. Knowing this figure by LOB would help supervisors to better understand the structure of the business of the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually. \n\nEPIFP should always be reported gross of taxes in all templates (S.12.01, S.17.01 and S.23.01)."]
["Reporting",null,"Solo","Commission Implementing Regulation 2015/2450 Article 9(b): \"(b) Where any single currency represents less than 80% of the total liabilities\". - Would you like to record all small currencies? Or should individual currencies be reported until 80% of total liabilities are reached?","Public","ECB","This template is not required to be submitted if one single currency represents more than 80 % of liabilities. When it is to be submitted then all currencies are to be reported. Information reported by currency shall at least represent 80 % of the total liabilities. The remaining 20 % may be aggregated. "]
["Reporting","S.02.02","Both","Template still called \"Assets and liabilities by currency\" while in Commission Implementing Regulation 2015/2450 is only called \"liabilties by currency\"","Public","ECB","Noted. Amended"]
["Reporting",null,"Solo","Commission Implementing Regulation 2015/2450 Article 11(l) template S.20.01.01 of Annex I, specifying information on the development of the distribution of the claims incurred at the end of the financial year for material lines of business representing a coverage of 90% of the non-life technical provisions as defined in Annex I to Delegated Regulation (EU) 2015/35, following the instructions set out in section S.20.01 of Annex II to this Regulation;","Public","ECB","Agree. Amended"]
["Reporting","S.17.02","Solo","Commission Implementing Regulation 2015/2450 Article 11 \"(b) template S.12.02.01 of Annex I, specifying information on life and health SLT technical provisions by region and by material country where the technical provisions regarding the home country represent less than 90% of the sum of the technical provisions calculated as a whole and gross best estimate, following the instructions set out in section S.12.02 of Annex II\" Article 11 (i) on S.17.02.01 does not specify material countries","Public","ECB","Agree. However, please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold."]
["Reporting","S.06.04","Solo","Instructions: \"As an input to computing the share of investments exposed to transition risk, undertakings are required to report four-digit level NACE codes for NACE sections A to N in the List of assets S.06.02.\" Maybe to add that this applies to the field issuer sector.","Public","ECB","Agree"]
["Reporting","S.06.04","Solo","Instructions and template: R0030/C0010: The same field should include the KPI and the location of the property?","Public","ECB","The location is reported in S.06.02 while the R0030/C0010 requests the reporting only of the KPI"]
["Reporting","S.06.02","Solo","C0141 Write off/write downs: To be in line with BaFin and BuBa requirements, the LOG file should be amended to also include CIC 1.","Public","ECB","Don't agree. Please note that the proposed requirement follows EIOPA opinion, in which this item was restricted to CIC categories 2 and 8 only.\n\nPlease note that following the comments received EIOPA decided to not introduce this change. As a result this proposal is not included in the final ITS package"]
["Reporting","S.04.03","Solo","C0030 Type of branch localisation. Does this refer to the location of the branch (EEA/non-EEA)? If yes, what is the added value when read in conjunction with C0040? ","Public","ECB","The interpretation is correct (i.e. this refers to whether branch is EEA or non-EEA).  The added value relates to techncial advice received on optimal structuring for XBRL implmentation; it does not add any information content not already implicit within C0040."]
["Reporting","S.04.04","Solo","Acquisition expenses should be used instead of Expenses incurred (S.04.05). Fields relating to the same should be named the same across templates.","Public","ECB","Disagree - S.04.05 is intended to capture all expenses incurred (including, but not limited to, acquisition expenses), whereas S.04.04 only captures acquisition expenses."]
["Reporting","S.04.04","Solo","S.04.05 refers to gross values, is this different from S.04.04 where \"gross\" is not mentioned? Fields relating to the same should be named the same across templates.","Public","ECB","The underlying definitions are the same (i.e. gross is noted in the ITS instructions for S.04.04); however, it is correct to note that this is not reflected in the item titles.  Amendment of titles will be considered."]
["Reporting","S.04.05","Solo","Is C0010 the sum of S.04.04 C0010 and S.04.04 C0020?","Public","ECB","Yes - these figures should reconcile at the overall entity level (as in both cases the total level of premium for an individual LoB is being considered)."]
["Reporting","S.04.03","Solo","We generally welcome the amendments in the different templates of S.04., which lead to a more comprehensive reporting of cross-border business. We also welcome the fact, that the positions on acquisition expenses and commissions were seperated and the definitions were corrected (in the old framework the term \"commissions\" in S.04. was used in the sense of acquisition expenses).","Public","ECB","Noted"]
["Reporting","S.04.04","Solo","Regarding ITS reporting instructions - Annex 2: For the definition of \"Premiums written\" the sentence \"Amount of taxes or charges should be excluded from the written premiums\" was added. Does this mean that those figures will differ substantially from the current methodology or is this just a clarification (meaning that this should already be the case in the current reporting)?","Public","ECB","This is a clarification to ensure consistency; should already be the case for current reporting."]
["Reporting","S.12.02","Solo","Due to the new materiality concept introduced (LOBs to capture 90% of TPs only) the allocation of TPs on an appropriate country-by-country base becomes even more incomplete. Since insurance corporations always have to calculate those materialities we were wondering whether it wouldn't be easier for the industry to report all data on an country-by-country base (i.e. without country and LOB materiality threshold). Dependend on whether ESCB breakdowns can still be estimated with a high quality, some additional information might need to be collected via ECB add-ons. ","Public","ECB","Please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold."]
["Reporting","S.12.02","Solo","One drawback of the new materiality thresholds is that the current cross-checks between S.12.01 and S.12.02 will not be feasible anymore (current BV835, BV990) .","Public","ECB","Noted."]
["Reporting","S.13.01","Both","EIOPA made extensive changes to this template. \n\nIn the log files, EIOPA states \"It should be noted that the projection horizon of future cash-flows should be realistic and it is not limited by contract boundaries. Eg a pure unit-linked product with immediate contract boundaries should not be assumed to immediately lapse. Instead, realistic projections should be reported in case it is valued as best estimate plus risk margin.\". This change is questionable and problematic, as it seems to go beyond the solvency regulation requirements. \n\nWhile the proposal to exempt all undertakings using simplifications for the technical provisions, for which an estimate of the expected future cash flows arising from the contracts is not calculated, is helpful, the request to report the value of the ‘total recoverable from reinsurance’ by LoB, and to split ‘future benefits’ in ‘future guaranteed benefits’ and ‘future discretionary benefits’ is seen as burdensome (from both a practical and technical point of view) with limited additional benefits. Undertakings will typically find it difficult to determine a clear cut-off point between the expected guaranteed cash flows and discretionary benefits, as there will be many different scenarios with different splits between the two.\n\nEIOPA announced it was investigating a threshold for this template, but disappointingly no threshold was proposed. Insurance companies in scope of stress tests have been asked information in similar detail before, but companies not in scope of stress testing have no experience with reporting this type of information, and proportionality should therefore be introduced. ","Public","Insurance Europe","The sentence highlighted is not a change, but a clarification. Undertakings are expected to report realistic cash flows for BE valuation as long as the BE is calculated through cash flow discounting. If the undertaking uses a calculation method that does not imply projecting future cash flows for the UL, then there is no need to report the template. If the undertaking uses a caluation method that requires projecting future cash flows, then the cash flows included in the BE should be reported. However, since this particular topic has been covered in the Guideline 0 on Contract Boundaries, EIOPA will delete the paragraph to avoid any confusion.\n\nEIOPA disagrees with the proposal to drop the split between future guaranteed benefits (FGB) and future discretionary benefits (FDB). EIOPA understands that under stochastic valuation different scenarios would lead to different allocation of cash flows. However, this issue does not only affect to the split of cash flows between FDB and FGB but also to the total amount of cash flows which is currently being reported. For this reason, the LOG already clarifies that reconciliation with BE is not required, but additional guidance has been included. \n\nEIOPA disagrees of providing a threshold. S.13.01 exists from the inception of Solvency II, so all undertakings should be used to it. The exemption for undertakings using simplifications, already linked to proportionality, should be enough. "]
["Reporting","S.17.02","Solo","Due to the new materiality concept introduced (LOBs to capture 90% of TPs only) the allocation of TPs on an appropriate country-by-country base becomes even more incomplete. Since insurance corporations always have to calculate those materialities we were wondering whether it wouldn't be easier for the industry to report all data on an country-by-country base (i.e. without country and LOB materiality threshold). Dependend on whether ESCB breakdowns can still be estimated with a high quality, some additional information might need to be collected via ECB add-ons. ","Public","ECB","Please note that considering the complexity of the threshold and the outcome of the discussions with the ECB to include add-on coming from the introduction of this threshold EIOPA decided to drop out this proposal and keep the current threshold."]
["Reporting","S.12.02","Solo","It does not seem to be a general rule that totals are deleted (e.g. S.17.01.02). We believe that not reporting cells C0210 and C0150 will not result in a reduction in reporting burden. Reporting agents are currently reporting these cells and will need to change their current reporting and implement new validation checks (e.g. between S.02.01 and S.12.02). In case these cells end up being deleted, it is important that the validation checks are updated accordingly in order to ensure data quality.","Public","ECB","EIOPA disagrees and will keep the template as publicly consulted. Validations will be further analysed as part of the work on taxonomy 2.8.0."]
["Reporting","S.06.02","Solo","There is an inconsitency between the introductory statement: \"All reporting items shall be reported, except when otherwise stated in these instructions.\nItems C0110, C0120, C0121, C0122, C0130, C0140, C0141, C0160, C0200, C0230, C0270, C0280, C0310, C0370, and C0380 are not applicable to CIC 09 - Other investments.\" and instructions for C0140 : \" Amount outstanding measured at par amount, for all assets where this item is relevant, and at nominal amount for CIC = 72, 73, 74, 75, 79, 09...\"","Public","ECB","Agreed and amended. Acquisition value has more relevance for this CIC code."]
["Reporting","S.06.02","Solo","Is accrued interest always zero for zero coupon bonds or is the interest from the issue date until the reference date reported (C0180)? Could this be clarified either in the LOG files or in the Q&A?","Public","ECB","EIOPA considers that it should be zero for zero cupon bonds. However there may be exceptions and therefore it is prefereble not to add this constraint."]
["Reporting","S.06.02","Solo","For zero coupon bonds is the nominal value (issue price+accrued interest) to be reported? Could this be clarified either in the LOG files or in the Q&A?","Public","ECB","EIOPA considers that the nominal value should not include accrued interest. The accrued interest should be only part of the Solvency II amount. It is also reflected in C0380 (Unit percentage of par amount Solvency II price)"]
["Reporting","S.06.02","Solo","C0210-C0280, C0320 and C0350: \"Regarding CIC 8 — Mortgages and Loans, other than mortgage and loans to natural persons the group relation relates to the borrower;\" This could be amended to explicitly exclude the new CIC codes 87 and 88.","Public","ECB","Agree. Amended"]
["Reporting","S.12.02","Solo","In order for instructions to be clearer, it should be good to first define for which line of business the template should be reported and then define how the country split should be reported.","Public","ECB","The instructions have been clarified as \"The threshold is based on the material lines of business calculated on S.12.01. As a next step the material countries for these material line of business are calculated.\""]
["Reporting","S.17.02","Solo","One drawback of the new materiality thresholds is that the current cross-checks between S.17.01 and S.17.02 will not be feasible anymore. It will be more difficult to cross-check the values between S.17.01 and S.17.02 (current BV446-457, BV1032-1033, BV1093-1103, BV1110-BV1120).","Public","ECB","Noted"]
["Reporting","S.19.01","Solo","In the LOG file \"ii. If the total gross best estimate for one non–life line of business represents more than 10 % of the total gross best estimate of the claims provision the information shall be reported with the following split by currencies in addition to the total for the line of business;\", \"a) Amounts in the reporting currency\" was deleted. Could you clarify if total line of business should be reported in the reporting currency, without thresholds, even if some currency splits are reported?\nThe following clarification could be added to the LOG file: \"If option „2 – reporting currency“ is selected in Z0040 “currency conversion”, the default value “x0” should be reported in Z0030 “currency”.\"","Public","ECB","EIOPA confirms that if no currency split is reported ,the total needs to be reported in reporting currency. \nAgree with the proposal and amended the instructions."]
["Reporting","S.19.01","Solo","Introducing a materiality threshold on the line of business might affect the quality of ESCB estimations. Dependening on whether ESCB breakdowns can still be estimated with a high quality, some additional information might need to be collected via ECB add-ons.","Public","ECB","Noted."]
["Reporting","S.19.01","Solo","Possible useful validations between S.17.01 (R0160/C0020-C0130) and S.19.01 (R0260/C0360) would not be possible. EIOPA Q&A 2040 specifies that the values for best estimate claims provision (C0360/R0260) reported in S.19.01 … should equal the values for the best estimate claims provision by line of business in S.17.01/R0160/C0020-C0170. For each line of business in S.19.01, the accepted proportional reinsurance business should be included. This would not apply anymore.","Public","ECB","Noted."]
["Reporting","S.17.01","Solo","While EIOPA presented the removal of the transitional information as a simplification to both S.12.01 and S.17.01, it is adding more reporting requirements regarding EPIFP. EIOPA notes that it ‘considers that to provide meaningful insights, EPIFP information should be available at least at Line of Business level.’ It is unclear what these meaningful insights would be. \n\nThe EPIFP disclosure requires complex calculation to produce, yet this figure is only required as a disclosure. It is not clear what this data point is used for or what the benefit of providing it is. The industry therefore recommends this requirement is removed or reduced to only being required for annual reporting as a minimum. See also comments regarding the EPIFP reporting.","Public","Insurance Europe","EPIFP represents the profitability embeded in future premiums. Knowing this figure by LOB would help supervisors to better understand the structure of the business of the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually.  "]
["Reporting","S.12.01","Solo","How will the amendment of Article 308d  affect the calcualtion of technical provisions? E.g. will the best estimate or other components of TP change as a result of this amendment?","Public","ECB","The current ITS amendments does not reflect possible changes in the SII Direcetive or Delegated Regulation. Once the changes are incorporated in Level 1 and Level 2 EIOPA will review what are the implications for the ITS on reporting and disclosure."]
["Reporting","S.04.03","Solo","C0010 – Underwriting entity code: it is stated in the log-file “For EEA branches and any non-EEA branches which do not have a distinct LEI, a specific code shall be attributed by the undertaking. Such a code shall be unique for the specific underwriting entity and shall not overlap with any other code attributed”. It must be clarified that the code will not only be unique but will also stable and not change over time. The following sentence which is also included in S.06.02 C0040 could be added \"This code must be unique and kept consistent over time.\"","Public","ECB","Agreed"]
["Reporting","S.06.02","Solo","C0296 – Property type: If a building has more than one purposes (e.g. retail and business offices) will the classification be undertaken based on the most dominant use? Would it be possible to specify in the LOG files?","Public","ECB","This item depends on the approach used in the ESRB recommendation. Please refer to ESRB Recommendation of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real estate data gaps (ESRB/2019/3), as mentioned in the instructions."]
["Other",null,null,"Executive Summary\nThe Belgian insurance sector is disappointed in the EIOPA proposal to amend the supervisory reporting and public disclosure documents.\nEIOPA is requested to:\n\tAlign the entry into force of proposed changes to the QRTs with the Solvency II review such that modifications to the reporting systems are only necessary once.\n\tPresent the final QRT package (including all technical documents, such as the DPM and the taxonomy) two years in advance to allow for sufficient implementation time.\n\tFirst analyse the effectiveness of the current set of QRTs and the extent to which these are used.\n\tSimplify the current set of QRTs and delete unused QRTs.\n\tAdd only new QRTs to the extent that these are useful.\n\tThe QRTs should remain limited to prudential reporting.\nIf EIOPA would continue with its proposal, the insurance sector would rather prefer a status quo of the current reporting package and reject all changes.","public","Assuralia","EIOPA disagrees for the following reasoning: No amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \nIn addition all changes included now are based on all the work during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations.\n"]
["Other",null,null,"1.\tUnfeasible timing\n\nA.\tNeed for alignment with the Solvency II review\nEIOPA should avoid making any changes to its QRTs and reporting requirements before proper Level 1 and Level 2 strategic consideration of the issues related to the Solvency II 2020 review (including full scrutiny by the EU institutions) to avoid having to change the QRTs and the IT-systems twice in a period of 3 years, which is both costly and burdensome. In this regard it is highlighted that EIOPA should respect the hierarchy of the EU-regulation, the QRTs are addressed in the ITS, while at the same time L1 and L2 are subject to an extensive review. Changes to the reporting systems should be made only once, as part of the Solvency II review.\n\nB.\tNeed for sufficient implementation time\nNine months implementation time is too short\nTo be able to produce the QRTs for Q4 2022 reporting and end of year 2022 reporting, the QRTs should be finished before December 2022, as companies start their reporting process before the reporting date due to the tight deadlines. This means that companies will only have time starting from the EC approval of the proposals, i.e., from January/February until November. Nine months is largely insufficient to implement this extensive package.\n\nRetro-active data gathering\nIt is noted that the new ITS will only be available beginning next year, while companies need to report on that year. This means that companies should set-up internal processes to gather newly requested information from 1 January 2022. However, since the QRTs, DPM and taxonomy will not be ready in time, companies will have to start a time-consuming retro-active data gathering exercise.\n\nData quality will suffer\nIt is unclear why EIOPA is rushing these extensive changes. If these changes will be pushed through, it will be expensive to implement them – i.e., testing and validating the changes to the IT-systems. A rushed approach is likely to lead to data quality problems and empty fields.\n\nInsufficient resources due to IFRS 17\nIn many cases the resources that will be working on the implementation of the reporting package will also be working on other major regulatory changes, including the implementation of IFRS 17 and IFRS 9 as well as the sustainability requirements. Insurance companies have already made a detailed planning for their IT architecture and allocated resources mostly to IFRS. There are not enough highly skilled people available. It estimated that for an average sized company, over 100 people will be working on implementing these QRT over a period of at least 18 months.\n\nEIOPA is requested to:\n\tAlign the entry into force of proposed changes to the QRTs with the Solvency II review such that modifications to the reporting systems are only due once.\n\tPresent the final QRT package (including all technical documents, such as the DPM and the taxonomy) two years in advance to allow for sufficient implementation time.","public","Assuralia","EIOPA disagrees for the following reasoning: No amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \nIn addition all changes included now are based on all the work during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations.\n"]
["Other",null,null,"2.\tThe result is increased complexity instead of simplifications\n\nThe sector asked EIOPA for simplifications but instead EIOPA has added new QRTs, has enlarged existing QRTs and has made changes to almost all QRTs. The proposed changes add to the complexity and lead to an excessive cost and burden for insurance companies. \n\nA.\tNeed for more simplifications\nIncreased reporting burden\nEIOPA argues that most of the undertakings would benefit from a reduction in reporting costs for several reasons (simplification of quarterly reporting, elimination of reporting templates and the risk-based thresholds). Overall, however, the many changes proposed by EIOPA would lead to a complication rather than a simplification. The amount of information to be reported and the effort to generate the requested data would increase significantly, together with implementation costs, contrary to EIOPA’s statement, the changes will not reduce the reporting burden for most undertakings and will increase costs for reporting in the end having negative implications for the policyholders, for example, higher premiums.\n\nImpact of thresholds is limited\nWhile the thresholds introduced in several templates are helpful to some extent (e.g., S.04.05), the sector is disappointed that only few thresholds were introduced/lowered and only to a limited extent. In fact, in practice, the thresholds may not result in a real reduction of the burden for (smaller) insurers, because if the insurer would breach the threshold in one period, this would result in a requirement to submit the data. And this implies that the insurer should always have a process in place to collect and submit the requested data. Therefore, the threshold should be valid for a longer period, or a single breach should not directly lead to a requirement to submit.\nIn addition, changing the thresholds in current templates does not necessarily imply a reduction of the reporting burden since the IT- data systems for reporting this information have already been developed. Furthermore, it is noted that EIOPA, in its proposals, no longer refers to the concept of core/non-core templates, which was introduced in the reporting consultation in 2019. \n\nProportionality remains limited\nWhile the sector welcomes the clear reference to the proportionality principle and the introduction of proportionality provisions for captives and specific ‘business models’ it highlights that the remainder of the reporting package is not proportionate at all and the specific proportionality measures and their respective impact are unclear. Further, the sector highlights that the link to the planned proportionality framework (treatment of low-risk undertakings) seems to be missing. There are still too many reporting requirements for smaller, non-complex insurance companies. There is also a disproportionate increased reporting burden with all new templates and the added requirements, including those proposed for undertakings with internal models, which by nature cannot reflect the diversity of internal model structures. \n\nDeletion of unused QRTs\nWhile the deletion of non-necessary/not used QRTs is welcome, the sector expected to see further templates being removed to have an impactful simplification, as most of the templates were not reported by many undertakings. ","public","Assuralia","EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nFollowing the comments received EIOPA has further reviewed the thresholds and introduced some new ones e.g. S.04.05. Also EIOPa proposed an extension of the thresholds period. \nRegarding the concept of core-non core templates please note that all thresholds without thresholds are considered as corewhile the others with as a non-core. \nIn addition the concept of low-risk undertaking is part of the SII Review and is included in the COM proposal on Level 1. Regarding the comments on Internal models please consult the resolutions on the individual comments."]
["Other",null,null,"B.\tLimit the addition of new templates\nHigh implementation costs\nIntroducing new templates, restructuring templates, or making extensive changes to templates by for example adding numerous additional cells, takes a lot of time to change and/or develop and implement, with high costs consequently. In general, companies find the proposed changes, both material and minor changed, very extensive and taken together these constitute a considerable amount of work for companies. As processes are automated, any change made is very costly. Indeed, the simple change of a row and/or column requires IT intervention. The complexity of these projects requires close collaboration between IT professionals, actuaries, and prudential law specialists. In addition, validation checks need to be carried out.\n\nAd hoc requests\nEIOPA, to eliminate/reduce ad hoc requests, has tried to anticipate every single possible ad hoc request that can be made by supervisors, resulting in more and more reporting requirements. Ad hoc requests can never be eliminated: there will always be some situations that cannot be foreseen. Attempts to try and cover every single eventuality, even if little/rarely used, therefore lead to lots of work but very little benefit. \nFlexible ad hoc request can be a very useful supervisory tool. For example, the National Bank of Belgium implemented an ad hoc reporting at the start of the COVID-19 crisis.  The reporting was justified, and the insurance sector agreed with it due to the extreme and turbulent circumstances. The NBB gradually lowered the frequency from weekly to biweekly to monthly with respect to the improving market conditions and the state of the pandemic. EIOPA and the NBB postponed other less urgent reporting to give insurance companies the necessary time to focus on the crisis at hand. As such, the ad hoc reporting proved itself to be a useful tool during extreme times. However, this does not mean that the regular reporting should be adapted to reflect extreme circumstances. On the contrary, reporting should always have clear purpose and should not be too excessive as the overload of data will be too high to serve its purpose, both for the insurance companies and for the supervisors \n\nClimate related reporting\nThe sector acknowledges the need for specific climate related reporting in relation to transition risk and physical risk. However, it highlights that the reporting should not anticipate requirements which are already foreseen under the Taxonomy Regulation and NFRD. Similarly, it should avoid duplication of information as much as possible, so that the burden of reporting is limited and data quality is maintained. Equally important, the sector urges to consider the data availability for the proposals. The sector is of the opinion that insurers only must do sustainability reporting in one reporting format and with the same scope and timing.","public","Assuralia","Noted. EIOPA would like to clarify that in the past EIOPA has regularly doing ITS amendments. The last one was done in 2019. The current proposal reflects the work done in 2019 and 2020 on the extensive review on SII and reflects the feedback received during the Call for input and the public consultations held. \nRegarding the climate relate reporting please consult the final proposal."]
["Reporting","S.14.02","Solo","Non-life business - policy and customer information\nThe template requests several datapoints for products split across 27 categories, which is deemed inappropriate and will be costly to implement. This would introduce a new, third categorisation to Solvency II, on top of the existing two categorisations systems: lines of business and branches. It would be very burdensome to make another product classification, in addition to LOBs, branches and internal classifications that are currently being used.\nThe proposed QRT S.14.02 non-life will require a lot of work and cause significant excess costs for almost no added benefit. There appears to be significant overlap with aspects of data reported on certain other templates, such as S.04, S.05, S.20, S.21.01. Insurance companies have difficulties to understand the purpose of S.14.02 as they report already a lot of information at the LOB level. The level of detail required in the new template implies automation would hardly be possible.\nThe proposed QRT is not needed for prudential reasons and Solvency II reporting should remain limited to prudential reporting only. The insurance sector deems it inappropriate to introduce new QRTs for other purposes than prudential reporting, such as for conduct of business supervision.\nThe proposed template cannot be completed based on accounting data (in contrast to the national reporting in Belgium and some other member states) meaning that it will be labour intensive, and as such very expensive to implement, support and maintain. The template requires detailed inventories by product category and sales channel supplemented with information on certain costs and the year's claims payments. In practice, this means that all insurance products in the insurance company must be reviewed and categorized once again, and this must be continued every year thereafter. The insurance company needs to do the same for each new product. \nFurthermore, it must be decided whether the course of the product is affected by climate related elements. Ultimately, completing and maintaining this template will be a project that requires ongoing maintenance and a close relationship with the product development department. The fact that data comes from many different sources with vastly different levels of detail is adding to the template’s complexity. \nTo monitor climate risk, EIOPA proposes to introduce two new cells:\n\tProportion of premiums covering climate-related perils (0-100)\n\tAllowance for climate-risk prevention measures in product design (Y/N)\nAs a result, the template requires information similar, but not identical to the new requirements under Article 8 of the Taxonomy Regulation to be disclosed via the NFRD, with different timing and scope, causing unnecessary burden. It is also questioned how insurance companies can calculate the proportion and allowance since it is unclear to which extent risks are affected by climate change. Climate change will likely increase the severity and frequency of certain events. As EIOPA rightfully concluded in its methodological paper on potential inclusion of climate change in the Nat Cat standard formula, it is not an easy feat to estimate such an increase, even for highly specialized reinsurance companies and for EIOPA, let alone individual insurance companies. Therefore, from the sector’s point of view and given the similarities of indicators, the framework for the CSRD should be the preferred way to report on this type of information.","public","Assuralia","To reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n\nThe proportion of GWP covering climate related perils is also an input for the corporate reporting by non-life undertakings when reporting the KPI related to underwriting activities on the amount of environmentally  sustainable non-life underwriting, as per Art. 8 of the Taxonomy Regulation TR (see link below). It is proportionate to ask companies to report this also for other purposes, and prudentially relevant, as it can contribute to establishing insurance penetration rates for certain perils.  The information on risk-prevention measures is a type of information which non-life undertakings may report to establish compliance with the taxonomy climate adaptation objective under the Climate Delegated Act technical screening criteria. It is prudentially relevant to ask for this information, as it can help supporting the analysis of the undertaking’s underwriting strategy."]
["Reporting","S.17.02","Solo","While the industry welcomes the decision to keep this template unchanged, it refers to the paragraph with comments on the new templates S.04.03/04/05, thereby noting that the overall reporting burden for cross border requirements will increase substantially. In addition, the extension of the scope of this template to reinsurance makes it more burdensome to report and should not be introduced. \n\nThe industry welcomes the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions.\n\nThe clarification of the definition of threshold regarding the negative technical provisions is welcomed. \n\nIt is highlighted that, for the accepted reinsurance business, the definition of country is not provided. Using the definitions of country for direct business would not be feasible for accepted reinsurance business, as data on the location of the risk is not available.\n\nIt should also be noted that when the original templates were being drafted and exposed for consultation, it was pointed out to EIOPA that there was an inconsistency between S.17.02 and S.12.02 with respect to indirect business. EIOPA did not however amend the template following these comments. Companies therefore now face additional costs for these changes, which could have been avoided if industry comments were taken into account. ","Public","Insurance Europe","Noted on threshold and clarification of the negative technical provisions. On the accepted reinsurance business EIOPA further clarified the definition of country. The proposed extension of the template to reinsurance is in line with the proposal included in the 2020 QRTs report and EIOPA considers informtion important to have."]
["Other",null,null,"C.\tConclusion\nIn sum, insurance companies find the proposed changes very extensive. In addition to the changes outlined above, there are many other changes proposed, which taken together constitute a considerable amount of work for the insurance companies. \nThe proposed changes only increase reporting requirements rather than reducing them as companies have requested. Companies report that the reporting burden and therefore the costs will only increase. Firstly, there is an increase in the costs of implementing the new QRTs. Secondly, there are additional costs to periodically report the additional reports. Thirdly, there are costs for the auditor to verify the extended reporting. Fourthly, there are additional monitoring costs by the supervisor.\nCompanies are disappointed that the reporting is being extended once again, even though questions about the content of the reports are hardly ever asked. It is questioned if the vast amount of data is necessary for supervisory purposes. Insurance companies have been reporting Solvency II templates for more than five years but have received only limited comments or questions on these from the supervisor. A more logical approach would be to first carry out an analysis of the effectiveness of the existing set of QRTs and the extent to which these are effectively used before asking for more data. \n\nEIOPA is requested to:\n\tFirst analyse the effectiveness of the current set of QRTs and the extent to which these are used.\n\tSimplify the current set of QRTs and delete unused QRTs.\n\tAdd only new QRT’s to the extent that these are useful.\n\tThe QRTs should remain limited to prudential reporting and should not be extended for conduct of business purposes.\nIf EIOPA would continue with its proposal, the insurance sector would rather prefer a status quo of the current reporting package and reject all changes.\n","public","Assuralia","EIOPA would like to clarify that the current ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. During these 2 years EIOPA together with the National competent authorities analysed all templates, the supervisory needs the usefulness of the information reported etc. The proposals were publicly consulted in 2019 and the comments received duly analysed. The report on the QRT published in December 2020 at EIOPA web site is the major source of this amendment that is led by the it for purpose principle. "]
["Other",null,null,"It is referred to Insurance Europe's answer for template by template feedback. Assuralia fully agrees with the detailed response of Insurance Europe, to which the Belgian insurance companies also contributed.","public","Assuralia","Noted. Check the resolutions of the Insurance Europe comments."]
["Reporting",null,"Both","ICISA is the Amsterdam-based, global association representing the largest providers of private trade credit insurance and surety internationally. With around EUR 3 trillion in trade receivables insured and billions of Euro worth of construction, services and infrastructure guaranteed annually, our members play a central role in facilitating trade and economic development around the world.\n \nOur members operate worldwide, but given the prominent position of European markets, the majority of our members are located and supervised within the EU. Our membership ranges in size and structure, including both those which are Groups themselves and others which are subsidiaries of Groups. We therefore address our comments more generally on the proposals and the challenges which can be experienced by ICISA members in meeting reporting requirements.\n\nOverall, we support the expressed goal of EIOPA to simplify reporting and to reduce the related costs for undertakings, while also filling gaps identified by national supervisors. Others, including individual members of ICISA may be better placed to comment on the specific proposals made by EIOPA as these may have individual effects, but we wish to address two points which we believe should also be considered as part of this review and the overall approach adopted by EIOPA.\n\nWhile there is clear benefit in simplifying reporting requests, both in terms of timings and the related templates used, the approach taken by individual supervisors across the EU can differ substantially from member state to member state. This can lead to significant differences in experiences of ICISA members from one country to another. For that reason, there may be benefit in further harmonising supervisory approaches to reporting. This is particularly the case for ad hoc requests where there is a noted difference in the frequency and breadth of these depending on the supervisor. While it is of course important that a supervisor in a particular jurisdiction can investigate or seek information relating to their markets, it should also be noted that such requests can pose significant challenges for undertakings both in terms of the resources required to provide responses and whether data or other relevant information is available to answer any particular questions. \n\nDue to very different approaches and attitudes to such requests across the EU, the experience for undertakings can be very different. As such, the approach of supervisors should be predictable and understandable from one juridiction to another, and information requested should require no more than a reasonable effort to produce in formats that are commonly utilised in the sector and with the reasonable use of proxies and assumptions where required.\n\nFrom an ICISA perspective, it is also important that supervisors are aware and understand that while there are key commonalities across the insurance sector, there are also important differences between various lines of business, including for example, between credit insurers and sureties and other lines. For this reason, supervisors should be aware that what may be simple for one type of undertaking may not be straightforward for another. Again, simplification of requests and the utilisation of formats commonly utilised in the sector is essential to support this. Similarly, having a clear dialogue with undertakings and relevant trade associations, such as ICISA, on an ongoing basis (and particularly in advance of ad hoc requests) can also help ensure that requests are better targetted to achieve the results supervisors are aiming for. For example, this may allow for feedback to be given to supervisors about how best to frame requests allowing for more precise data and ultimately a clearer picture for supervisors.","Public","ICISA","Noted. EIOPA is aware that there might be differences in the country ad-hoc reporting and has already taken steps to harmonise the reporting. However, please note that still national request can not be avoided as they relate to specific market situations and supervisory needs."]
["Sustainable finance questions",null,"Both","Would EIOPA be able to use the NACE code to categorise those investments exposed to the different risks (physical risk, climate change related transition risk, etc.)","Public","Partnerre","Noted. The NACE codes can indeed also be used by EIOPA for top-down or bottom up analysis on expsosures of investments to certain sectors."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?","Both","ShareAction welcomes and supports this reporting requirement on sustainable investments and welcomes the broadening of the scope to all undertakings subject to Solvency II reporting requirements. Such a wider scope will allow supervisors, including national competent authorities, to receive all the data necessary to get a more accurate picture of the insurance industry and its alignment with or transition to sustainability objectives. \n\nSecond, the alignment of Solvency II reporting requirements with the methodology and KPIs set out in Art. 8 Taxonomy Regulation Delegated Act will ensure prompt regulatory coherence across various pieces of EU legislation, thereby also avoiding legal uncertainty and regulatory burden for insurers.  \n\nAs EIOPA rightly mentions, given that the Corporate Sustainability Reporting Directive (CSRD) (currently under negotiation) is expected to enlarge the scope of undertakings covered by Article 8 of the Taxonomy Regulation, all large undertakings, and all undertakings listed on EU regulated markets (except listed micro-enterprises) will in any case be required to disclose these KPIs as part of the mandatory reporting requirements set out by the Taxonomy Regulation and its Delegated Act. Therefore, using these KPIs for prudential purposes will ensure consistency, with no additional burdens for the industry, which is already preparing for the enlarged scope provided for by CSRD. \n\nHowever, ShareAction believes that this reporting requirement should be not subject to a materiality assessment, as introducing a materiality threshold will lower the quality of disclosure as whole and deprive supervisors and other users of key information. \n\nShould it be deemed necessary to mitigate the broadening of the scope to all undertakings under Solvency II by introducing a materiality threshold for undertakings not subject to the NFRD, ShareAction recommends, at the very least, that such threshold should be set in the most cautious way, and as closely aligned with CSRD as possible. The threshold should be set so that it does not significantly limit the broadening of the scope, as this would defeat the point of proposed amendment (i.e., the threshold should be set in such a way that a significant majority of undertakings not considered ‘large undertakings’, not-listed on EU regulated markets and/or classified as micro-enterprises would be considered within scope).  ","Public","Share Action","Noted. EIOPA tends also to be of the view that tresholds for the proposed KPIs may be of limited supervisory value. \nEIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting. The reporting shall focus on the reporting of the transition and physical risk metrics, supported by standardised reporting of geo-location of physical assets and more detailed NACE reporting."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ","Both","ShareAction supports EIOPA in the widening of the detailed NACE codes to be reported. This will ensure alignment with the EU Taxonomy and hence regulatory coherence and legal certainty.  \n\nShareAction also welcomes the reporting requirement related investments exposed to climate change-related transition risk. As noted by EIOPA, the insurance sector is exposed to climate change-related transition risks as regulations, policies, market actors’ and customers’ expectations and behaviours change in line with the increasingly urgent need to combat climate change and seek alignment with the objectives of the Paris Agreement, the European Green Deal and the renewed Sustainable Finance Strategy. It is thus very important that supervisors receive information allowing them to assess the extent to which insurers, and the insurance sector as a whole, are exposed to transition risks and what measures could be taken to mitigate such risks. \n\nGiven that the materialisation of transition risks to investments could be detrimental to policyholders, it is also important, from the perspective of policyholder protection, to allow insurers and supervisors to identify those risks early and mitigate them. \n\nHowever, we do not agree with EIOPA’s proposal on the reporting of the share of investments exposed to climate change-related transition risk, and do not believe that a materiality threshold is appropriate here, because of the systemic nature of climate-related risks, which will always be material given that all companies need to transition to net-zero emissions by 2050, in line with the EU’s emissions reduction target set in the European Green Deal. So instead, we encourage EIOPA to require asset-by-asset reporting on physical risk, without any materiality threshold introduced. ","Public","Share Action","Noted. On the transition risk metric, EIOPA is not proposing the application of a materiality threshold. EIOPA is not proposing asset-by-asset reporting at this stage, for proportionality reasons."]
["Sustainable finance questions","3. What could be a methodology for standardised reporting of climate change-related physical risk exposure for other investments than property?","Both","We do not have a methodology to propose but ShareAction welcomes EIOPA’s proposal to standardise the reporting on the physical location of properties and agrees with the proposed standardisation. We also support EIOPA’s suggestion that it will seek to go further than the standard reporting of the geolocation and will look into the inclusion of further parameters in the methodology for standardised reporting, such as building standard, construction date, location of manufacturing or storage, etc.  \n\nShareAction believes that all types of insurers’ investments should be covered, not just property investments. ","Public","Share Action","Noted. We would welcome further views from stakeholders on methodologies for assessing physical risk to other types of investments than property investments."]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?","Both","ShareAction welcomes the reporting requirement on investments exposed to climate change-related physical risk. This KPI will allow supervisors, including national competent authorities, to assess insurers’ exposure to physical risk, which is a key component of insurers’ exposure to climate-related risks more broadly, and can have consequences for financial stability. \n\nGiven that the materialisation of climate change-related physical risk to investments could be detrimental to policyholders, it is also important, from the perspective of policyholder protection, to allow insurers and supervisors to identify those risks early and to mitigate them. \n\nHowever, we do not agree with EIOPA’s proposal on the reporting of the share of investments exposed to climate change-related physical risk, and do not believe that a materiality threshold is appropriate here, because of the systemic nature of climate-related risks, which will be always material in certain geographical zones. So instead, we encourage EIOPA to require asset-by-asset reporting on physical risk, without any materiality threshold. ","Public","Share Action","Noted. On the transition risk metric, EIOPA is not proposing the application of a materialith threshold. EIOPA is not proposing asset-by-asset reporting at this stage, for proportionality reasons."]
["Other",null,"Both","We encourage EIOPA to further align with the TCFD guidelines, in order for the EU to remain at the forefront of global efforts to tackle climate change and to transition to a low-carbon economy. In particular, we encourage EIOPA to introduce the following reporting requirements, listed as part of the TCFD cross-industry, climate-related metrics: Disclosure of GHG emissions across the value chain of the organization (including the emissions of investee companies); Proportion of executive management remuneration linked to climate considerations.  ","Public","Share Action","Noted. Carbon intensity of an investment portfolio is indeed a key and relevant input for assessing transition risk,  and at the basis of a number of the methodologies which we refer to in our application guidance. With regard to remuneration, this is part of the proposal made by EIOPA for sustainability disclosure requirements, as part of the Solvency II 2020 review, pending further consideration by the Comission :  https://www.eiopa.europa.eu/document-library/opinion/opinion-2020-review-of-solvency-ii_en "]
["Other",null,"Both","We encourage EIOPA to also require the disclosure of the extent to which insurers’ investment and insurance underwriting activities are aligned with a well-below 2°C scenario, and the disclosure of transition plans specifically aligned with the goals of the Paris Agreement (i.e. with limiting warming to 1.5°C above pre-industrial levels) and the EU’s own emissions reduction commitments. Such transition plans should indicate who the individuals responsible for implementing the transition strategy are and should include a remuneration policy incentivising senior managers to implement the transition strategy.  ","Public","Share Action","Noted. We note the intention for requiring disclosure of transition plans under the CSRD proposal."]
["Other",null,"Both","In addition to its current work on asset-side reporting requirements, we support EIOPA’s intention to develop reporting requirements on liabilities.   ","Public","Share Action","Noted."]
["Other",null,"Both","EIOPA proposes a large number of changes in both existing and new QRTs. Changes of such magnitude imply large costs and efforts for undertakings and can hardly be implemented starting from Q4 2022. For this reason we would like to suggest EIOPA to:\n- better assess the proposed changes limiting them to the ones deemed as unaivodable for prudential purpouses.\n- postpone at least by two years (i.e. starting form Q4 2024 reporting) the deadline for the implementation by undertaking.","Public","Unipol Group"," The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \n"]
["Impact assessment",null,"Both","Eiopa assessed the one-off and ongoing variation in costs that the undertakings would face as percentage calculated on total assets. Based on such criteria the impacts result in very low figures (the highest amounting to 0.0017% which is perceived as to be very low). Taking also in account the actual interest rate scenario, we suggest EIOPA to use a more appropriate benchmark, which should be based on an average pre-tax profit (i.e. 3-5 years average).","Public","Unipol Group","Please note that the impact assmessment figures are based on a survey to insurance and reinsurance undertakings and a survey to groups about the expected costs and benefits of the proposals in the Consultation Paper of the Opinion on the 2020 review of Solvency II. The survey for insurance and reinsurance undertakings was responded by 357 individual undertakings from 29 EEA Member States  with an EEA market of 32% in terms of total assets and 42% in terms of technical provisions. \n"]
["Reporting","S.03.01","Group","We propose to exclude from the calculation of the threshold undertakings consolidated in accordance with Article 335, paragraph 1, (d), (e) and (f) of Delegated Regulation (EU) 2015/35. Indeed, we believe that the formula would be inconsistent for these undertakings, since the denominator would not represent the proportional share of total asset but the proportional share of the excess of asset over liabilities. \n","Public","Unipol Group","Agree. Amended"]
["Reporting","S.04.04","Solo","In order to allow us to have a better understanding on the QRT,  we would like to ask EIOPA some clarifications on the  meaning of location of underwriting. For instance, in case an Italian insurance company (underwriting entity) underwrites an insurance policy through an agency located in San Marino and the underwriter of the policy is an Austrian company needing insurance on an asset in Austria, we would like to ask EIOPA which would be the location of underwriting (Italy, San Marino or Austria). ","Public","Unipol Group","The location of underwriting refer to the country in which the entity (head office or branch) who is originating the business is based.  Template S.04.04.01.02 captures, for business written under freedom to provide services (FPS), the country into which the underwriting entity has written business on a FPS basis.\nIn the example provided, the location of underwriting would be Italy (to be reported as country of establishment in S.04.03.01).  As the ultimate insured is in Austria, this is FPS business into Austria and so would be reported in S.04.04.01.02 as FPS business into Austria.\n"]
["Reporting","S.04.05","Solo","We ask to reintroduce a threshold similar to the one used in S.04.01 on Material non-EEA countries of at least 5% on the total gross written premiums. This would be important in order to avoid reporting insignificant activities for minor countries not material to the underwriting entity business.","Public","Unipol Group","Supervisory experience since the introduction of Solvnecy II has shown that the existing templates do not provide sufficient information on location of risk to enable effective cross-border supervision.  Therefore, we do not consider retention of the existing templates as a viable option.\n\nThe observations on proportionality are noted.  It is not possible to introduce a threshold for template S.04.04 on location of underwriting (where information is required for cross-border statistical exchanges), but a threshold (e.g. 5% of GWP by LoB) could be considered for location of risk reporting in S.04.05."]
["Reporting","S.05.02","Group","Eiopa should avoid the introduction of different QRTs at solo and group Level. Submitting QRT S.05.02 at group level would also mean doing it at solo level. Therefore we propose to replace the QRT S.05.02.01 with QRT S.04.05.21 already proposed as QRT of Disclosure at solo level.","Public","Unipol Group","This proposal was considered but the preference is to keep the current S.05.02 at group level, aknowledging that it will be mainly based on consolidated accounts."]
["Reporting","S.06.02","Both","C0230 - Issuer Sector:  We would like to underline that currently, primary info providers do not guarantee 4-digit NACE for NACE <> Financial and Insurance. Therefore, we would like to ask EIOPA not to change the specification","Public","Unipol Group","The proposed change, i.e. the letter identifying the Section followed by the 4 digits code is required only for sections A to N and it is important for the identification of the transition risk. "]
["Reporting","S.06.03","Both","C0040 - Country of issue: We would like to underline that the modification seems inconsistent with the recent indication of Q&A 2319 in which, in addition to excluding CIC 8 and 9, CIC = 7 would also be excluded (see BV1136 - taxonomy 2.6).","Public","Unipol Group","Agree. Instructions have been amended."]
["Reporting","S.08.01","Both","C0371 - Currency of price: We would like to underline that the market price is not a field reported in the template and it is already available the filed CURRENCY (C0370). Therefore, we would like EIOPA to explain the benefits of the introduction of this new field. ","Public","Unipol Group","It is the currency of the amount being exchanged. For example, if the undertaking is paying (or receiving) GBP for the notional amount (whatever it is – USD, EUR, …), the currency if the price is GBP. The currency of the notional amount (C0370) is, in the example, USD. With this information the supervisor is able to better understand the currencies of the amounts being exchanged under the derivative"]
["Reporting","S.14.01","Solo","We believe that the QRT is already very burdensome to be completed. Therefore, the additional details required by EIOPA (commissions and expences, number of insured persons and contracts surrended) and the details required in some information (distinction between new contracts and contracts in force or type of underwriter),  would increase the complexity and would require further effort for the undertakings. Indeed, this new information would be excessively burdensome to collect from various owners and would require a lot of effort to be analysed and combined. For this reason, we would like to invite EIOPA not to amend this template.","Public","Unipol Group","Information on the amount of  premiums written by distribution channels is essential to allow for an assessment of relevance of sales channels. Currently availble soruce of information on distribution channels are limited. The added information allows to determin the business models used to commercialise certain products and possible concentration risks. EIOPA notes that the new information required may be a burden. However this information is deemed necessary to assess concentration risks and determine the changing distribution patterns - i.e., more reliance on own channels. Moreover, information on written premium by distribuition channels should be already available to insurance undertakings as they should know the channels through which they are writing premium/selling certain products to monitor risks arising from distribution. This information for several Member States and in a more granular manner (i.e., more granulirity in terms of distribution channels) is published annually by InsuranceEurope itself showing that for several markets this information is available. Aware of the possible burden to undertakings, to strike a balance between supervisory needs and and limiting the reporting burden EIOPA has reduced the number of new cells by reducing the granularity required on premiums written by distribution channel, no longer requiring a split between regular and single premiums.  \n\nCommissions represent a key information on products being extensively used for understanding insurance undertakings' business model and sales strategy, including to identify whether the possible higher commissions could raise solvency issues and/or increase mis-selling which in turn could lead to solvency risks. This includes information on expected future commissions to allow an assessment of the commissions paid during the whole life-time of the contract. EIOPA also notes the burden to the industry but also notes that the information on commissions paid during the year should be already available as it should be calcualted for both pricing purpose and when commissions are paid to intermediaries. The information on expected future commissions is part of the calculation of the best estimate liabilities, approximations can be used to determine the necessary information. To strike the balance between supervisory needs and possible burden to the industry EIOPA dropped the breakdown between commissions for new contracts for single and regular premium products and no longer requires the information on expected future commissions for new contracts.\n\nFinally information in relation to number of insured is important to understand possible exposures and have a better overview over liabilities as under one contract there could be multiple consumers this information is needed to determine whether the insurers could be expected to pay out the full amount under one contract or less. "]
["Reporting","S.14.02","Solo","C0010 - This QRT requires a level of granularity that is different form the LoB and potentially different from IFRS17 and Local Gaap. In this regard, we would like to stress out that managing these different levels of granularities would be costly and difficoult to implement. Furthermore, the split of multi-line products in product categories and the management of the related add-ons is very complicated and burdensome. ","Public","Unipol Group","We are aware of the complexity. The report aims at striking a balance between the currently absence of non life product information and the extreme granularity of product reporting.\n\nTo reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n"]
["Reporting","S.14.02","Solo","C0050 - We would like to ask EIOPA to provide an explanation about the meaning of new contract. In particular, we would like to know whether a renewal and a substitution can be considered a new contract. ","Public","Unipol Group","New contracts refers to contracts which are subscribed for the first stime. Some further indication are provided in the instructions"]
["Reporting","S.14.03","Solo","The report appears to be aimed at gathering information on affirmative cyber risk. However, the instrunctions do not specify that. Is the interpretation correct? If this is not che case, we invite EIOPA to consider that collecting all the required information for the non-affirmative cyber risk - if possible - would be challenging and that a reporting on an aggregate basis would be more appropriate and in line with the principle of proportionality.","Public","Unipol Group","Disagree. The template is aimed at collecting information on affirmative cyber as the information asked is clearly linked to affirmative cyber exposures (premiums, claims, etc.). There are however fields, such as the distinction between standalone cyber and cyber as add on, that can serve as a proxy to identify possible non-affirmative cyber exposures. Furthermore, information requested in the template is already to be provided on aggregate basis whenever products sold can be considered as similar (following the ITS instructions)"]
["Reporting","S.14.03","Solo","This QRT requires marking Company's portfolio at a deep level. We must represent the Cyber product standalone and also every Cyber guarantee included in other products. Moreover, we must assigne LoBs and Description of Risks to every single granularity and then analyze the intersection between the pre-mentioned features.","Public","Unipol Group","Disagree. EIOPA believes it is time to focus for undertakings on identifying the key elements of cyber products as included in the proposed template. EIOPA strongly believes that this level of granularity shoud not only be provided from a reporting point of view, but also from the risk management point of view."]
["Reporting","S.14.03","Solo","C0140 - We would like EIOPA to clarify whether this QRT requires to allocate the best estimate and the risk margin for each combination of product category, LoBs and Description of Risks","Public","Unipol Group","Noted. Instructions will embed information on this"]
["Reporting","S.23.02","Group","We welcome the deletion of the information related to  \"Excess of assets over liabilities - attribution of valuation differences\" at solo level, however, we do not see the usefullness at group level. In addition, we would like to underline that all information requested in the section can be derived from QRT S.02 and from the financial statements. ","Public","Unipol Group","EIOPA prefers to keep the  table on \"Excess of assets over liabilities - attribution of valuation differences\" at  group level, considering that the Variation Analysis templates don't apply at group level"]
["Reporting","S.23.03","Both","We welcome the introduction of the threshold, however we would like to ask EIOPA to clarify the formula. ","Public","Unipol Group","The methodology of the threshold has been changed cmpared to the one publicly consulted where EIOPA received comments that the threshold will be difficult to be calculated. EIOPA disagree to increase the threshold to 10% considering also the outcome of the impact assessment."]
["Reporting","S.23.04","Solo","We welcome the introduction of the threshold, however we would like to ask EIOPA to clarify the formula. ","Public","Unipol Group","The methodology of the threshold has been changed cmpared to the one publicly consulted where EIOPA received comments that the threshold will be difficult to be calculated. EIOPA disagree to increase the threshold to 10% considering also the outcome of the impact assessment."]
["Reporting","S.23.04","Group","We welcome the introduction of the threshold, however we would like to ask EIOPA to clarify the formula. \nWith regard to QRT S.23.04, can you confirm that cells from C0760 to C0841 refer to the total amount of Non available OF and they don't refer to the part that should be deducted?\nLet's imagine a Group with 1 billion of non available subordinated liabilities of which 100 mln actually deducted from the Group's own funds as it exceeds the contribute of solo SCR to Group SCR. Can you confirm we should fill cell C0930 with the value of 1 billion?","Public","Unipol Group","Eiopa confirms that the cells from C0760 to C0841 of template S.23.04 refer to the total amount of Non available OF and not to the part to be deducted."]
["Reporting","S.18.01","Solo","The proposed change to add ‘total recoverable from reinsurance’ for some LoBs will be burdensome to implement. \n\nWhile the industry takes note of the inclusion of a threshold representing a coverage of 90% of the non-life technical provisions, it believes a threshold of 80% would be appropriate, with the proposed 90% threshold, smaller LoBs would have to be included. In addition, while the proposed materiality threshold reflects a proportionality approach, it introduces an additional step of applying a materiality selection, hence it works against the objective of reducing reporting costs.","Public","Insurance Europe","EIOPA understands that in some cases the allocations of the cash flows from reinsurance contracts may require expert judgement but EIOPA expects undertakings to perform this calculations following the same criteria as for the recoverables in the S.17.01. \nOn the threshold EIOPA disagrees of changing it to 80% and keeps it to 90%. "]
["Reporting","S.26.09","Both","In our understanding, for those undertakings whose internal models calculates counterparty risk for non financial instruments separately from calculation of market and credit risk, these templates must not be filled in with the related counterparty risk exposures.\nFor avoidance of doubt, it should be worthy to specify in the ITS that in all cases where a modular approach has not been implemented, information related to non-financial instruments must not be fed in.\nFurthermore we would like to point out that Template S.26.09.01 with this level of detail requires a considerable effort in terms of implementation.\nIt should be usefull to clarify the meaning of mVaR percentile; from our understanding it referes to Modelled Value-at-Risk (mVaR):\" Aim of this information is to obtain a ‘VaR for the value/price of each single instrument and benchmark portfolio’ (not a profit or loss). [Definition taken from Market & credit risk modelling comparative study (‘MCRCS’), year-end 2020 edition - Instructions to participating undertakings for filling out the data request]\".\nQRT is based on granular and specific information (i.e. credit risk information and mVaR without transitional on TP) which value depends on model assumptions and hyphothesis. Interpretation of these values could be wrong without a detailed description of model used and list of hypothesis assumed. Our suggestion is to reduce information required.\nIt's not clear if columns F and G of Market & credit risk and sensitivities - Sensitivities (values) section should include Pension Funds. It should be worthy to clarify in the ITS.","Public","Unipol Group","S.26.09 is the QRT for Market & Credit risk. I don't understand the referernce to Counterparty risk exposures. There is a question (C0010/R0040) to indicate whether non financial instruments are covered.\n\nThe granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups.\n\nmVaR is the same measure as in the MCRCS but it is also described in the LOG file.\n\nIf Pension Funds are part of the internal model and not categorised as Unit-linked then they should be included."]
["Reporting","S.26.10","Both","The internal model, approved by the NSA, is group/undertaking specific, therefore highly individual and customized to the specific business and risk structure of the group/undertaking. A pre-defined QRT could not be representative of the specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. \nIn our understanding, for those undertakings whose internal models calculates counterparty risk for non financial instruments separately from calculation of market and credit risk, these templates must not be filled in with the related financial instrument exposures.\nThe Company would like the QRT ITS to specify that in all cases where a modular approach has not been implemented all informations about financial instruments must not be fed in.\n","Public","Unipol Group","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nClarification is required regarding the comment: \"for those undertakings whose internal models calculates counterparty risk for non financial instruments separately from calculation of market and credit risk, these templates must not be filled in with the related financial instrument exposures\". There is a separate template for non-financial instruments (S.26.12)."]
["Reporting","S.26.11","Both","The same considerations of QRT S.26.10 are applicable.","Public","Unipol Group","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.12","Group","It should be worthy to clarify how the information required in rows from R200 to R220 must be filled in: with reference to row R200 \"Total undiversified counterparty default risk\" we ask wheter the company must fill in the cell as the sum of Type 1 and Type 2 mVaR or other type of calculation is required.\nThe internal model, approved by the NSA, is group/undertaking specific, therefore bespoken to specific business and risk profile of the group/undertakings. A standardized template could not be representative of the specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. ","Public","Unipol Group","Sum of Type 1 and Type 2 mVaR is expected.\n\nThe granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.12","Group","It should be worthy to clarify how the information required in rows from R200 to R220 must be filled in: with reference to row R200 \"Total undiversified counterparty default risk\" we ask wheter the company must fill in the cell as the sum of Type 1 and Type 2 mVaR or other type of calculation is required.\nThe internal model, approved by the NSA, is group/undertaking specific, therefore bespoken to specific business and risk profile of the group/undertakings. A standardized template could not be representative of the specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. ","Public","Unipol Group","Sum of Type 1 and Type 2 mVaR is expected.\n\nThe granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.13","Both","Table S.26.13.01.02. The undertaking is asked to map the internal lines of business to the Solvency II lines of business with no distinction between risk sub-modules. We would like to ask EIOPA to clarify the approach to be taken in case the internal model provides for different level of granularity among the sub-models (e.g. direct claims settlement in motor vehicle liability could require a granularity level on the reserve risk side that is not relevant nor appropriate for premium risk).  In particular, we would like to know whether the company should fill-in the template using the minimum common level of granularity between premium and reserve risks.","Public","Unipol Group","S.26.13.01.02 - Two extra columns have been added to resolve this issue."]
["Reporting","S.26.13","Both","Tables S.26.13.01.03-07. According to the 2009/138/EC Directive premium and reserve risk can be calculated within the same sub-module. Moreover, no paticular method is prescribed for the elicitation of the probability distribution function. Thus, an internal model shall not necessarely produce the probability distribution at the required granularity level. This is relevant, in particular, for partial internal models.\nThe internal model, approved by the NSA, is group/undertaking specific, therefore highly individual and customized to the specific business and risk structure of the group/undertaking. A pre-defined QRT could not be representative of the specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. ","Public","Unipol Group","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.13","Both","Table S.26.13.01.13. According to the relevant regulations no particular method is prescribed for the elicitation of the probability distribution function. Thus, an internal model shall not necessarely produce the probability distribution function with the required granularity in terms of aggregates or metrics.\nThe internal model, approved by the NSA, is group/undertaking specific, therefore highly individual and customized to the specific business and risk structure of the group/undertaking. A pre-defined QRT could not be representative of the specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. \nWe would like to ask EIOPA to clarify the definition of C230: \"Annual Loss\" and what are differences with respect to the AEP Loss.\n","Public","Unipol Group","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nThe Aggregate Exceedance Probability (AEP) is the probability that the associated loss level will be exceeded by the aggregated losses in any given year and is used when the insurance program is written on an aggregate basis.\n\n“Annual loss” is the loss determined according to the statistical measure, i.e. mean, standard deviation or percentile.\n"]
["Reporting","S.26.14","Both","To fill the template an implementation effort and some approximations are required. In our opinion, the split of the mortality and longevity SCR into trend, level, volatility and catastrophe components, probably is related to a specific model implementation and it requires an important effort for implementation.\nIn relation to the partition of lapse risk into increase, decrease and mass is not clear because the 99.5 scenario of the PDF is one and correspond with a single stress of lapse rates. Therefore, our interpretation is that it should be filled only the information corresponding to the applicable stress of lapse rates relevant for the calculation of lapse SCR. It should be worthy to clarify in the ITS.  \nMorever the split of lapse risk in partial and full surrender requires an important implementation effort, we suggest to simplify and cancel this requirement from the template.\nWe would like to highlight that internal model approved by the NSA, is group/undertaking specific, therefore highly individual and bespoked to the specific business and risk profile of the group/undertaking. A standardized template could not be representative of the entity specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. ","Public","Unipol Group","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.16","Both","On a quarterly basis the companies with approved internal model already submit to the National Authority a model change report, and the report is bespoken on the basis of rules defined in the Group model change policy. A new standardized report on model changes would introduce further operational burden and could not represent the approach defined by companies in the model change policy.\nIn this regards, with reference to minor model changes,  insurance/reinsurance companies could adopt them in different reporting period of the year and therefore perform impact analysis on different dates. Therefore it should be worthy to specify in the ITS that cell C240 and C250 of S.26.16.01.03 could be filled with the sum of SCR impacts calculated on relevant dates for approval. \nIn relation to the Own Funds impact amount to be reported for minor model changes, it seems from specification that it would be necessary to recalculate all the minor model changes at the reporting date. If the interpretation is correct, it should be noted that the operational burden of this activity is relevant, therefore we suggest to use for Own Funds impact the same approach proposed for SCR (sum of minor model changes impact).","Public","Unipol Group","Regarding the MCP template the intention is to have a common template on a European level with some basic information regarding model changes where supervisors can quickly check the impact of a specific change or a set of changes. The common template will also assist in colleges. EIOPA acknowledges that specific governance frameworks deviate from each other and that's the reason that it requests each undertaking to report major and minor changes according to its own model change policy (MCP). The template will be reported annually and the LOG file states that fields corresponding to minor changes should provide information based on the reporting period.\n\nSCR impacts should not be recalculated based on the reference date but accumulated when the changes where approved. Same for OF. LOG file has been amended."]
["Reporting","S.30.01","Solo","Cell C0030 \"Risk identification Code\" and C0200 \"Risk identification Code\": If this template has to report the 20 largest facultative reinsurance exposures in the next reporting year, we suggest to amend the instructions of these cells, which refer to \"the 10 most important risks in terms of exposure for each line of business\".","Public","Unipol Group","Agree. Amended."]
["Reporting","S.31.01","Solo","Cell C0045: We kindly ask to describe in details the meaning of \"the operation of the facultative reinsurance item\", supported by an example. Furthermore, we suggest to clarify the difference between cell C0045 \"Description of operation of the facultative reinsurance item\", and cell C0080 \"Description risk\" and cell C0090 \"Description risk category covered\", supported by an example. Lastly, we would like to stress out that the introduction of a further description could be an additional burden for the undertakings.","Public","Unipol Group","This cell has been deleted."]
["Reporting","S.30.01","Solo","Cell C0045: We kindly ask to describe in details the meaning of \"the operation of the facultative reinsurance item\", supported by an example. Furthermore, we suggest to clarify the difference between cell C0045 \"Description of operation of the facultative reinsurance item\", and cell C0080 \"Description risk\" and cell C0090 \"Description risk category covered\", supported by an example. Lastly, we would like to stress out that the introduction of a further description could be an additional burden for the undertakings.","Public","Unipol Group","This cell has been deleted."]
["Reporting","S.30.02","Solo","We kindly ask to better clarify whether, in case we have a Reinsurer with a direct participation and the same Reinsurer has another participation through an underwriting agency and/or a broker on the same \"Facultative reinsurance placement identification code\" (S.30.02 cell C0040), it is correct to add the participation's shares and to report the Reinsurer directly only once.","Public","Unipol Group","This is correct. The split by borker is no longer requested as C0070 has been deleted."]
["Reporting","S.30.03","Solo","Cell C0430 \"Order of claims within the reinsurance program\": We kindly ask to describe clearly the meaning of \"the order of claims\", with some examples.","Public","Unipol Group","This cell has been deleted."]
["Reporting","S.30.03","Solo","Cell C0070 \"Line of business\": In respect of LoB 37 — Multiline, the log description reports at point 2): \"Where the term of the cover do not differ by line of business only the dominant (based on the Gross Estimated Treaty Premium Income) Solvency II line of usiness is required\". In case of a Treaty which covers different lines of business, both reinsurance and retrocession, and the conditions are the same for all the lines of business, we would like to ask whether it is correct to report only the dominant line of business, which is almost always the reinsurance Lob. Furthermore, we would like to ask whether, in the case reported above, the Gross Estimated Treaty Premium Income is referred to the total premium of the Treaty, or only to the dominant line of business.","Public","Unipol Group","Yes, in this case only the dominant LOB is to be identified. However, the gross estimated treaty premiums should inclde the premiums of all LOBs."]
["Reporting","S.36.00","Both","We believe that the introduction of this additional QRTs does not produce any benefits.\nIndeed, QRT S.36.00 seems to merely summarize the requests already contained in the qrts S.36,01-05. As preparing such qrts would entail a significant effort, we propose not to require undertakings to provide QRT S.36.00.","Public","Unipol Group","Please note that S.36.00 has been removed from the package."]
["Reporting","S.36.01","Both","We wonder wether, in order to identify indirect transactions, reference can be made to the definition of “single economic operation”, namely those transactions “which, from an economic perspective, contribute contribute to the same risk, or serve the same purpose/objective or are temporally connected in a plan”. \nAccording to this interpretation, a chain of related intragroup transactions would only be reported as an indirect transaction when the final and intermediary steps are all connected each other and such relationship is disclosed since the origination of the first transaction of the chain.\n","Public","Unipol Group","For the purpose of reporting the two fields of  indirect transactions and single economic operations are to be filled in as mutually exclusive.\nAbout the definitions, indirect transactions are normally identified as a chain of transactions shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or entities outside of the group but ultimately risk exposure is brought back or stays within the group and impacts the solvency position of any insurance undertaking of the group.(description in the log to be amended if definition confirmed). While, where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation. "]
["Reporting","S.36.04","Both","We would like to ask EIOPA whether the Column C0170 refers to the premiums ceded to the treaty for the QRT reference year or to the gross premium to be applied to the treaty for the QRT reference year.","Public","Unipol Group","The cell C0170 is applicable only for direct insurance"]
["Reporting","S.36.04","Both","We would like to ask EIOPA whether it is correct that the fields C0140 Total reinsurance recoverables, C0150 Reinsurance result (for reinsured entity) and C0160 Line of business previously reported on the former Qrt 36.03 won't be reported on the new format of QRT 36.04; in this case, we would like EIOPA to explain the reasons of this choice.","Public","Unipol Group","EIOPA agrees that the information on  Total reinsurance recoverables, Reinsurance result (for reinsured entity) and Line of business previously reported on the former Qrt 36.03  should not be lost in the new format of QRT 36.04 and the corresponding columns have been added consistently. On the other hand, insurance and reinsuance transactions are removed from the scope of S.36.05."]
["Reporting","S.36.05","Both","We believe that the introduction of this additional QRTs does not produce any benefits. \nIndeed, QRT S.36.05 seems to mostly summarize information already reported in QRT S.36.01-03. As preparing such qrts would entail a significant effort, we propose not to require undertakings to provide QRT S.36.05 and to include any additional information requested in QRT S.36.05 in other QRT S.36.","Public","Unipol Group","EIOPA confirms that although interest, dividends are reported in S.36.01, S.36.02 they must be reported additionally in S.36.05 P&L. The double reporting is expected to be of limited burden. While with regard to premiums, thery should be reported only in S.36.04; insurance and reinsurance are now excluded from the scope of S.36.05."]
["Reporting","S.37.01","Group","We note that the amendement report proposed by EIOPA differs from the current one in that it no longer requires the identification code of the exposures (type of instrument). \nAccording to the in force version of the Commission Implementing Regulation (EU) 2015/2450, the risk concentrations related to Off–balance–sheet contingent liabilitys can be classified filling the S.37.01.04 template with a code equal to 10 in item C0050. Undertakings can assign a tailor-made code to the exposure in item C0060 specifying its nature using a code equal to 99 in item C0070. Understakings report the value of the exposure, according to the granularity required, within item C00150. It is not clear, within the new layout of the S.37.01 template defined by the amendements, if and how the Off–balance–sheet contingent liabilitys should be reported, which codes should be used to describe their nature and in which items to report them. In this regard, we would like to ask EIOPA to provide an example of reclassification of the reporting of Off–balance–sheet contingent liabilitys between the old and the new track record .","Public","Unipol Group","The column Others (C0200) can be used with additional explanations in C0210.\n"]
["Financial stability guidelines",null,"Group","We strongly disagree with the additional request stated in QRT S.39.01 R0020 R0030 R0040 R0050 as we believe that the cost required for the preparation of the data, even in a \"best effort\" way, would greatly exceed the benefits at prudential level.\nConsolidated financial statements are prepared based on IAS/IFRS accounting standards and income statements is drawn up based on criteria that are very different to presentation and recognition/valuation principles stated in Directive 91/674/EC. Furthermore, also the principles stated at national level for drawing up statutory individual financial statements for insurance companies, even if similar, are not the same stated in such directive. Requiring the information at consolidated level, based on principles stated Directive 91/674/EEC would consequently entail the need to prepare an additional consolidated income statements. The amount of work needed would be huge both for each insurance group (system upgrade, consolidation process, instructions to subsidiaries) and at EIOPA / NCA level due to the need to issue a comprhensive guidance to reconcile the rules for preparing individual and consolidated financial statements to the requirement stated in Directive 91/674/EC.\nWe also highlight that the information concerning financial performance are already available based on local requirement and NCA and Eiopa could easily access such information.","Public","Unipol Group","EIOPA acknowledges that some Member States require the use of IFRS for all or a certain set of insurance and reinsurance undertakings. IFRS 4 Insurance Contracts, which remains applicable until the endorsement of IFRS 17 in the EU, allows for grandfathering national practices and with regard to performance reporting can be reconciled to income statements that are based on Directive 91/674/EEC. Therefore, the request for basic information referring to the operating results are not expected to lead to additional efforts or significant costs."]
["Financial stability guidelines",null,"Both","Template S.14.04.11 Liquidity risk for life business:\n1. We would like to underline that the level of detail by product is highly costly and bundersome, and would require a lot of effort to be produced. Therefore we suggest to reduce the level of details and to produce the template on annual basis.\n2. Furthermore with reference to Items C0070 and C0290 we would like to underline that the information required is available only on an accrual basis. Therefore we suggest to produce the information related to these items on accrual basis.","Public","Unipol Group","In order to reduce the burden for insurance undertakings, EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). \n\nThe reporting of these items on an accrual basis will not facilitate the adequate supervision of liquidity risk. Moreover, the change in granularity should assist in the availability of this information. "]
["Financial stability guidelines",null,"Group","S.14.05 - This QRT requires a level of granularity that is different form the LoB and potentially different from IFRS17 and Local Gaap. In this regard, we would like to stress out that managing these different levels of granularities would be costly and difficoult to implement. Furthermore, the split of multi-line products in product categories and the management of the related add-ons is very complicated and burdensome.","Public","Unipol Group","EIOPA proposes the following changes in the reduction in granularity of the liquidity information: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). The change in granularity should assist in the availability of this information. "]
["Financial stability guidelines",null,"Group","S.14.05 - C0180 C0300 - BE are calculated at a higher level of granularity (LoB), these amounts have to be allocated at the products categories. We would like to ask EIOPA whether undertakings may adopt different criteria of allocation with a potential distortion at a market level.","Public","Unipol Group","EIOPA proposes the following changes in the reduction in granularity of the liquidity information: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). The change in granularity should assist in the availability of this information. "]
["Financial stability guidelines",null,"Group","S.14.05 - We would like to underline that the quarterly frequency adds complexity to the compilation of this QRT. Therefore we suggest to produce the template on annual basis.","Public","Unipol Group","Noted. In order to reduce the burden for insurance undertakings, EIOPA proposes to reduce granularity and frequency of the liquidity information. S.14 is to be reported semi-annually (instead of quarterly)."]
["Financial stability guidelines",null,"Both","Template S.14.05.11 Liquidity risk for non-life business:\n1. We would like to underline that the level of detail by product is highly costly and bundersome, and would require a lot of effort to be produced. Therefore we suggest to reduce the level of details and to produce the template on annual basis.\n2. Furthermore with reference to Items C0070 and C0290 we would like to underline that the information required is available only on an accrual basis. Therefore we suggest to produce the information related to these items on accrual basis.\n","Public","Unipol Group","Noted. \n1. In order to reduce the burden for insurance undertakings, EIOPA proposes to reduce granularity and frequency of the liquidity information. \n2. The reporting of these items on an accrual basis will not facilitate the adequate supervision of liquidity risk. Moreover, the change in granularity should assist in the availability of this information. "]
["Reporting","S.26.01","Both","It is unclear why information on absolute values of liabilities before shock is required. Firstly, long-term equity (on the asset side) is ear-marked, but insurance companies do not distinguish their liabilities (passive side) backed by long-term equity. Such a distinction is not legally required and does not make sense. Secondly, this distinction is asked before but not after shock. It is unclear what purpose this serves. Therefore, the industry opposes the changes to this template.\n\nCells C0020/R0205 and C0040/R0205 in S.26.01.01 and S.26.01.04 should be available for input. ","Public","Insurance Europe","Noted. R0205/C0034 and C0035 have been deleted"]
["Reporting","S.12.01","Solo","For cost-benefit reasons, there should be no requirement to report EPIFP information at LOB level. A potential benefit of this additional requirement is not comprehensible. ","Public","GDV","EPIFP represents the profitability embeded in future premiums. Knowing this figure by LOB would help supervisors to better understand the structure of the business of the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually. "]
["Reporting","S.13.01","Solo","\nEIOPA announced to investigate a threshold for this template, but disappointingly such a threshold is missing. \n\nThe proposal to exempt all undertakings using simplifications for the technical provisions, for which an estimate of the expected future cash flows arising from the contracts is not calculated, might be helpful in some cases. \n\nHowever, the requirement to report the value of  ‘total recoverable from reinsurance’ by LoB and, in particular, to split ‘future benefits’ in ‘future guaranteed benefits’ and ‘future discretionary benefits’ should be dropped. Such as s split is at least burdensome (from both a practical and technical point of view) with limited additional benefits, or it is not feasible at all. For many current products with an innovative profit sharing mechanism, it is not clear how a unique classification of future payments as either guaranteed or discretionary benefit should be done, as there will be many different scenarios with different splits between the two.\n\nIf this requirement was kept nevertheless, sufficient prior time would be needed to implement according calculations in health (e.g. INBV in Germany) and life insurance models. ","Public","GDV","EIOPA disagrees with the proposal to drop the split between future guaranteed benefits (FGB) and future discretionary benefits (FDB). EIOPA understands that under stochastic valuation different scenarios would lead to different allocation of cash flows. However, this issue does not only affect to the split of cash flows between FDB and FGB but also to the total amount of cash flows which is currently being reported. For this reason, the LOG already clarifies that reconciliation with BE is not required, but additional guidance has been included. \nEIOPA disagrees of providing a threshold. S.13.01 exists from the inception of Solvency II, so all undertakings should be used to it. The exemption for undertakings using simplifications, already linked to proportionality, should be enough. "]
["Reporting","S.17.01",null,"•\tWhile EIOPA presented the removal of the transitional information as a simplification to both S.12.01 and S.17.01, it is adding more reporting requirements regarding EPIFP. EIOPA Noting that it ‘considers that to provide meaningful insights, EPIFP information should be available at least at Line of Business level.’ It is unclear what these meaningful insights would be. ","Public","GDV","EPIFP represents the profitability embeded in future premiums. Knowing this figure by LOB would help supervisors to better understand the structure of the business of the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually. "]
["Reporting",null,"Both","General Comments to the EIOPA´s proposal to review the reporting package:\n• Timeline: The expected timeline for all the proposed changes is too tight and it does not consider the need to mobilise resources to collect all the necessary data in order to fulfil the new requirements; The timeline is also misaligned with the European Commission sustainability agenda and the coming into effect date of the amendments to the Solvency II review framework. The 2021 company´s budgets will be soon closed and validated for 2022 developments whereas the final advice of EIOPA will be published at the very end of 2021 and the final adoption of the European Commission is not likely to take place before March 2022 (i.e after the budget validation process). For this reason, it appears unfeasible to include all the EIOPA’s proposals for an effective implementation on 1 January 2023 with 2022-year end figures. Furthermore, the current package in consultation proposes new QRTs and changes to existing QRTs. Amending the associated validations are also time-consuming and lead to changes in parameterization and/or filling. For the new templates introduced in the package, an even longer time frame should be considered in order to have a realistic timeframe for undertakings to report all the new information. We therefore request EIOPA to postpone the entry into force date at least by one-year (31/12/2023) for the changes in the existing templates given the large number – and often material – proposed changes. For the new templates we request an entry into force date in 31/12/2024.\n• Proportionality: We welcome the proposed thresholds, however in their current form they will not represent a significant relief for undertakings. The proposed thresholds are too restrictive and they would not decrease the burden on insurance companies. Morevoer, the rigid nature of the threshold could result in firms moving in and out of the requirement on a year-by-year basis. As a result, firms should have, at all times, a process in place to collect and submit the requested data. In order to ensure there is an alleviation on the burden, the thresholds should be valid for a longer period or a single breach should not directly lead to a requirement to submit the related QRT. We reiterate the need to develop further thresholds, in addition to the ones proposed by EIOPA; Furthermore, some of the new proposed thresholds should be improved so that they have an impact in terms of reducing the workload for insurers. \n• Deleted QRTs: We welcome the deletion of some of the templates but the deleted templates would not represent a significant saving in terms of work. In fact many times deletions mean that information is included in other templates, so there is often really no reduction in the amount of the information requested. In order to lessen the burden for small and medium size undertakings, we propose that other non-core QRTs also be deleted. The new requested information also suggests that supervision is conducted at a micro level. There is a real risk that the very granular data would disrupt the actual supervision of the (re-) insurers as envisaged in the Solvency legislation. The focus on small details is not needed for the purpose of a continuous prudential supervision and could defer the attention from the real trends and developments. We request EIOPA to align the data requirements with the Solvency II framework and the manner in which the capital requirements are calculated.\n• EIOPA is proposing additions and changes to many existing templates: However, the industry had requested no changes in the design of the QRTs as already implemented. We request EIOPA to reassess whether the proposed small changes are really needed as they imply significant costs for undertakings; EIOPA may consider that some changes are small, but the effort of implementing the information in regular reporting imply that considerable efforts and costs are required. These additional costs will ultimately be passed on to policyholders. For minor changes or when some information is just moved around between templates, we request that they instead remain unchanged/unaltered.\n• New templates: EIOPA’s new proposals and existing templates which are significantly amended (e.g S.06.02 and S.14.01) would require an enormous additional effort for insurers both in terms of human resources and changes in their IT systems. That is why for new and significantly amended templates an even longer time frame should be considered.\n• Proposed Changes to S.14.01 – Life Insurance Obligations: The information requested at product level would be a very demanding exercise. The objection to the changes also apply to the new liquidity templates (see Financial Stability section below).\n• New template on non-life products S.14.02: We would like to reiterate that the Solvency II reporting package contains a significant number of QRTs which collect non-life information. We query the added value of the new proposed information on non-life products when the risk management and even the pricing process are not conducted at this level. We appreciate that EIOPA has reduced the number of product categories and simplified the amount of information requested, however the template is still extremely difficult to produce at the requested granularity level which is often not used by insurers and which will require many system intervention. The proposed template should therefore be removed. The objection to the changes also apply to the new liquidity templates (see Financial Stability section below). \n• Sustainable investments and climate change-related risks to investments S.06.04: Insurers should only report information on sustainable investments if subject to the NFRD/CSRD; Firms not subject to the NFRD/CSRD should not be required to report this information. We do not support any thresholds to be included in the Solvency II package, but that EIOPA/other stakeholder receive the data as part of the public disclosures made through NFRD requirements, where applicable.\nIf EIOPA persists with introducing this information in the Solvency II reporting, at the very least it should not go beyond the Taxonomy-regulation timelines or scope of undertakings. The same timeline as the disclosures delegated act on Article 8 of the Taxonomy, which is currently subject to the scrutiny period by the European Parliament and the Council, should apply (i.e As of 1 January 2023 for the reporting period 2022, the Delegated Act will apply fully to non-financial undertakings and as 1 January 2024 for the reporting period 2023 to financial undertakings (including insurers).\n• New template on cyber risk S.14.03: Reporting on cyber risk may be justified for companies which develop a significant exposure. A suitable higher threshold for this template should be included.\n• Proposed Changes to Variation analysis templates S.29.05: We welcome the separation of the variation analysis template between life and non-life business. However, EIOPA’s Proposal for VA for non-life is more granular than the current template and it will be very costly to implement. Therefore, we believe that at this stage the current QRTs should remain unaltered and no new QRTs be introduced. EIOPA should also consider whether the current templates S.29.01-S.29.04 could be removed completely. Where relevant and material to explain “the variation of the excess of assets over liabilities between reporting periods”, it is perhaps better to request that firms, on an ad hoc basis, submit the analysis of change they are using for internal reporting and other management proposes. While not aggregated or collected in a harmonised manner, we believe this data/information would likely provide more insights into the movements in the EoAoL than it is currently the case with the VA templates; this would likely also be less burdensome for undertakings to submit. \nThe proposed adjustments to capture composites with both life/non-life seems overly complex. A proportional approach should therefore be taken - i.e. introduce thresholds to determine whether disaggregation is actually required.\n• Loss absorbing capacity deferred taxes (LAC DT): We oppose the introduction of the new set of deferred tax templates as the current information reported in S.25 is sufficient. \nThe new detailed information on the LAC DT is introducing new provisions and new requirements not defined in the Solvency framework. The set of templates require firms to follow a certain methodological approach for the calculation of the loss absorbing capacity of deferred taxes, however there are some heterogeneities of approaches. By requiring companies to provide such detail, EIOPA is forcing insurance companies to choose that approach.\n• Groups templates: The additions to S.36/S.37 templates should not be required in the case of groups that do not form a financial conglomerate, i.e. groups which operate solely or mainly in the insurance sector. We request that those undertakings which \"operate solely or mainly\" in the insurance sector report using the current templates. \n• Financial stability templates: EIOPA proposes that some information be reported in more granular form or more frequently (more information will be requested on a quarterly basis at group level); this development would lead inevitably to more data quality issues and an increase in the administrative burden.\nAdditionally, EIOPA requests new information on liquidity risk which is one the measures of the macro-prudential approach proposed by the European Commission in its proposal for amendments to the Solvency Directive. The introduction of this and any other related information should wait for the finalisation of the Solvency II review package.\n• Taxonomy: EIOPA states in its document that the consultation of the 2.7.0 taxonomy release will not follow the usual calendar (PWD in 1 June and final taxonomy 15 July) but will instead be consulted as soon as possible after the delivery of the draft ITS to the COM to allow industry more preparation time. Can some clarity be provided as to when that consultation could take place and for how long? Given that the taxonomy usually takes effect from Q4, shall we understand that the new taxonomy (with the proposed amendments) will be applicable to Q4 202X?\n\n","Public","Amice","Timeline - EIOPA has extended the application date. Please consult the final package proposal.\nThreshold - following the comments received EIOPA has extedned the observation threshold period. EIOPA has further revised the thresholds and also proposed new ones. Please consult the final package proposals.\nQRTs - following comments received the proposals have been further reviewed and in some cases changes have been introduced e.g. revert to the current S.29s, dropped LAC DT templates etc. Please review the final package proposals for detail view.\nS.14.01 and S.14.02 - further changes have been introduced to reflect the comments received and to reduce the burden. On S.06.04 the sustainable investment ratio has been dropped out of the proposal. S.14.03 - a threshold has been ncluded. Group templates - please consult the ndividual comments resolutions. Fianncial stability templates:\nLiquidity information (S.14.04/05): reduce the frequency to semi-annual (instead of quarterly) and granularity of the templates in order to reduce the burden for undertakings. Namely S.14.04 (Life) is to be reported at (unit and index) linked business and non-linked business  (instead of product level) and S.14.05 (Non-life) is to be reported for the non-life business as a whole (instead of product category). \nDuration information (S.38.01): to require the effective duration only where material optionalities are present in the technical provisions;\nProfit & Loss (S.39.01): as some information on P&L was already part of the financial stability templates the additional high level breakdown should not add excessive additional burden to the undertakings. Guidelines will be provided in relation to both the Insurance Accounting Directive and IFRS.\nTaxonomy - the PWD 1 is expected to be publicly consuled soon after the submission of ITS package to COM. Current planning in March/April.\nFor more detailed view on the individual topics please consult the relevant comments and their resolutions.\n"]
["Reporting",null,"Both","General comments\nEIOPA is keeping a significant number of additions and changes to the QRTs; During the public consultation, we had proposed an approach by which the templates which have already been implemented are not modified and only those which have already been identified as not useful for supervision, are removed from the reporting package. We propose that EIOPA reassess whether all the suggested changes are really needed.\nWe welcome the removal of some QRTs from the reporting package; However, we have concerns that the templates which have been removed would not represent a big saving in terms of work. We believe that EIOPA should be more ambitious in their analysis and that further templates should be deleted. \nEIOPA also proposes that some information be reported in more granular form; the granularity proposed and would lead inevitably lead to more data quality issues.\n","Public","Amice","EIOPA has evaluated all comments received and in case needed changes have been introduced in the final package of the ITS amendments. Whenever the comments are considered not relevant the initial proposals were kept."]
["Reporting",null,"Both","Proportionality\nGenerally, we welcome the proposed thresholds, however in their current form and design they will not represent any significant relief for undertakings, neither large nor small undertakings. The proposed thresholds are too restrictive and they would not decrease the burden on insurance companies. We reiterate the need to develop further thresholds, in addition to the ones proposed by EIOPA; Furthermore, some of the new proposed thresholds should be improved so that they have an impact in terms of reducing the burden for insurers. \nAdditionally, in practice the thresholds may not result in a real reduction of the burden for insurers  if the insurer would breach the threshold in a period which would result in a requirement to submit the QRT to which the threshold applies. As a result, the insurer should have, at all times, a process in place to collect and submit the requested data. Therefore, the threshold should be valid for a longer period or a single breach should not directly lead to a requirement to submit the related QRT. We propose that a template is only reported provided the threshold is breached for three consecutive years.\n","Public","Amice","EIOPA disagrees with the comment. Each threshold proposed has been assessed from the impact point of view and it is clear that the proposals lead to a reduce burden for the insurers.\nOn the threshods please note that the observation period for the annual threshold have been extended."]
["Reporting","S.01.02","Both","S.01.02 – Basic Information\nWe agree with the proposed changes. \n","Public","Amice","Noted"]
["Reporting","S.01.02","Both","S.01.02 – Basic Information – Run-off business – C0010/R0280\nWe welcome the consideration in this cell of partial run-off business and that insurance undertakings can 'run off' a portfolio. \n","Public","Amice","Noted"]
["Reporting","S.01.02","Both","S.01.02 – Basic Information – M&A during the period - C0010/R0290\nM&A could be interpreted as only 'acquisitions', but disposals of activities should also be addressed. We reiterate the need to add 'and disposals' or by rewording the new cell as 'acquisition or disposal of activities'. Furthermore, it is currently not clear whether the purchase of a small insurance portfolio should be regarded as 'M&A'. A threshold could be introduced. \n","Public","Amice","Noted. Wording has been clarified. As the cell doesn't require any quantitative reporting but only information of whether such activity has been performed affecting the information reported EIOPA is of the opinion that no threshold is required and not further changes in the instructions are needed."]
["Reporting","S.02.01","Both","S.02.01 – Balance sheet – Equity Investments – R0110 & R0120\nOn the Balance Sheet, EIOPA differentiates within the equity investment between listed and unlisted equity despite this information is not being used elsewhere. We propose that EIOPA removes this granularity and keep the “equity investments” line only. \n","Public","Amice","EIOPA disagrees and would like to remind that granularity within rows R0110 (Equities - listed) & R0120 (Equity - unlisted) is nothing new (these rows are reported staring from 2016). "]
["Reporting","S.02.01","Both","S.02.01 – Balance sheet – Own shares (held directly) – R0390\nOn the Balance Sheet template, EIOPA re-classifies \"own shares\" from the own funds to the asset side of the balance sheet. This approach increases the amount of the total balance sheet while not providing any added value and it is also not in line with accounting practices. \n\n","Public","Amice","EIOPA disagrees. The presentation of own shares (held directly) (R0390) on the assets side of balance sheet is nothing new (these way of presentation has been in force since 2016). EIOPA doesn't see any grands for a change in this respect, i.e. a change from the presentation on the asset side of the balance sheet (positive value) to the presentation on the liabilities side of the balance sheet (negative value). "]
["Reporting","S.02.01","Both","S.02.01 – Balance sheet – Subordinated liabilities – C0010 - C0020/R0850\nOn the Balance Sheet template any subordinated liability which is part of the basic own funds has to be re-classified as a liability whereas this item is also being requested in other templates. This approach increases the balance sheet total while not providing any added value. We propose that EIOPA excludes the subordinated liability information from the S 02.01 template and makes subsequent corrections in the other templates where relevant.\n","Public","Amice","EIOPA disagrees - no approval of the proposed change in this regard. The comment is incomprehensible, because regardless of whether the subordinated liabilities are or not Basic Own Funds it should be reported on the liabilities side of the balance sheet. At the same time, subordinated liability which is part of the basic own funds has to be reported within other templates, therefore reporting by subordinated liabilities not in Basic Own Funds and subordinated liabilities in Basic Own Funds should not create any burden on (re)insurance undertakings (additionally these way of presentation has been in force since 2016)."]
["Reporting","S.02.02","Both","S.02.02 – Assets and Liabilities by currency – General comments\nWe agree with the proposed changes:\n• Deletion the assets part of the template (and add currency in S.31.01); \n• Keeping the liabilities part of the template; \n• Clarification of the  treatment of negative TP\n","Public","Amice","Noted"]
["Reporting","S.03.01","Both","S.03.01 – Off-balance sheet items – Thresholds \nWe welcome EIOPA’s decision regarding the value of collateral held/pledged by which the economic value at the reference date and not the risk adjusted value would be used. \n","Public","Amice","Noted"]
["Reporting","S.03.01","Both","S.03.01 – Off-balance sheet items – Thresholds \nIt is not clear on which basis the amount of guarantees and contingent liabilities needs to be included i.e. the Solvency II value or the maximum value. Furthermore, the thresholds of 2% of total Assets are rather low and therefore it is highly likely that the thresholds will be met. As a result, the thresholds proposed do not limit the amount of work to be performed on reporting the guarantees and contingent liabilities. We propose an increase in the thresholds.\n","Public","Amice","EIOPA has re-analyzed the impact of the proposed threshold based on solo insurer reporting S.03.01 in 2020. The impact assessment shows that if the threshold was to be implemented, 45% of solo insurers would have benefited from it (ie. 45% of solo insurers would not report S.03.01 template). \nTherefore, EIOPA believes that the implementation of the treshold in S.03.01 template will bring relief to insurers and does not see the reason to increase the threshold.\nIn addition, it should be noted that the application of the threshold in not mandatory, ie. insurer may or may not use it.\n\nGuarantees need to be calculated based on the Solvency II value and contingent liabilities on the maximum value (in accordance with the information included in ITS)."]
["Reporting","S.03.01","Both","S.03.01 – Off- balance sheet items – Thresholds \n(new) Centrally-cleared derivatives require parties to keep cash or collateral as a guarantee. Any insurer using these types of derivatives would be required to post collaterals and the proposed threshold would be reached very easily. We propose to remove the collaterals from centrally-cleared derivatives from the threshold proposed by EIOPA.\n\n","Public","Amice","EIOPA does not see the ground to change the threshold for S.03.01 template and to exclude the collaterals from centrally-cleared derivatives from the threshold."]
["Reporting","S.03.01","Group","S.03.01 – Off balance sheet items –Thresholds \nWe propose to exclude undertakings consolidated in accordance with Article 335, paragraph 1, (d), (e) and (f) of Delegated Regulation (EU) 2015/35 from the calculation of the threshold. Indeed, we believe that the formula would be inconsistent for these undertakings, since the denominator would not represent the proportional share of total assets but the proportional share of the excess of assets over liabilities.\n","Public","Amice","Agree. To clarify the instructions"]
["Reporting","S.03.02","Both","S.03.02 & S.03.03 - Off-balance sheet items - List of unlimited guarantees received by the undertaking and Off-balance sheet items - List of unlimited guarantees provided by the undertaking\nWe agree with the amendments proposed by EIOPA to delete both S.03.02 and S.03.03 from the reporting package which are applicable both at solo and group level.\n","Public","Amice","Noted"]
["Reporting","S.04.03","Solo","S.04.03/04/05 – Cross-border business – Threshold \nEIOPA proposes to delete two of the existing templates for cross-border business (S.04.01, S.05.02) from the reporting package and replace those with a new approach of reporting templates that would consolidate the information requirements (i.e three new templates S.04.03, S.04.04, S.04.05). \nWe welcome EIOPA’s decision to keep S.12.02 and S.17.02.\nThe proposed EIOPA template can be simplified as follows:\n• A threshold of 10% should be introduced to avoid burdensome processes for insignificant cross-border activities. This is key for smaller insurers, especially those doing business on the borders of different countries. Filling in the template would be very burdensome given that the information is not part of the undertaking’s core business and it has not been directly integrated in the systems. Some examples could further describe the issue: \n1) an entity insures horses on both sides of the border between two jurisdictions. \n2) a policyholder who has a second home in another Member State but wants to remain insured with his/her local mutual. The cross-border business may not be material but it will be required to fill in the new cross-border template.\nFurther guidance is needed as to the notion of country of location according to the different scenarios (i.e ceding or accepting company, FPS).\nThe new proposed S.04.05 should not be part of the public disclosure.\n\n","Public","Amice","Supervisory experience since the introduction of Solvnecy II has shown that the existing templates do not provide sufficient information on location of risk to enable effective cross-border supervision.  Therefore, we do not consider retention of the existing templates as a viable option.\n\nThe observations on proportionality are noted.  It is not possible to introduce a threshold for template S.04.04 on location of underwriting (where information is required for cross-border statistical exchanges), but a threshold (e.g. 5% of GWP by LoB) could be considered for location of risk reporting in S.04.05."]
["Reporting","S.05.01","Both","S.05.01 – Premiums, claims and expenses – premiums written\nIn relation to the data reported from an accounting perspective, i.e. applying Local GAAP or IFRS recognition and valuation basis, we believe that EIOPA needs to clarify the instructions on S.05.01, given that the introduction of IFRS 17 may imply major changes for those companies that will adhere to the new standard IFRS17. However, such alterations cannot be uniform and applicable to every insurer in the scope of Solvency II reporting as many insurers in Europe will not be subject to IFRS17 but continue to apply local GAAP.\nAs a  result, the EIOPA instructions (LoG files) need to be updated to indicate which parts are applicable to insurers under the scope of IFRS17 and which elements apply to firms subject to local GAAP requirements. Some deletions and the inclusion of new cells in S.05.01 may be required for IFRS17 players.\n\n","Public","Amice","EIOPA recognizes that IFRS17 will bring material changes in the recognition, valuation, presentation, disclosure of insurance contracts. However, the template S.05.01 will be kept as it is now even if IFRS insurers don´t report the written and earned premius in their accounting P&L. The main reason is to maintain consistent basis of reporting for all insurers (IFRS and local gaap users). Further reasons:\n1) Although linked to accounting, S.05.01 is not a P&L but simply requires some P&L related items to collect some volume measures to measure the performance trend and for market wide analysis;\n2) This approach is already in place today with regard to insurance contracts with no significant insurance risk, whose written premiums/claims paid are not accounted for in the IFRS P&L (according to IFRS 4) but are still to be reported in S.05.01;\n3) The mandatory disclosure of IFRS 17 on premiums/claims paid would allow undertakings to fill in S.05.01 following the current approach;\n4) Re(insurance) undertakings will have to keep track of written/earned premiums for MCR/SCR calculation.\n\nFor IFRS17 users: Written premius/claims paid will be reported in the notes to the financial statements."]
["Reporting","S.05.01","Both","S.05.01 – Premiums, claims and expenses – premiums written\nThe contract boundaries in IFRS17 differ from those in Solvency II. IFRS 17 requires firms to split their contracts between profitable and onerous contacts. In IFRS17 a contract is bounded immediately in case of an expected loss at the starting date of the policy. So, for a loss making policy with a starting date in January 1st year X, the policy is within the contract boundary of December 31st year (X-1), whereas for a profit making contract the contract boundary starts in Jan 1st year X.  If the S.05 were to be reported from an accounting perspective, it can be the case that, due to the IFRS17 grouping, a single policy would have to be split between the onerous and the profitable part. As a result, an amount of the premium would be written in year X and another part of the premium would be written in year X+1. This can give very strange results for premiums written under the accounting perspective. For the Dutch medical expenses this situation can happen quiet frequently.\n\n","Public","Amice","The question does not really relate to contract boundaries, but to the time when contracts and losses are recognised. \nLooking at the time when contracts are recognised (Art. 17 of Delegated Regulation (EU) 2015/35 and IFRS 17 paragraph 25), there are no obvious practical differences. In the case of onerous contracts, SII requires the recognition of the obligation when the insurer becomes a party of the contract (once the contract is underwritten) and IFRS 17 when the group of contracts becomes onerous.\nFurther, please be advised that under IFRS 17 contracts are allocated to groups (onerous/non-onerous/others) – however, contracts are not split into an onerous component and a non-onerous one."]
["Reporting","S.05.02","Both","See our comments to S.04.03/04/05.","Public","Amice","Noted"]
["Reporting","S.06.02","Both","S.06.02 – List of assets – Comment on proportionality \nSubmitting information on the list of assets on a quarterly basis is very burdensome, particularly for SMEs. Article 35 of the Solvency II Directive allows Member States to exempt up to 20% of the national market, however that exemption is only applied in a few jurisdictions; We therefore propose a threshold that exempts SMEs from submitting this template in the quarterly reporting when the insurer can justify that its portfolio does not contain complex products. The threshold would only apply to insurers not benefiting from the exemption in Article 35 of the Solvency II Directive and which will qualify for low risk undertakings according to Article 29 of the amended Solvency II Directive.\n\n","Public","Amice","Please note that the proposal from COM for exemptions in Article 35 are already linked to the qualification of LRPU according to Article 29. EIOPA disagrees of intorudcing threshold to this template that is considered important for the supervisory purposes."]
["Reporting","S.06.02","Both","S.06.02 – List of Assets– ECB add-on items – General comments \nEIOPA’s proposal to include new ECB add-on items appears to be in contradiction with the planned reduction of the ECB add-ons. \n","Public","Amice","Please note that as part of the analysis on data gaps EIOPA decided to include two ECB add-on items relevant for prudential supervision purposes (Write-offs/write-downs and Issue date)"]
["Reporting","S.06.02","Both","S.06.02 – List of Assets – ECB add-on items \nWe welcome the aim to reduce the ECB add-ons. In case add-ons remain, please align the definitions with the Solvency II reporting as much as possible. For example, the Q&A 1059 states that for the ECB reporting, Issuer Sector according to ESA 2010 should be reported also for loans and mortgages to individuals, as they are reported with CIC category 8. It can be reported always with the option 11 – households and non-profit institutions serving households (ESA sector S.14 + ESA sector S.15). \nThis implies that for ECB-reporting a revised S.06.02 needs to be generated.\n","Public","Amice","Please note that for the ECB add-ons not incorporated in the Solvency II reporting the original instructions keep being defined by the ECB and not by EIOPA. As part of the analysis on data gaps EIOPA decided to include two ECB add-on items relevant for prudential supervision purposes (Write-offs/write-downs and Issue date)"]
["Reporting","S.06.02","Both","S.06.02 – List of assets – RGLA – C0294\nEIOPA proposes to add an additional item on RGLA. We reiterate that adding this item to the CIC table should suffice.\n","Public","Amice","Due to the structure of the CIC codes, it is not possible to have additional positions to capture this new data need. EIOPA has carefully considered the options – changing CIC structure or add an additional item – and concluded that the additional item would have a smaller impact overall compared to the other options."]
["Reporting","S.06.02","Both","S.06.02 – List of assets – Write-offs & Write downs – C0141\nThe ECB add-on regarding write-offs/write-downs is not clear since it is not in line with the economic value principle (write-offs/write-downs are calculated only in case of an 'amortised cost' valuation). As long as the financial instrument still reflects an economic value at the reporting date, the decrease in value in comparison to a prior period is a 'common' decrease in value. Therefore, we suggest deleting this cell from the QRT.\n","Public","Amice","It should be independent from the accounting framework. It corresponds to the part of the notional amount that is \"lost\" due to the impairment of the loan or non-negotiable debt securities. Please note that as part of the analysis on data gaps EIOPA decided to include two ECB add-on items relevant for prudential supervision purposes (Write-offs/write-downs and Issue date)"]
["Reporting","S.06.02","Both","S.06.02 – List of assets – CIC code – C0290\nIn case of a bond with a different currency for the nominal and the accrual, EIOPA is asked to clarify whether the currency of the nominal is leading for identification as CIC 18.\n","Public","Amice","EIOPA confirms that it should be the currency of the nominal leading for the identification as CIC 18"]
["Reporting","S.06.02","Both","S.06.02 – List of assets – Property location – C0297\nRegarding this new item “Property location” (prime, non-prime or non-applicable), it should be clarified from which perspective a property should be assessed (i.e from a city, village or country perspective) to determine whether it is located in prime or non-prime area.\n","Public","Amice","Please refer to ESRB Recommendation of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real estate data gaps (ESRB/2019/3), as mentioned in the instructions."]
["Reporting","S.06.02","Both","S.06.02 – List of assets – CIC definitions \nEIOPA proposes to clarify the CIC definitions of Government bonds (CIC 11) by including the following explanation: “government bonds are bonds that are fully, unconditionally and irrevocably guaranteed by the European Central Bank, Member States' central government and central banks”; We welcome this clarification.\n\n","Public","Amice","Noted."]
["Reporting","S.06.02","Both","S.06.02 – List of assets – CIC definitions \nEIOPA proposes to ease the identification of government bonds and corporate bonds backed by government guarantees issued in a different currency by adding a new CIC 18 code and amending the definitions of CIC 1 accordingly. We welcome this clarification.\n\n","Public","Amice","Noted."]
["Reporting","S.06.02","Both","S.06.02 – List of assets – Crypto-assets – C0295\nWe would like to reiterate that this information should be requested as part of the CIC table rather than through the addition of a new cell.\n\n","Public","Amice","Item C0295 allows the identification of assets that have a link to a crypto-asset. The CIC should be the code attributed to the “basis” asset. If it is a (new) asset category, not classifiable under the existent CIC categories, them CIC 09 should be used. "]
["Reporting","S.06.02","Both","S.06.02 – List of assets – LEI code – C0010\nWe would like to reiterate that submitting information on the LEI for each and every asset is very burdensome. Requiring an additional item regarding the LEI code of the custodian would be very demanding for small and medium sized undertakings.\n","Public","Amice","Please note that this information facilitates an aggregate analysis, especially in case of financial institutions crisis. The number of custodians per undertaking is limited and changes are not frequent. Providing/updating the LEI code seems not to impose a significant reporting burned on the long run."]
["Reporting","S.06.02","Both","S.06.02 – List of assets – Fund number – C0070\nWe reiterate that insurance undertakings do not usually categorise their assets by way of fund numbers. Therefore, the inclusion of a fund number is artificial and  it does not provide any additional insights for the NCAs. While for RFF(s) there is a rationale to use a fund number, for other internal funds there is no such rationale. Assigning a fund number to individual investments would create a tremendous administrative burden and it would not reflect the manner in which investments are managed. The proper matching of the insurance liabilities with the assets can be reviewed by other means, for example by analysing how an insurance undertaking complies with the prudent person principle and how it performs its ALM. \n\n","Public","Amice","On the fund number, there is no additional requirement. The objective is to clarify the applicability and provide the adequate framework for the current practice in some jurisdictions."]
["Reporting","S.06.02","Both","S.06.02 – List of assets –  Issuer group – C0240\nFurther guidance is needed on the issuer group of collective investment undertakings as in most cases they are legally separated from the trustee. Can EIOPA clarify whether the issuer group should be the legal name of the fund or the ultimate parent of the trustee?\n","Public","Amice","Please note that this isn't a new requirement. EIOPA tried to clarify the applicability to CIUs. EIOPA believes that the definition, as is now, is flexible enough for undertakings to comply with, precisely knowing that there are different possible group structures. It is up to the undertaking to determine what is the most relevant relation in order to identify a potential concentration (or other type of) risk arising at the aggregated / group level "]
["Reporting","S.06.02","Both","S.06.02 – List of assets –  Custodian – C0120\nEIOPA states that for assets where there is no custodian or when this item is not applicable, report “No custodian”. \nIt is also stated that Items C0110, C0120, C0121, C0122, C0130, C0140, C0141, C0160, C0200, C0230, C0270, C0280, C0310, C0370, and C0380 are not applicable to CIC 09 - Other investments. \nEIOPA is asked to clarify whether this implies an empty reporting for CIC 09 field C0120 or “No custodian”\n","Public","Amice","\"No custidian\" should be reported, as prescribed in the instructions of C0120."]
["Reporting","S.06.02","Both","S.06.02 – List of assets – Item Title – C0190\nEIOPA allows for a NSA option in completing this field; This should be avoided in order to keep the comparability. Any deviation from the default should be requested through a national QRT.\n","Public","Amice","EIOPA sees the point of the request and despite that would like to have more harmonisation in the reporting NSAs can request additional information regardless whether it is explicitly mentioned in the instructions or not. In addition this isn't a new requirement and the change in the instructions aims to clarify it's applicability, that is, to clarify what was the meaning of \"not mandatory\"."]
["Reporting","S.06.03","Both","S.06.03 – Look-through template – General Comments \nWe regret that EIOPA has decided not to increase the quarterly threshold from 30% to 50%. Moreover we would like to reiterate that this template could be further simplified:\n• Additional proportionality considerations for the annual calculations should be introduced; \n• Article 84 (3) of the Solvency II Delegated Acts allows firms to use data groupings for up to 20% of the total value of the assets. The template S.06.03 should be aligned with the Delegated Acts so that the same level of granularity is required.\n\n","Public","Amice","To gather all relevant information, the threshhold will not be further increased. (The original proposal of an increased threshold was to be understood with the parallel introduction of the additional S.06.04 lookthrough template).\n\nArt. 84 corresponds to pillar 1 and is therefore not transferable to the template S.06.03."]
["Reporting","S.06.03","Both","S.06.03 – Look through – Country of issue – C0040\nEIOPA is asked to clarify whether this is a mandatory field for categories 8 and 9 as reported in C0030.\n","Public","Amice","The field C0040 - Country of issue is a mandatory field for categories 8 and 9 as reported in C0030."]
["Reporting","S.06.04","Both","S.06.04 – Sustainable investments and climate change-related risks to investments – General comments \nThe Article 8 of the Taxonomy Regulation aims “to increase transparency in the market” and “help prevent greenwashing by providing information to investors about the environmental performance of assets and economic activities of financial and non-financial undertakings”. Therefore this article goes beyond the objectives of the Pillar III of the Solvency II framework.\nWe expect that as a result of the review of the NFRD more companies will be subject to non-financial reporting. Insurers should only report information on sustainable investments if subject to NFRD/CSRD; Firms not subject to the NFRD/CSRD should not be required to report this information. We do not support any thresholds to be included in the Solvency II package, but that EIOPA/other stakeholders receive the data as part of the public disclosures made through NFRD requirements, where applicable.\nIf EIOPA persists with introducing this information in the Solvency II reporting, at the very least it should not go beyond the Taxonomy-regulation timelines or scope of undertakings. The same timeline as the disclosures delegated act on Article 8 of the Taxonomy, which is currently subject to the scrutiny period by the European Parliament and the Council, should apply (i.e as of 1 January 2023 for the reporting period 2022, the Delegated Act will apply fully to non-financial undertakings and as 1 January 2024 for the reporting period 2023 to financial undertakings (including insurers).\n\n","Public","Amice","Noted. EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Reporting","S.06.04","Both","S.06.04 – Sustainable investments and climate change-related risks  to investments – General comments \nEIOPA refers to several KPIs/information related to the EU taxonomy. As part of the NFRD, entities are also disclosing several KPIs. However, these are based on accounting data and will differ from the Solvency II classification and methodology resulting in separate values for the same KPI. We query how does EIOPA ensure alignment; Further guidance is therefore needed. In the cover note EIOPA indicates that firms can apply their own methodologies, accepting a misalignment with for example the information provided based on S.06.02.\n\nThe ratios required to be reported are very sensitive to the development of economic variables resulting in an economic value. As a result, the development of these ratios will not help understand whether an insurer is more or less sustainable. The ratio(s) could differ just based on a different behaviour of the value of sustainable investments versus the total economic value. The reporting of these type of information could lead to the wrong conclusions.\n\n","Public","Amice","Noted. EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Reporting","S.06.04","Both","S.06.04 – Sustainable investments and climate change-related risks  to investments – General comments \nEIOPA is requesting groups to also complete this template. We query how does EIOPA envisage the aggregation of the KPI's for financial conglomerates as requested by the various ESAs. For example, how should the KPI from an asset manager be aggregated into the group KPI's?\nIn the logfile, EIOPA refers to a TEG final report on the EU Taxonomy. It is to be stressed that the work of the TEG does not have legal basis. Therefore, it is also not clear whether the presented table will be a legal requirement categorisation.\n","Public","Amice","Noted. EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?","Both","Cover note S.06.04 – Reporting requirement on sustainable investments\nWe do not support any thresholds to be included in the Solvency II package but that EIOPA/other stakeholder receive the data as part of the public disclosures made through NFRD requirements, where applicable.\n\n","Public","Amice","Noted. EIOPA tends also to be of the view that materiality tresholds for the KPIs may be of limited supervisory value. EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ","Both","Cover note S.06.04 – Reporting requirement on investments exposed to climate change-related transition risk\nWe do not support any thresholds to be included in the Solvency II package but that EIOPA/other stakeholder receive the data as part of the public disclosures made through the NFRD requirements, where applicable.\n\n","Public","Amice","Noted. EIOPA tends also to be of the view that tresholds for the proposed KPIs may be of limited supervisory value. We note note that the NFRD requirements do not require the corporate reporting of explict transition or physical risk metrics. "]
["Sustainable finance questions","3. What could be a methodology for standardised reporting of climate change-related physical risk exposure for other investments than property?","Both","Cover note S.06.04 – Reporting requirement on investments exposed to physical risk\nWe do not support any standardistion of the reporting of physical risk exposures which is not in line with the developments in the area of sustainability.\n\n","Public","Amice","Noted. EIOPA tends also to be of the view that materiality tresholds for the KPIs may be of limited supervisory value. We note note that the NFRD requirements do not require the corporate reporting of explict transition or physical risk metrics. "]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?","Both","Cover note S.06.04 – Reporting requirement on investments exposed to physical risk\nWe do not support any thresholds to be included in the Solvency II package but that EIOPA/other stakeholder receive the data as part of the public disclosures made through the NFRD requirements, where applicable.\n\n","Public","Amice","Noted. EIOPA tends also to be of the view that materiality tresholds for the KPIs may be of limited supervisory value. We note note that the NFRD requirements do not require the corporate reporting of explict transition or physical risk metrics. "]
["Reporting","S.07.01","Both","S.07.01 – Structured Products – General Comments \nWe regret that EIOPA has decided not to amend the threshold to this template. We propose that the amount of structured products – measured as the ratio between assets classified as asset categories 5 (Structured notes) and 6 (Collateralised securities) as defined in Annex IV — Asset Categories of this Regulation and the sum of item C0010/R0070 and C0010/R0220 of template S.02.01,– is higher than 10%. \nMore clarity should also be provided regarding the instructions so that the template can be more easily completed.\n","Public","Amice","EIOPA disagres and keeps the template as it is. EIOPA further discussed the possibility to improve the threshold . The proposed threshold by the industry - s defined in Annex IV — Asset Categories of this Regulation and the sum of item C0010/R0070 and C0010/R0220 of template S.02.01,– is higher than 10% has been analysed. EIOPa consider current threshold to be adequate and will keep it.EIOPA disagrees with the deletion of items C120 to C190. "]
["Reporting","S.08.01","Both","S.08.01 – Open derivatives – General comments \nFurther guidance is needed as to the scope of this template (i.e whether it covers all derivatives or only the over-the-counter derivatives).\n","Public","Amice","It covers all derivatives"]
["Reporting","S.08.01","Both","S.08.01 – Open derivatives – C0340 & C0270 & C0371\nRegarding the cells C0340 (Counterparty group code) and C0270 (Counterparty code), is it correct to say that C0270 should be filled for all derivatives and C0340 only for OTC derivatives?\nC0371 (currency of price): For insurers reporting S.08.01 in Euro, suppose a cross-currency swap has been concluded between USD and GBP. EIOPA is asked to clarify what is to be reported in this field for this specific case. \nC0060 – there should be no NSA optionality regarding this template.\n","Public","Amice","Yes, it is correct. C0340 is only required for OTC as these are the cases where it is relevant to assess the risk at group level."]
["Reporting","S.09.01","Both","S.09.01 – Income/gains and losses in the period –  General Comments\nSolvency II is a prudential regime and it does not have a “profit or loss account”. The requested information duplicates information already provided in the financial statements. We reiterate the need of deleting this template. \n\n","Public","Amice","EIOPA disagrees. The template is kept as of today without introducing additional data."]
["Reporting","S.09.01","Both","S.09.01 – Income/gains and losses in the period – Portfolio –  C0050\nThere should be no NSA optionality regarding this template.\n\n","Public","Amice","This isn't a new requirement and the change in the instructions aims to clarify it's applicability, that is, to clarify what was the meaning of \"not mandatory\". In addition EIOPA would like to clarify that NSAs can request additional information regardless whether it is explicitly mentioned in the instructions or not. "]
["Reporting","S.10.01","Both","S.10.01 – Securities lending and repos – Portfolio –  C0050\nThere should be no NSA optionality regarding this template.\n\n","Public","Amice","This isn't a new requirement and the change in the instructions aims to clarify it's applicability, that is, to clarify what was the meaning of \"not mandatory\". In addition EIOPA would like to clarify that NSAs can request additional information regardless whether it is explicitly mentioned in the instructions or not. "]
["Reporting","S.11.01","Both","S.11.01 – Assets held as collateral – LoG document \nEIOPA-BoS-21-296 states: ‘1.8. Template S.11.01 - Assets held as collateral - the current threshold and the impact of the different options have been analysed but decided to keep as of today’. In the current situation there is no threshold. While 2450_ITS_reporting_consolidated_AnnexII_solo instructions_S.01_to_S.13.pdf states: ‘This template should be only reported annually when the ratio of the value of assets held as collateral to total balance sheet exceeds 10%.’ It seems that the two instructions do not match. EIOPA is requested to clarify.\n","Public","Amice","EIOPA has clarified. A threshold is proposed and the change is reflected in the Impact assessment."]
["Reporting","S.26.01","Both","•\tBoth for group and solo level: \n•\tSmall change, which may make sense to distinguish liabilities backed by Long Term Equity.\n\nNew cells, including R0205 / C0034 and C0035: What exactly is meant by insurance obligations that are sensitive to a long-term equity risk?","Public","GDV","Noted. R0205/C0034 and C0035 have been deleted"]
["Reporting","S.12.02","Solo","S.12.02 – Life and Health SLT Technical Provisions – General Comments \nWe welcome the decision to keep this template unchanged and the clarification regarding the negative technical provisions.\nSee our comments to S.04.03/04/05.\n","Public","Amice","Noted"]
["Reporting","S.12.01","Solo","Currently transitional deductions for technical provisions are possible and are also collected. In the future these transitionals will not be collected anymore on a quarterly basis but will however still be possible (Article 308d explicitly states the cases in which they are allowed). This will affect the cross-checking of S.12.01.02 and S.02.01.02 through BV382-388 and 390-391. According to these checks, the values for the balance sheet ITR - life (R0600+R0690) equal the total values in S.12.01 (R0200) and R0200 includes the transitionals (BV246-248, TP calculated as a whole + BE + Risk Margin + transitional). This might affect the data quality and might create problems with ESCB estimation procedures.","Public","ECB","Noted. Undertakings are expected to follow a similar process to derive quarterly and annual information on TPs. Therefore, EIOPA expects that ensuring data quality on annual basis is enough to maintaing data quality on quarterly basis. It should also be noted that the materiality of the transitional should decrease with time and eventually disappear. "]
["Reporting","S.26.01","Both","Template s.26.01.01 Market Risk Information with this level of details requires a considerable effort in terms of implementation. We suggest to reduce the level of details.\nThe internal model, approved by the NSA, is group/undertaking specific, therefore bespoken to the specific exposures and risk profile of the group/undertaking. A standard termplate could not be representative of the specific structure of the internal model and therefore oblige the group/undertaking to adapt its internal model output to the QRT structure requiring a significant effort. ","Public","Unipol Group","Internal Model users are not required to report S.26.01 for market risk if it is within the scope of the Internal Model. Instead, undertakings are expected to report the specific templates designed for Internal Model users (S.26.08 onwards)."]
["Reporting","S.02.01","Solo","The column C0030 and C0040 (Deductible/taxable temporary differences vs. tax base) in QRT S.02.01 would be costly to provide without a clear explanation of the use of such information for prudential purpouses. We also note that in several country there are more than one income taxes based on different definition of taxable profit. As a consequence the filing of such column would not be meaningful.","Public","Unipol Group","EIOPA recognises that there is a need of convergence in the area of LAC DT and introduction of the template could be a good step towards achieving it. However, considering stakeholders’ comments, EIOPA agrees in dropping the LAC DT templates from the ITS amendments 2021 package. Therefore, EIOPA will further work on convergence on LAC DT, including the templates which will be published in future ITS amendments. This includes the new columns in S.02.01 - BR-AG these are to be removed"]
["Reporting","S.14.01","Solo","S.14.01 – Life obligations analysis– Number of contracts at the end of the year – C0040\nWe welcome EIOPA´s clarification by which inactive policyholders have to be added with premium equal to zero or the last premium paid. \n\n\n","Public","Amice","Noted "]
["Reporting","S.14.01","Solo","S.14.01 – Life obligations analysis – number of contracts surrendered during the year of which surrendered within the first three years – C0053\nIn cell C0053 the “number of contracts surrendered during year of which surrendered within the first three years” is required. However further clarification is needed as to whether contracts which have been partially surrendered are the ones to be taken into account in this cell.\n","Public","Amice","Partial surrenders were not expected to be taken into account. Just note that EIOPA decided to delete this information from the template to reduce the implementation effort for undertakings."]
["Reporting","S.14.01","Solo","S.14.01 – Life obligation analysis – Portfolio product – C0061 to C0063\nEIOPA proposes to split the Gross written premiums by different distribution channels (i.e Direct business, Written via credit institutions, Written via other distributors). We query why such split is needed when the risk is not related to excessive commissions on gross premiums written by different distribution channels. As long as it is included in the Solvency II calculations, no unaddressed risks are foreseen.\n\n","Public","Amice","Information on the amount of  premiums written by distribution channels is essential to allow for an assessment of relevance of sales channels. Currently availble soruce of information on distribution channels are limited. The added information allows to determin the business models used to commercialise certain products and possible concentration risks. EIOPA notes that the new information required may be a burden. However this information is deemed necessary to assess concentration risks and determine the changing distribution patterns - i.e., more reliance on own channels. Moreover, information on written premium by distribuition channels should be already available to insurance undertakings as they should know the channels through which they are writing premium/selling certain products to monitor risks arising from distribution. This information for several Member States and in a more granular manner (i.e., more granulirity in terms of distribution channels) is published annually by InsuranceEurope itself showing that for several markets this information is available. Aware of the possible burden to undertakings, to strike a balance between supervisory needs and and limiting the reporting burden EIOPA has reduced the number of new cells by reducing the granularity required on premiums written by distribution channel, no longer requiring a split between regular and single premiums.  \n"]
["Reporting","S.14.01","Solo","S.14.01 – Life obligations analysis – administrative expenses – C0073\nThe allocation of administrative expenses per product level is not currently available in companies and it would be very difficult to estimate. The allocation of administrative expenses at any level – either by product or by HRG or at any other level - is always challenging. \n","Public","Amice","In view of the concerns expressed and the implementation effort required, EIOPA decided to delete the information on administrative expenses."]
["Reporting","S.14.01","Solo","S.14.01 – Life obligations analysis – Fiscal treatment – C0210\nEIOPA proposes to include a new closed-list cell on the fiscal treatment (i.e cell C0210). We query why this cell needs to be added. It is not clear how a change in the fiscal treatment would have an impact on the life obligations of the  insurance undertaking. Furthermore, an insurance undertaking would not be able to complete the requested information for all its policyholders. Some of the cells can only be based on certain assumptions (e.g 'all policyholders are residents of the home country and have a taxable income').\n\nFinally, we question whether through a closed list all relevant fiscal treatments would be captured. For example, in one jurisdiction there is no fiscal impact when the policyholder can find a similar insurer willing to accept the contract. Shall this situation be reported?\n\n","Public","Amice","The objective is to capture one of the fundamental elements that would (de)incentivise policyholders to surrender their policies in case of stress, potentially leading to liquidity crises. The use of assumptions is indeed an option. \nThe example mentioned, i.e. “in one jurisdiction there is no fiscal impact when the policyholder can find a similar insurer willing to accept the contract” would fall under option 1 “In case of lapse/surrender there is no tax or subsidy related loss” as explained in the LoG file. \n"]
["Reporting","S.14.01","Solo","S.14.01 – Life obligations analysis – expected future premiums – C0075\nEIOPA introduces two new cells C0075 and C0076 on expected future premiums. Insurers do not calculate the Best Estimate by product but by homogenous risk groups (HRG). The requested calculation would be extremely difficult if not impossible for most insurance companies. \n\n","Public","Amice","Expected future premiums are part of the determination of the best estimate and as such available. EIOPA acknowledges that the current granularity of the data may not allow to extract the information in the granularity required, i.e. by product and for new business separatley. To reduce the burden on undertakings, the information does no longer need to be provided for new business separately. Still, implemention effort is necessary to provide the information in the granularity provided. However, approximations may be used to allocate the premiums to the level of product categories."]
["Reporting","S.14.01","Solo","S.14.01 – Life obligations analysis – expected future premiums on new business – C0075\nEIOPA requests that this cell be populated with the effect of expected future premiums in the Best Estimate at product level. As indicated in the previous cell, insurers do not calculate the Best Estimate by product but by homogenous risk groups (HRG). Companies assess the impact of new business in the Variation Analysis template but the calculation is computed at HRG and not at product level.\n\n","Public","Amice","Noted - in view of the concerns raised, the information on expected future premiums for new business is no longer required."]
["Reporting","S.14.02","Solo","S.14.02.01 – Non-life business – policy and customer information – General Comments \nWe would like to reiterate that the Solvency II reporting package contains a significant number of QRTs which collect non-life information. We query the added value of the new proposed information on non-life products when the risk management and even the pricing process are not conducted at this level. \nWe appreciate that EIOPA has reduced the number of product categories and has simplified the amount of information requested, however the template would still be extremely difficult to produce at the requested granularity level.\n","Public","Amice","To reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n"]
["Reporting","S.14.02","Solo","S.14.02.01 – Non-life business - policy and customer information – Line of Business – C0020\nNon-life products are normally unbundled across different lines of business (LoBs). The requirements to insert a line for each of the LoB where the different components of the product have been allocated would be extremely burdensome and demanding for companies.\nFurther clarity is needed on\n• the definition of a product within the same product category \n• the requested granularity. \nExample: \n• are two supplementary health care policies from the same brand but with increasing coverage two different products?\n• What about two basic health care policies with the same coverage but with different names within the same entity, are they different products?\n","Public","Amice","To reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify."]
["Reporting","S.14.02",null,"S.14.02.01 – Non-life business - policy and customer information – For the products commercialised under this product category, which proportion (measured by gross written premiums) covers climate-related perils (0-100) ? –  C0033\nEIOPA is requesting information about the proportion of products commercialised under the product category (measured by gross written premiums) that covers climate-related perils. \nWe do not see the need to require information that it is being regulated under Article 8 of the Taxonomy Regulation to be disclosed via the NFRD.\n","Public","Amice","The proportion of GWP covering climate related perils is also an input for the corporate reporting by non-life undertakings when reporting the KPI related to underwriting activities on the amount of environmentally  sustainable non-life underwriting, as per Art. 8 of the Taxonomy Regulation TR (see link below). It is proportionate to ask companies to report this also for other purposes, and prudentially relevant, as it can contribute to establishing insurance penetration rates for certain perils.  "]
["Reporting","S.14.02","Solo","See our comments above.","Public","Amice","Noted"]
["Reporting","S.14.02","Solo","S.14.02 – Non-life business - policy and customer information – Total amount of Gross Written premiums – C0070 to C0090\nThe split of gross written premiums between “written directly by the undertaking”, “written via credit institutions” and “written via insurance distributors other than credit institutions” will not fit health entities subject to the equalisation system in the Netherlands.\n","Public","Amice","The template has been significantly simplified and thus threshold has been assessed as not needed."]
["Reporting","S.14.02","Solo","S.14.02.01 – Non-life business - policy and customer information – Country – C0010\nEIOPA defines this cell as “country where the contract was entered into\" whereas in S.04 the country cell is defined as  “the country in which the risk is situated\" and “the country of location of underwriting”. Further clarification is needed as to whether all these different definitions should be aligned.\n","Public","Amice","As per instruction the relevant country refer to Country ISO 3166–1 alpha–2 code or list of codes according to the following instructions: \n- ISO 3166–1 alpha–2 code of the country where the contract was entered into, for countries representing more than 10 % of technical provisions or written premiums for a given product. \n- For countries representing less than 10 % of Technical Provisions or written premiums for a given product, report a list of ISO 3166–1 alpha–2 Codes of the countries concerned.\n"]
["Reporting","S.14.03","Solo","S.14.03 – Cyber risk – General Comments \nEstablishing a common terminology for cyber risk is imperative for firms in quantifying and managing their cyber risk exposures. One common problem is the use of the term ‘cyber risk’ to refer to what in fact is a threat, rather than a risk. The risks caused by cyber threats are of types that are already known – for example, reputational damage, business interruption, theft and fraud. \nWe believe that the impact of cyber risk on insurance will vary a lot across the industry; We do not think that cyber risk constitutes a new line of business. It will represent either property, surety or liability risk and can be handled in a conventional matter. This could be covered in the ORSA - where appropriate and deemed to be a material risk exposure for the company in question.\nWe believe that cyber risk could be part of a thematic review similar to the one launched by EIOPA aimed at better understanding travel insurance products.      \nReporting on cyber risk may be justified for companies which develop a significant exposure. An overall threshold on premium income and / or MPL should apply for the mandatory reporting of the template (as already proposed by EIOPA for several existing QRTs in the consultation paper on supervisory reporting).\n• Detailed reporting should be limited to affirmative cyber exposure within industrial or commercial lines. It may be sufficient to report on the top risks in detail and the overall risk in aggregate. The restriction on top risks and aggregated reporting of overall risk is already good practice in the existing QRTs S.21.02 and S.21.03 and sufficient for cyber risk. \n• Non-affirmative cyber risk on commercial and industrial lines should be reported on an aggregated basis if it exceeds a certain MPL threshold. \n• Non-affirmative cyber risk on private line business should not be reported at all; it should be sufficient to cover the risk in the ORSA where relevant and material.\n• Affirmative cyber risk on private line business should be reported on an aggregated basis only, provided it exceeds a certain MPL threshold. There is a huge number of relatively small risks so that the risk is more of a cumulative nature which is completely captured by aggregated reporting. If the threshold is not met, it should be handled in the ORSA where relevant and material.\n\n","Public","Amice","EIOPA disagrees. Infrmation is onsidered important and EIOPA believes that even more granular information should already be available to undertakings for their internal risk management purposes. Regarding threshold, please note that such have been included in the instructions."]
["Reporting","S.16.01","Solo","S.16.01 – Information on annuities stemming from Non-Life Insurance obligations – General comments \nWe propose that this template not be reported when the best estimate on the annuities stemming from non-life insurance obligations is less than 10% of the total amount of best estimate. This threshold would be in line with the one proposed for S.19.01, S.20.01 and S.21.01.\n\n","Public","Amice","EIOPA disagrees as from the analysis performed it was proposed to keep the current approach and percentage as any other change will not make a technical difference."]
["Reporting","S.12.01","Both","S.12.01 – Life and Health SLT Technical Provisions – EPIFP\nEIOPA proposes to simplify the quarterly template S.12.01 by deleting the information on the transitional measures. We agree with this proposal. However, EIOPA is requesting firms to report the EPIFP by Lob or HRG. Such information is already been reported in the RSR according to Article 309 of the Delegated Regulation. We question why there is a need to introduce the EPIFP at this level in the QRTs. We propose that \n• a threshold on the EPIFP per LoB is included. \n• an alternative/combination with a threshold per LOB could also be a EPIFP / OFs threshold - e.g. where EPIFP is > 10% of OFs, additional disclosure should be made - but only in relation to material LOBs (e.g. those that make up 75-90% of the total EPIFP).\n","Public","Amice","The information included in the RSR is frequently included in the QRTs as the objective of both reports are different. In any case, this shows that the information is relevant and undertakings are able to provide it, so it should not create any relevant buden for the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually. "]
["Reporting","S.17.02","Both","S.17.02 – Non-life technical provisions by country – General comments \nSee our comments to S.04.03/04/05.\n\n","Public","Amice","See the resolutions of the comments in their section."]
["Reporting","S.20.01","Solo","S.20.01 – Development of the distribution of the claims incurred – Threshold\nAs for S.19, we welcome EIOPA’s proposal to introduce a threshold for this template but the proposed threshold is still very high and it would not exempt the reporting of non-material LoBs; We suggest lowering this threshold so that it represents 80% of the total best estimate.\n\n","Public","Amice","EIOPA disagrees of reducing the threshold to 80% and keeps the 90% as publicly consulted based on the impact assessment."]
["Reporting","S.21.01","Solo","S.21.01 – Development of the distribution of the claims incurred – Threshold\nWe welcome EIOPA’s proposal to introduce a threshold for this template but the proposed threshold is still very high and it would not exempt the reporting of non-material LoBs; We suggest lowering this threshold so that it represents 80% of the total best estimate.\n\n","Public","Amice","EIOPA disagrees. Based on the impact assessment the threshold is kept as publicly proposed of 90%."]
["Reporting","S.23.01","Group","S.23.01 – Own Funds – Foreseeable dividends, distributions and charges \nIn cell C0060/ R0720, EIOPA introduces a definition on foreseeable dividend which deviates from the guidelines of EIOPA on the own funds. Foreseeable dividends are recognised when the proposal is declared by the AMSB. The industry does not see a need to change the definition of foreseeable dividends and proposes to stick with the original explanation.\n","Public","Amice","EIOPA disagrees. The information is alignes also with the Q&A 1701 on this topic."]
["Reporting","S.23.02","Both","S.23.02 – Detailed information by tiers on own funds – General Comments\nWe welcome the deletion of the cells related to the “excess of assets over liabilities” and other items. This deletion should also be extended to the group template. However, in our view the requested information does not provide any additional insights on the own funds which are not already submitted either as part of the RSR or in other templates. \n\n\n","Public","Amice","Information regarding the excess of assets over liabilities has been deleted from the solo reporting due to its complexity in relation with specificities of each local accountancy GAAP .  This complexity can be avoided at group level thanks to the common  use of IFRS.  Furthermore this information is still considered very useful to understand  the amount of own funds created by the SII valuation rules."]
["Reporting","S.23.03","Both","S.23.03 – Annual movements on own funds – General comments\nWe regret that EIOPA has decided to lower the proposed threshold during the public consultation and requires this template to be submitted if the own funds change per tier is more than 5% compared to the previous year calculated as below”. We request to increase the threshold to 10%. \n\nMoreover, we query the intended use of this template for prudential supervision: We believe that this template is in any case of limited use and it should be deleted.\n\n","Public","Amice","The methodology of the threshold has been changed cmpared to the one publicly consulted where EIOPA received comments that the threshold will be difficult to be calculated. EIOPA disagree to increase the threshold to 10% considering also the outcome of the impact assessment."]
["Reporting","S.23.04","Both","S.23.04 – List of items on own funds – General comments\nSee our comments above. However, we believe that this template is of limited use and should be deleted.\n\n","Public","Amice","EIOPA disagrees."]
["Reporting","S.23.01","Both","S.23s – Own Funds – Subordinated liabilities \nThe information on subordinated liabilities has to be reported in different own funds related templates. We request that EIOPA consolidates all the related information in one single template.\n","Public","Amice","Consolidation would need changes in many templates. The idea is to keep different kind of information corresponding to different perspectives  in different templates"]
["Reporting","S.13.01","Solo","S.13.01 – Projection of future gross cash flows – LoG file\nThe LoG file to S.13 states that \"it should be noted that the projection horizon of future cash-flows should be realistic and it is not limited by contract boundaries….Instead, realistic projections should be reported in case it is valued as best estimate plus risk margin.\". This information is not consistent with the information requested regarding the balance sheet or other QRTs. \n\n","Public","Amice","The sentence highlighted is not a change, but a clarification. Undertakings are expected to report realistic cash flows for BE valuation as long as the BE is calculated through cash flow discounting. If the undertaking uses a calculation method that does not imply projecting future cash flows for the UL, then there is no need to report the template. If the undertaking uses a caluation method that requires projecting future cash flows, then the cash flows included in the BE should be reported. However, since this particular topic has been covered in the Guideline 0 on Contract Boundaries, EIOPA will delete the paragraph to avoid any confusion."]
["Reporting","S.13.01","Solo","S.13.01 – Projection of future gross cash flows – Total recoverables by LoB\nEIOPA proposes to add a cell on  “Total recoverables by LOB”. Guidance is needed as to how reinsurance recoverables covering multiple LoBs would have to be treated. \nThe request to report the value of the ‘total recoverable from reinsurance’ by LoB ’ is burdensome  from a practical and technical point of view and will provide limited additional benefits.\n\n","Public","Amice","Undertakings should follow an approach that is consistent with the approach already followed to unbundle the recoverables by line of business."]
["Reporting","S.25.05","Both","S.25.05 - Solvency Capital Requirement - for undertakings using an internal model (partial or full)\nEIOPA introduces the term \"market risk & credit risk\" in row R0070. This terminology is confusing as it does not relate to a category of the Solvency II legislation. Normally, credit risk is part of market risk. \nIn row 270, EIOPA introduces the term business risk, however EIOPA is not providing any definition and multiple interpretations can be used. EIOPA is asked to clarify how this would provide additional information.\nIn row 310, EIOPA introduces the term “net non-life risk”. EIOPA is asked to clarify how \"net\" is defined in this cell.\n","Public","Amice","In some internal models market and credit risk is calculated in different modules so EIOPA proposes this terminology to avoid confusion.\n\nSome UTs have a definition for business risk. EIOPA does not want to impose a definition. If the internal model supports it then it has to be reported.\n\n'Net' is defined as net of reinsurance."]
["Reporting","S.26.01","Both","S.26s – Internal Model – General Comments \nThe additional information requested by EIOPA would be very burdensome to collect. Internal model users already submit internal model information as agreed with their supervisory authorities and EIOPA also publishes benchmark studies for market risk on a yearly basis which capture very similar information. We do not see the need to report further information on internal models.\n\n","Public","Amice","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.08","Both","S.26.08 – Internal Models – Company specific information and S.26.09 – Internal model - Market & credit risk and sensitivities \nEIOPA asks for a split (this is also done for other risk types) between interest rate risk and interest rate volatility risk. However, not all internal models are modelled in such a manner that these risks can be isolated. EIOPA’s request should not lead to changes being required in internal models. Therefore there should be a possibility to disregard those cells provided the internal model does not accommodate such a split. The same comments apply to the split requested within credit spread and equity risk.\n\nFurthermore, EIOPA should explain all its requests in a more explicit manner and apply clearer definitions as to what is expected and how the terminology and methodology is defined. The proposed templates should encompass more flexibility to allow for the differences in the methodological components of the various internal models.\n\n","Public","Amice","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.08","Both","S.26.08 – Internal Models –  SCR for undertakings using an internal model – LoG files\nIn the logfiles EIOPA points out that \"all components that are supported by the model structure shall be reported. The components to be reported shall be agreed between national supervisory authorities and insurance and reinsurance undertakings.\" We find it difficult to see the purpose of completing these templates if the scope is left to NSAs and insurers.\n","Public","Amice","The scope of the templates is not changing. The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported."]
["Reporting","S.26.08","Both","S.26.08 – Solvency Capital Requirement - for undertakings using an internal model – pension risk – R0250\nIn row R0250 EIOPA introduces a new risk type \"pension risk\". We query why this is in line with the Solvency II standard formula taxonomy. Despite the fact that pension risk may be a recognised feature by some insurers, it should not be introduced as a general feature.\n","Public","Amice","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported.\n\nIt is not clear why the SF taxonomy should be used for internal models as it might not be representative. If pension risk is part of the internal model then it shall be reported."]
["Reporting","S.26.09","Both","S.26.09.01 – Internal model - Market & credit risk and sensitivities \nEIOPA states that \"these figures should correspond to impact on the ‘net asset value’ associated\". In other cells and templates and even in the next sentence reference is made to BOF. EIOPA is asked to clarify the definition of net asset value. \nEIOPA states \"mVaR 99.50% without volatility adjustment (VA) and without transitionals\". EIOPA is asked to clarify whether this implies that it should also be reported without DVA. \nEIOPA requests insurers in scope of these templates to provide several sensitivities. However, these sensitivities are not aligned with EIOPA´s proposals for a standardised set of sensitivities to be included in the SFCR. We request EIOPA to align the sensitivities to avoid an increase in the administrative burden.\n","Public","Amice","Net asset value' sentence has been amended in the LOG file in order to avoid confusion.\n\nYes, DVA is also excluded.\n\nThe standardised sensitivities proposed by EIOPA for the SFCR are not part of the ITS amendments. This is under review and depends on the COM proposal and if changes are needed they will be included in another ITS amendment."]
["Reporting","S.26.13","Both","S.26.13.01 – Internal model – Non-life & Health non-slt \nFor internal model users additional information is requested regarding the percentiles. In premium risk EIOPA is requesting the percentiles of the loss distribution whereas for reserve risk firms will have to submit percentiles of the future cash outflows relating to claim events. Moreover, regarding the aggregation of premium-reserve risk the percentiles of future cash flows relating to claim events are being  requested; And related to disability risk, firms will have to submit the percentiles of the required capital distribution. \nCan EIOPA confirm whether this is a correct interpretation of the information to be requested? \n","Public","Amice","Profit and loss distributions are expected. Please send clarifications on what is meant by 'future cash outflows' and 'capital distribution'."]
["Reporting","S.26.16","Both","S.26.16 – Internal Model – Model Changes – CREDIT FinInstr risk impact & CREDIT NonFinInstr impact – C0090 & C0100\nThe is no clear rationale for the information requested in cells C0090 and C0100. Further guidance is required as to the need of breaking down each major change to its subcomponents and the risk areas impacted. \nWe query how this would be consistent with the whole process of obtaining approval and the supervisory review process already in place. Moreover, the split into the sub-components is arbitrary.\n\n\n","Public","Amice","C0090 and C0100 are Yes or No columns indicating whether the major model change impacts these specific risks."]
["Reporting","S.29.05","Solo","S.29.05 –  Non-life – Variation analysis templates – General Comments \nWe welcome the separation of the variation analysis template between life and non-life business. However, EIOPA’s Proposal for VA for non-life is more granular than the current template and it will be very costly to implement.\nThe added value from the new QRT S.29.05 is not clear and therefore should not be introduced. Building up an harmonized VA template is difficult; In the past the VA QRTs (current templates S.29.01-S.29.04) were subject to criticism as they pose a real challenge, both for undertakings and supervisors. \nAlso it should be noted that few years after the first implementation of the Solvency II reporting package, EIOPA introduced major changes to the VA QRTs and the LOGs files, thus radically altering the information being requested. In this regard, the costs of harmonized VA templates outweigh the benefits/merits. \nTherefore, we believe that at this stage the current QRTs should remain unaltered and no new QRTs be introduced. EIOPA should also consider whether the current templates S.29.01-S.29.04 could be removed completely. Where relevant and material to explain the variation of the excess of assets over liabilities between reporting periods, it is perhaps better to request that firms, on an ad hoc basis, submit the analysis of change they are using for internal reporting and other management proposes. While not aggregated or collected in a harmonised manner, we believe this data/information would likely provide more insights into the movements in the EoAoL than it is currently the case with the VA templates – this would likely also be less burdensome for undertakings to submit. \nThe proposed adjustments to capture composites with both life/non-life seems overly complex. A proportional approach should therefore be taken - i.e. introduce thresholds to determine whether disaggregation is actually required.\n\n","Public","Amice","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Solo","S.29.05 – Non-life – Variation analysis templates \nThere is a lack of a clear link between the items in table 1 of S.29.05 and those that are detailed in table 2, table 3 and table 4. In some cases, there is not a one to one relation; it would therefore be extremely useful if EIOPA could indicate how to reconcile the first table with the other tables.\n\n","Public","Amice","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Solo","S.29.05 – Non-life – Variation analysis templates –  Instructions – Analysis of undiscounted movements – Removal of future premium on past business at the opening date\nIn the table “Analysis of undiscounted movements - analysis per AY/UWY if applicable” EIOPA introduces a new cell “Removal of future premium on past business at the opening date”. Guidance is needed as to the intended purpose of such removal.\n\nMoreover, the instructions define this cell as the Amount of future premiums as reported in S.18.01 C0070 and S.13.01 on annuities stemming from Non-life at year N-1 on an aggregated level for the corresponding LoB. We believe there is a typo and it should be read as follows: “Amount of future premiums as reported in S.13.01 and S.18.01 on annuities stemming from Non-life at year N-1”.","Public","Amice","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.29.05","Solo","S.29.05 – Non-life – Variation analysis templates – Variation of the claims provision due to changes in experience and actuarial assumptions-prior years – R0100\nIn the previous analysis of change template (S.29.03.01.03) there was a distinct row regarding the non-economic assumptions, however the row has disappeared from the table. Could EIOPA indicate whether the non-economic assumptions should be considered as actuarial assumptions in cell R0100?\n","Public","Amice","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.30.01","Solo","S.30s – Reinsurance templates – General Comments – Threshold\nWe welcome the reduction of scope of the templates, however, the set of reinsurance templates is still very granular and it is difficult to understand why such level of detail is really needed. The rationale for such granularity is not provided in EIOPA´s consultation package. We reiterate that more clarity is needed as to the purpose of these templates for prudential supervision.\nWe agree that the threshold proposed during the 2019 public consultation was very complicated, however we do not agree with EIOPA’s decision to remove the threshold completely.\nThe reinsurance templates are very burdensome for our small and medium sized membership. We reiterate the need to introduce a simplified threshold by which insurers with a ratio of recoverables over the best estimate below 10% should not report the template. \n\n","Public","Amice","EIOPA understands the burden that this templates may create, although a proper understanding of the reinsurance strategy is also a key element for supervisors. For this reason, a prudent threshold has been included. "]
["Reporting","S.30.01","Solo","S.30.01.01 – Reinsurance templates – Facultative covers for non-life and life business basic data\nEIOPA proposes to reduce the scope of the templates to the overall 20 largest facultative reinsurance exposures plus the largest two in each line of business if not covered by the largest 20 (in line with template S.21.02); We understand that the proposed simplification would not reduce the workload significantly. We propose instead that the threshold is redefined so that only the 20 largest facultative reinsurance exposures are reported.\nFurther guidance is needed as to whether EIOPA is referring to a completed facultative treaty or also to tranches of a facultative treaty. \n\n","Public","Amice","EIOPA agrees this could be unduly burdensome for undertakings with low amounts of reinsurance recoverables.\nHowever, EIOPA considers that this redefinition of the scope together with the threshold under assessment will significantly reduce the burden for undertakings, while still allowing to have a minimum overview of the main risk transfers by LOB."]
["Reporting","S.30.01","Solo","S.30.01.01 – Reinsurance templates – C0180&C0330\nWe welcome EIOPA´s proposal to delete cells C0180 and C0330 related to commissions.\n","Public","Amice","Noted"]
["Reporting","S.30.01","Solo","S.30.01 – Reinsurance templates – Description of operation of the facultative reinsurance item – C0045\nEIOPA is proposing a replacement of cell C0045 by a cell with the description of operation of the facultative reinsurance item (e.g. how to apply this cover). EIOPA is proposing a free text but further guidance is needed as to how this cell should be fulfilled. Our preference is that EIOPA provides a closed list.\n","Public","Amice","This cell has been deleted."]
["Reporting","S.30.02","Solo","S.30.02 – Reinsurance templates – Facultative covers – Shares \nWe welcome the proposal for the deletion of the broker info (i.e. cells C0370/C0380/C0390).\n","Public","Amice","Noted"]
["Reporting","S.30.03","Solo","S.30.03.01.01 – Reinsurance templates – Outgoing Reinsurance Program in the next reporting year – Basic – Coverage of a layer covered by reinsurance – C0420\nEIOPA proposes to add a field to address the coverage of a layer by reinsurance. Such information might be difficult to extract.\n","Public","Amice","Noted. However, this information will allow a better understanding of each reinsurance structure."]
["Reporting","S.30.03","Solo","S.30.03 – Reinsurance templates – Outgoing Reinsurance Program in the next reporting year – Basic – Order of claims within the reinsurance program – C0430\nEIOPA proposes to add a field to address the order of claims within the reinsurance program. Further guidance is needed on the information to be reported in this cell.\n","Public","Amice","This cell has been deleted."]
["Reporting","S.30.03","Solo","S.30.03 – Reinsurance templates – Outgoing Reinsurance Program in the next reporting year – Basic – “Minimum claim ratio”\nEIOPA proposes to add a field to report the minimum and maximum and the expected commission and it also proposes to delete the fields C0270 to C0350 (i.e details on reinsurance commissions). \nEIOPA also proposes the deletion of all former cells from C0270 to C0350 and the addition of new cells on the Minimum commission (C0440), Maximum commission (C0450) and the Expected commission (C0460); \nFurther clarification is therefore needed as to why such information will be required.\n","Public","Amice","As in the past, EIOPA considers that information on commissions is a main element of reinsurance contracts. Indeed, the current Opinion on the use of risk mitigation techniques highlights this particular element. The changes included by EIOPA only reflect a streamlined approach to gather the relevant information, which should ease the reporting process for undertakings and facilitate the analysis for EIOPA.\nPlease note that EIOPA proposed a threshold in this template."]
["Reporting","S.33.01","Group","S.33.01 – Insurance and Reinsurance individual requirements – Contribution of solo SCR to the group SCR – C0270\nWe request EIOPA to provide more background information as to why this change has been proposed.\n","Public","Amice","The purpose of the data in this template is to provide information to supervisors that improves the assessment of availability of own funds as well as that faciliates assessing the amount of diversification effects."]
["Reporting","S.34.01","Group","S.34.01 – Other regulated and non-regulated financial undertakings including insurance holding companies and mixed financial – Contribution of solo (notional) SCR to group SCR – C0085\nIn the LoG document, EIOPA has included the explanatory text of the S.33 template, whereas this is not the scope of the S.33 template.\n\n","Public","Amice","It is in the scope for IHC and MFHC"]
["Reporting","S.36.01","Group","S.36s – Intra-group transactions & S.37s – Risk concentration – General comments\nSome consideration should be taken by EIOPA that not all undertakings covered by S.36/S.37 will also be covered by the FICOD templates. The current proposal should not be required in the case of groups that do not form a financial conglomerate, i.e. groups which operate solely or mainly in the insurance sector. We request that those undertakings which \"operate solely or mainly\" in the insurance sector report using the current templates. \nThe S.36s templates require reporting of all intra-group transactions distinguishing between significant, very significant and transactions required to be reported in all circumstances. We request to only report based on significant and not significant intra-group transactions.\n\n","Public","Amice","EIOPA clarifies that the changes to S.36 and S.37 templates were not only introduced in order to align the template with the financial conglomerate ones but also to better align the reporting to the supervisory needs. The new additions are also relevant for insuance groups. Reporting requirements which are peculiarities of the financial conglomerate have been removed.                                                                                               EIOPA confirms that that the significant IGTs are supposed to be reported regularly, on annual basis and that the very significant IGTS and IGts to be reported in all circumstances will  be still reported on ad hoc basis, as soon as practicable."]
["Reporting","S.36.00","Group","S.36.00 IGT – Summary template – General comments\nWe do not see the added value of introducing this new template. This template should be removed.\n","Public","Amice","Please note that this template has been removed."]
["Reporting","S.36.01","Group","S.36.01/S.36.02 – Intra-Group Transactions – C0031\nFor these templates fields are given a different code (e.g old code C0040 in S.36.01 becomes C0031) or new data to be reported is being requested using existing codes (e.g “C0040: sector of the investor/lender” in existing code “C0040: ID code of the investor/lender”). This creates a lot of additional administrative burden and costs. We request that EIOPA develops a less onerous alternative.\n","Public","Amice","Amended"]
["Reporting","S.36.01","Group","S.36.01/S.36.02– Intra-Group Transactions – Indirect transactions – C0080 and Single economic operation – C0090\nEIOPA is asked to clarify whether the fields “Indirect transactions – C0031” and “Single economic operation – C0090” are mutually exclusive, and to provide an exact definition of an indirect transaction.\n","Public","Amice","For the purpose of reporting the two fields of  indirect transactions and single economic operations are to be filled in as mutually exclusive.\nAbout the definitions, indirect transactions are normally identified as a chain of transactions shifting risk exposures between entities within the group including but not limited to transactions with special purpose vehicle, collective investment undertakings, ancillary entities or unregulated entities; or with entities outside of the group but ultimately risk exposure is brought back or stays within the group and impacts the solvency position of any insurance undertaking of the group. While, where two or more transactions between entities of the group which, from an economic perspective, contribute to the same risk, or, serve the same purpose / objective or are temporally connected in a plan, they shall be considered as a single economic operation. "]
["Reporting","S.36.02","Group","S.36.02.01 – Intra–Group Transactions – Associated P&L – Revenues stemming from derivatives – C0260\nThe revenues stemming from derivatives is new. EIOPA is asked to clarify what this entails. Interest will be reported in FC.05 P&L; Could EIOPA elaborate further on FC.05 P&L and what the connection is with the field C0260?\n","Public","Amice","EIOPA confirms that although interest, dividends are reported in S.36.01, S.36.02 they must be reported additionally in S.36.05 P&L. The double reporting is expected to be of limited burden."]
["Reporting","S.36.05","Group","S.36.05.01– Intra-Group Transactions – P&L\nIt will be useful to specify what is considered as “significant intra-group P&L transaction” so that the P&L intra-group transactions that have to be reported are reasonable. \n\n","Public","Amice","The thresholds which provide the break down between significant and not significant IGTs should be set by the group supervisor, set individually for every group taking into accout all elements listed in DR. "]
["Reporting","S.37.02","Group","S.37.02 – Risk Concentration – Exposure by currency, sector, country – General comments \nWe query which is the added value of the additional information requested in S.37.02 and S.37.03 in addition to S.37.01. The template is to be used to assess the risk concentration at a global level.\n","Public","Amice","Eiopa confirms that the template is to be used to assess the RC at global level"]
["Group reporting questions",null,"Group","S.37.01 (C0260) Information on Credit or insurance risk mitigation techniques\nOptions for consideration: Three options are currently considered as possible options to solve the issue described above. Additional options that may serve the objectives can be offered to EIOPA’s consideration. \nOption 1: A proportional break-down of the capacity of the treaty among the counterparties. It may be ‘practical’ from an operational point of view but is very arbitrary, artificial and does not fit the aim.\nOption 2: Application of simulations to see how in chosen scenarios the reinsurance treaty may work. This option has a dependency on the selecting adequate and consistent scenarios. It is quite burdensome for the aim of the reporting and may impair data comparability across groups. \nOption 3: Not applying such contracts in the presentation of the net exposure, but supplementing the template with the narrative information about the reinsurance contracts encompassing the reported exposures. This option is currently applied in one Member State. It gives the supervisor an idea of the actual reinsurance protection of the significant exposure. However, it is difficult to carry out a proper analysis. Thus, this option is also not deemed as an appropriate solution for the template which should present risk concentration.\nWe favour Option 1: A proportional break-down of the capacity of the treaty among the counterparties.\n\n","Public","Amice","Noted. Based on the inputs received, the selected option for S.37.01 is option 1 with some changes: „proportional or otherwise justifiable break-down agreed with the group supervisor“"]
["Financial stability guidelines",null,"Both","Financial Stability Reporting – General Comments\nWe welcome the proposed deletion of some templates, however the new additions and increase in frequency of some of the QRTs would increase the burden for undertakings.\nLiquidity templates\nEIOPA introduces the liquidity templates S.14.04 and S.14.05 as group templates that will have to be submitted on a quarterly basis. In order to complete the template at group level, the group needs the information at solo level. However, according to EIOPA´s proposal the solo level information will have to be submitted on an annual basis only (i.e S.14.02.01). This requirement would therefore imply an increase in reporting frequency. We query whether our understanding is correct and EIOPA identified this issue. The granularity of the new liquidity templates will significantly increase the administrative burden. For example new pointers will have to be added to be able to generate the new granularity. Furthermore the proposed categories will lead to arbitrary decsions as to the unbundling of existing products into the new product classes proposed by EIOPA.\nDuration of liabilities\nWe share EIOPA’s view that the duration concepts used for assets and liabilities could be aligned, and we support the proposal to use the modified duration for both assets and liabilities. The effective duration is particularly challenging to calculate for liabilities, especially in life guarantee business. We do not see an added value in providing the effective duration that would justify the significant additional effort.\n\n\n","Public","Amice","We acknowledge the fact that most of the groups manage the liquidity at solo level. Nevertheless, in order to avoid a granular reporting at solo level, it was decided to include the liquidity information at group level in the Financial stability templates.\n\nIn order to reduce the burden for insurance undertakings, EIOPA proposes the following changes in the reduction in frequency and granularity of the liquidity information: S.14.04 (Life) is to be reported semi-annually (instead of quarterly) at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) and S.14.05 (Non-life) is to be reported semi-annually (instead of quarterly) for the non-life business as a whole (instead of product or LoB category). \n\nFrom the feedback received for S.38, Option 1 will be implemented. Therefore effective duration will only be required to be calculated in addition to the modified duration where material optionalities are present in the technical provisions. "]
["Financial stability guidelines",null,"Group","S.02.01 – Balance sheet \nEIOPA is amending S.02.01 – balance sheet for groups – to include a statutory column on a quarterly basis. Adding this column will be extremely challenging given the shorter deadlines (7 weeks for quarterly reporting). Moreover, we query the added value of such additional information. \n","Public","Amice","The statutory accounts in template S.02.01 (Balance sheet) should be reported with an annually frequency and not quarterly. As stated in the errata of the Guidelines on reporting for Financial Stability Purposes, the template S.02.02.01 has been ameded by template S.02.01.01, with the inclusion of the statutory accounts in an anually frequency, correspondly to the prudential reporting.\n\nAt the same time, EIOPA acknowledges that the financial stability figures, considering the shorten reportinf deadlines (7 weeks), are reported on a best effort basis, and could marginally differ from the figures reported in the prudential reporting."]
["Financial stability guidelines",null,"Both","S.14.04.11.01 – Liquidity risk for life business – Portfolio  – Product ID code – C0010\nFurther clarification is needed as to whether S.14.04.11.01 includes the cell C0010 – Product ID code. Such code is not included in S.14.05.11.01.\n","Public","Amice","The liquidty template S.14.04 (Life) is to be reported now at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level) "]
["Financial stability guidelines",null,"Both","S.14.04.11 – Liquidity risk for life business – Total amount of claims paid (year to date) – C0070\nThe information related to the total amount of claims paid (year to date) is available only on an accrual basis. Therefore we suggest to be allowed to produce the information related to these items on an accrual basis.\n","Public","Amice","The reporting of the item on an accrual basis will not facilitate the adequate supervision of liquidity risk. Moreover, the change in granularity should assist in the availability of this information. "]
["Financial stability guidelines",null,"Both","S.14.04.11 – Liquidity risk for life business – Cashed premium – C0290\nIn the new life liquidity template S.14.04.11, EIOPA introduces a new item cashed premium which is normally only available on an accrual basis. This is a new data field which will require a significant administrative burden. Should EIOPA go ahead with these changes, the industry would deem it reasonable to include a proxy which can be used to complete this cell in order to allow for a proportionate approach.\n","Public","Amice","The reporting of the item on an accrual basis will not facilitate the adequate supervision of liquidity risk. Moreover, the change in granularity should assist in the availability of this information. "]
["Financial stability guidelines",null,"Both","S.14.04.11 – Liquidity risk for life business- Administrative expenses – C0074\nThe allocation of administrative expenses per product level is not currently available in companies and it would be very difficult to estimate. The allocation of administrative expenses at any level – either by product or by HRG or at any other level - is always challenging.\n","Public","Amice","The liquidity template S.14.04 (Life) is to be reported now at Unit-linked or index-linked/Neither unit-linked nor index-linked (instead of product level). Further, the administrative costs can be apportioned in a management accounting approach."]
["Financial stability guidelines",null,"Both","S.14.04.11 – Liquidity risk for life business – Best estimate – C0180\nEIOPA introduces this new cell C0180 where it requests the amount of gross best estimate calculated by product. Insurers do not calculate the best estimate by product but by homogenous risk groups (HRG). The requested calculation would be extremely difficult if not impossible for most insurance companies subject to financial stability reporting.\n","Public","Amice","Noted. The change in the granularity of the liquidty template should assist in the availability of this information. "]
["Financial stability guidelines",null,"Both","S.14.04.11 - Liquidity risk for life business – Fiscal treatment – C0210\nEIOPA proposes to include a new closed-list cell on the fiscal treatment. We query why this cell is needed. It is not clear how a change in the fiscal treatment would have an impact on the life obligations of the insurance undertaking. Furthermore, an insurance undertaking will not be able to complete the requested information for all its policyholders. Some of the cells can only be based on certain assumptions (e.g all policyholders are residents of the home country and have a taxable income').\n\nFinally, we question whether through a closed list all relevant fiscal treatments would be captured. For example, in one jurisdiction there is no fiscal impact when the policyholder can find a similar insurer willing to accept the contract. Shall this situation be reported?\n\n","Public","Amice","The objective is to capture one of the fundamental elements that would (de)incentivise policyholders to surrender their policies in case of stress, potentially leading to liquidity crises. The use of assumptions is indeed an option. \nThe example mentioned, i.e. “in one jurisdiction there is no fiscal impact when the policyholder can find a similar insurer willing to accept the contract” would fall under option 1 “In case of lapse/surrender there is no tax or subsidy related loss” as explained in the instruction document. \n"]
["Financial stability guidelines",null,"Both","S.14.05.11 – Liquidity risk for non-life business – Line of Business – C0020\nNon-life products are normally unbundled across different lines of business (LoBs). The requirements to insert a line for each of the LoB where the different components of the product have been allocated, would be extremely burdensome and demanding for companies.\n","Public","Amice","Noted.  EIOPA proposes to reduce the granularity for S.14.05 (Non-life), to be reported for the non-life business as a whole (instead of product or LoB category). "]
["Financial stability guidelines",null,"Both","S.14.05.11 – Liquidity risk for non-life business – Best estimate – C0180\nEIOPA introduces this new cell C0180 where it requests the amount of gross best estimate calculated by product. Insurers do not calculate the Best Estimate by product but by homogenous risk groups (HRG). The requested calculation would be extremely difficult if not impossible for most insurance companies subject to financial stability reporting.\n","Public","Amice","Noted.  EIOPA proposes to reduce the granularity for S.14.05 (Non-life), to be reported for the non-life business as a whole (instead of product or LoB category). "]
["Financial stability guidelines",null,"Both","S.14.05.11.01 – Liquidity risk for non-life business – Portfolio\nEIOPA does not provide any link between S.14.05.11.01 – Portfolio and S.14.05.11.02 – Portfolio detail; further clarification is therefore needed.\n","Public","Amice","In order to reduce the burden for insurance undertakings, EIOPA proposes the reduction of granualrity for the liquidity templpates S.14.04 and S.14.05"]
["Financial stability guidelines",null,"Both","S.39.01 – Profit and loss \nEIOPA introduces the technical accounts in S.39.01. This template is a quarterly template which is to be a built up from a solo perspective. This is not aligned with each other. Again, this will result in an increase in the administrative burden.\nEIOPA adds new requirements with respect to the reporting of the P&L figures in S.39.01.11.02. We do not see the added value of the inclusion of this type of information as the whole Solvency II information is based on an economic value. This requirement will again add to the administrative burden.\n","Public","Amice","Please note that S.39 is to be reported with a semi-annual frequency, not quarterly. \nS.39 previously collected P&L figures as part of the financail stability templates, differing from the economic value of the SII prudential reporting. The new information constitutes a high level breakdown of this P&L figure. This should not add additional burden to the undertakings, as these figures should be already include in the statutory acounts. "]
["Financial stability guidelines",null,"Both","S.38.01 – Duration of technical provisions – General comments \nWe query why EIOPA proposes to submit S.38.01 on a quarterly basis when the duration of the insurance liabilities does not change very frequently. \n\n\n","Public","Amice","Please note that template S.38 is reported on a semi-annual frequency, not quarterly. "]
["Financial stability guidelines",null,"Group","Question 1: The exact criteria and format for the reporting of the effective duration of technical provisions is to be confirmed after the feedback received from the public consultation: \nOption 1: Modified duration reported for all undertakings; Effective duration to be reported only where material optionalities are present in the technical provisions.\nOption 2: Portfolio to be split based on presence of optionalities: Both modified and effective duration to be reported for all undertakings along with the associate best estimate for each measure.\nWe share EIOPA’s view that the duration concepts used for assets and liabilities could be aligned, and we support the proposal to use the modified duration for both assets and liabilities. The effective duration, however, is particularly challenging to calculate for liabilities, especially in life guarantee business. We do not see an added value in providing the effective duration that would justify the significant additional effort.\n\n\n\n","Public","Amice","From the feedback received, Option 1 will be implemented. Therefore effective duration will only be required to be calculated in addition to the modified duration when material optionalities are present in the technical provisions. "]
["Disclosure",null,"Both","EIOPA-BoS-21-299-ITS_Amendments_Disclosure – Article 3a – Means of disclosure\nSome undertakings/groups may choose to publish the information related the narrative part of the solvency and financial condition report and the templates in two files in order to facilitate the work of the users, while other firms may choose a single file. However both options are available as part of the regulations regarding the disclosure of the Public QRTs and should remain to be so. We request EIOPA to abandon this requirement and leave it optional for undertakings to include both the narrative and the QRTs into one single document.\n\nEIOPA also states that the location of the file in the website of the insurer where it has been disclosed for the first time shall be submitted to the supervisory authority and shall not change for at least five years after the disclosure date.\n\nThis requirement would force companies not to change its website. This is technically impossible if the company changes its name or its website; Not even legally allowed this way. A change or re-design of the website will be almost impossible.\n\n","Public","Amice","Please note that Article 3a and the related amendment introduced in Article 6 have been deleted. However, the proposal in the reporting instructions for submition of the undetaking's SFCR url is kept on a voluntary basis."]
["Disclosure",null,"Both","EIOPA-BoS-21-299-ITS_Amendments_Disclosure – Article 6 – References to other documents in the solvency and financial condition report\nEIOPA also states in Article 6 that the location of the file in the website of the insurer where it has been disclosed for the first time shall be submitted to the supervisory authority and shall not change for at least five years after the disclosure date.\nSee comments to article 3a Means of disclosure.\n","Public","Amice","Please note that Article 3a and the related amendment introduced in Article 6 have been deleted. However, the proposal in the reporting instructions for submition of the undetaking's SFCR url is kept on a voluntary basis."]
["Disclosure",null,"Both","EIOPA-BoS-21-299-ITS_Amendments_Disclosure Article 4 – Templates for the solvency and financial condition report of individual undertakings\n We oppose the requirement by which internal model players will be requested to publish in their SFCR both the results of the standard formula and internal models. The main reason for going the internal model route is to calculate the capital requirements according to their risk profile. A comparison based on standard formula results will not add any value and create confusion in the market.\n\n","Public","Amice","The current ITS amendment doesn't have such a requirement. Undertakings using an internal model will not be required to publish their Standard Frmula results. "]
["Other",null,null,"The IRSG welcomes EIOPA's consultation on proposed amendments on reporting and public disclosure, and particularly the intent to reduce reporting costs for the majority of insurance undertakings, and to focus on emergent risks and on areas where supervisors have identified gaps.  The IRSG supports the intent to promote better risk-based and proportionate reporting requirements and to reduce the number of templates to be reported for the majority of undertakings.  The IRSG is also supportive of a requirement for proportionate, relevant, specific, and materially pertinent reporting of information.\nIn the interest of full consistency and to avoid several changes within a relatively short timeframe, new reporting and disclosure requirements should only become applicable once the corresponding pieces of Level 1 legislation are finalised, in particular the revised Solvency II Directive  as well as the Corporate Sustainability Reporting Directive (CSRD) . Therefore, we propose to align the timing of the changes with the timing of the revised Solvency II Directive; this would allow sufficient time to enable undertakings to effectively implement the required changes at a time of many other required changes.   \nGenerally, companies are at an advanced stage in planning IT resources budgets for 2022.  As the final QRT proposals will only be known and approved by the end of this year, they will not be included in current plans for 2021 activity, leading to technology and personnel resource challenges, with IFRS 17 and sustainability requirements implementation likely presenting direct conflict for resource for many undertakings. \nThe way the consultation is presented is unstructured; a complete and concise overview of the changes is missing, which makes it hard for stakeholders to deliver relevant feedback. A comprehensive document outlining the changes and the rationale for the changes would help stakeholders to get a better understanding of the impact of the changes proposed and would enable them to provide more targeted comments.\nEIOPA highlights that the changes to the reporting package will lead to a reduction in reporting costs, for instance through simplifying quarterly templates and eliminating less relevant templates.   It is difficult to see how the many changes, both minor and material, will achieve this, and there are notable and complex additional requirements proposed as well as reductions.   It is likely in many cases that the amount of data to be reported would increase significantly were these proposals to be implemented.  Implementing these changes will add more costs to the already high cost and burden of reporting. The additional costs will ultimately be borne by the policyholder. The changes to the reporting package should be limited to proposals that are essential for supervisors to fulfil their supervisory responsibilities.  \nReporting which is dependent on the exercise of subjective judgement on the part of undertakings or NCAs should be avoided, unless guidance can be provided to ensure consistency of approach between undertakings. Requirements to allocate data to cyber or climate change might fall into this category.\nOne of the issues with thresholds is that data is still required to be accessed and collated in defined structures in order to compare the company's position with applicable thresholds and, if necessary, report.  Nevertheless, we support appropriate thresholds and, where thresholds are to be set, we recommend that they be set at as high a level as is acceptable in order to effectively cater for proportionality and reduce cost burden.  Where the size of these limits subsequently appears too high on the basis of experience, they can if necessary be lowered.\nEIOPA should also have regard to the requirements of IFRS17, where additional burdens could be imposed on companies reporting under the new standard if they are also required to provide information for regulatory purposes which is no longer required for accounting purposes.  IRSG also proposes that EIOPA consider providing support for undertakings on how to bridge reporting requirements under Solvency II and IFRS 17.\nThroughout the instructions, EIOPA references individual requirements stemming from national supervisors and even allows for deviation on national level from the provided instructions. Instructions in the nature of “unless required by the national supervisory authority” do not facilitate convergence of regulation and make data comparison on cross country level impossible. IRSG considers that EIOPA should strive to find a common ground and unify requests from national supervisors to a common basis in all but exceptional circumstances. It will not be possible to capture all potential requests from supervisors in general reporting requirements and to entirely eliminate ad-hoc reporting requests, as ad-hoc requests are often in response to unforeseen situations. Constantly introducing new reporting requirements with a view to capturing requirements for every situation will lead to excessive reporting and associated cost.  ","Public","IRSG","EIOPA would like to clarify that the current ITS amendments implement changes already indicated during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations where the timeline for implementation was clear.\nNo amendment proposed now will be impacted by Solvency II Review. Impact on reporting from Solvency II review is not expected to be material. The amendments reflect the lessons learned from the last years and it is important to proceed with this review at this time, without waiting for the Solvency II Review, as EIOPA proposals on the review of the Technical Standards will lead to two crucial improvements: 1)Reduction of reporting costs for the majority of insurance undertakings;2) Incorporation of information needed for supervisory purposes focusing on emergent risks and new areas for which supervisors identified a number of data gaps. \nIn addition following stakeholders' comments on the proposed timing EIOPA is proposing extension tof the implementation date to 2024. \nEIOPA disagrees. All changes have been introduced in track changes. The changes in the majority has been based on the QRT report published by EIOPA at the end of 2020. In addition newly introduced areas were explained in the Cover Note. In addition all changes included now are based on all the work during the SII Review performed in 2019 and 2020. This set of amendments started in July 2019 with a call for Input, followed by several public consultations.\nImpact analysis include an assessment of the thresholds but the concrete thresholds proposals are included in the consultation package in track changes more in the individual instructions of the different templates.\nThe DPM will be available early in the 2021. The consultation included only proposals of the ITS amendments together with changes in the templates. \nRegarding IFRS 17 and the impact on S.05.01 EIOPA further clarified the instructions of the template but would like to stress that S.05.01 is not a P&L and therefore some deviation may occur (e.g. differences exists also today with IFRS 4). At ‘solo’ level IFRS 17 is expected to be applied only by a minority of undertakings and it is preferable to keep one consistent metric\nIFRS users are expected to keep track of written/earned premiums (as defined Art. 1(12) of DR) in order to calculate capital requirements under SII (e.g. S.28.02).\nFor detail view please consult the resolutions on individual templates and the final package proposals."]
["Sustainable finance questions","1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?",null,"We believe that undertakings which are not subject to NFRD (Non-Financial Reporting Directive) should not be required to report on sustainable investments. The extension of reporting requirements from NFRD to Solvency II is neither proportionate nor justified. The policymakers have already considered the principle of proportionality in the scope of the NFRD and there is no added benefit by increasing the reporting burden to the industry beyond already passed regulation.\nIn addition, the reporting obligations of Article 8 of the Taxonomy Regulation enter into force sequentially from 31.12.2023 with the full scope only to be disclosed from 01.01.2024. The Solvency II risk considerations should be then developed in context of the NFRD and in line with it. With EIOPAs knowledge and experience from its work on the sensitivity analysis of climate related risks it would be then possible to derive a better understanding on activities that should be considered for the exposure after the first figures are disclosed and analyzed by the supervisors.   \nIf such reporting is to be required, we believe that a materiality threshold should be introduced. Undertakings should not be subject to reporting the same information as already reported under NFRD, and Solvency II reporting requirements for sustainable investments and climate change related risks should not be applied before the NFRD enters into force.","Public","IRSG","EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting."]
["Sustainable finance questions","2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ",null,"The requirement to identify and report on exposures to transition risks is new and could therefore prove to be onerous for firms which do not currently have access to such information. If such requirement is introduced, then it should be explained what companies are expected to report.  In this sense, a materiality threshold would be welcome, ideally consistent with threshold requirements in NFRD. ","Public","IRSG","Noted. We do not propose a materiality threshold nor propose to exempt certain lines of business, as this would not serve a risk-based prudential assessment. We propose instead a gradual introduction of the reporting requirement to allow undertakings to seek to obtain the relevant information: the KPI will need to be reported only from 2024 (FY2023 information). EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for hte risk assessment. "]
["Sustainable finance questions","3. What could be a methodology for standardised reporting of climate change-related physical risk exposure for other investments than property?",null,"Key aspects of reporting in relation to physical risk exposure would be consistent measurement of exposures and supplementary qualitative information to provide insight into exposure differences which are not properly assessed by qualitative means.","Public","IRSG","Noted. Hence EIOPA's proposal for standardised reporting of geo-location of property, and the importance of the ORSA assessment, which can have qualitative and quantitative aspects. With regard to the metric, EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for the risk assessment, which can inform the methodology for computing the metric for reporting purposes. "]
["Sustainable finance questions","4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?",null,"Yes.  The IRSG consisders that a threshold for physical risk exposure for investments other than property should be introduced, ideally consistent with NFRD requirements.","Public","IRSG","Noted. We do not propose a materiality threshold nor propose to exempt certain lines of business, as this would not serve a risk-based prudential assessment. We propose instead a gradual introduction of the reporting requirement to allow undertakings to seek to obtain the relevant information: the KPI will need to be reported only from 2024 (FY2023 information). EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs. The guidance aims at supporting small and medium undertakings, by providing examples and proportionate solutions for the risk assessment. \nUndertakings are invited, as part of their ORSA to explore and explain if and how they have assessed the physical risk exposure of their non-property investments. "]
["Reporting","S.06.04",null,"EIOPA's decision not to go ahead with the new template on look-through for CIU, and EIOPA's efforts to get access to the information already reported by companies, are welcome.","Public","IRSG","Noted"]
["Reporting","S.06.04",null,"New template for sustainable investments and climate change-related risks to investments.  While the wish to receive specific climate related related reporting, particularly in relation to transition risk and physical risk, is understood, it is also key that requirements already foreseen under the Taxonomy Regulation are taken into account. In addition, for fulfilling these proposals, consideration should be given to availability of data, and it should be ensured that the same information is not reported twice. For taxonomy-aligned investments: CSRD would be the preferred format, and it is considered that the entities in scope of CSRD and the timing would be appropriate for sustainability reporting. The scope of the DA on Article 8 Taxonomy under NFRD should not be extended to all Solvency II companies. Regarding timing, EIOPA should take into consideration other sustainability initiatives and it should not require the reporting of taxonomy-alignment indicators before 2024 as envisaged in the CSRD.  \nRegarding indicators on physical and transition risks, the regular QRTs is not an appropriate way to collect that data. The reporting should aim at collecting standardised data, thus allowing meaningful aggregation. As the indicators on physical and transition risks would be based on the outcome of idiosyncratic scenario analysis, they cannot be appropriately aggregated. The European Commission’s legislative proposal on Solvency II will render long-term climate change scenario analysis mandatory in the ORSA. The IRSG believes that the ORSA is a more natural recipient of the outcome of own analysis than QRT.\n","Public","IRSG","Noted. The ORSA will support the reporting of the KPI for prudential purposes. EIOPA has also developed dedicated application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA. Currently under consultation in 2022, the guidance aims to support the assessment of the exposure to climate risk, as part of the undertakings's ORSAs and builds on existing and ongoing work at EIOPA on transition and physical climate risk. "]
["Reporting","S.14.02",null,"The introduction of this new template would imply that insurers need to make another product classification, on top of the currently used Lines of Business and the internal classifications.  It will not be possible to use existing accounting data to report this template, making it more labour intensive and costly to implement, support and maintain this template.  \nThe granularity of the template makes automation of the template near to impossible in the initial reporting periods and its completion will require significant manual effort.\nIt is hard to see the purpose of S.14.02 because many details and information is already reported at line of business level.\nWhile the requested climate related information in the template is analogous, it is not identical to the new requirements under Taxonomy Regulation Article 8 (to be disclosed via the NFRD). Furthermore, it is required to be reported with different scope and timing, adding an unnecessary burden. \nGiven the similarities of indicators for reporting on this type of information, the CSRD framework would be the preferred way.","Public","IRSG","To reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n\nThe proportion of GWP covering climate related perils is also an input for the corporate reporting by non-life undertakings when reporting the KPI related to underwriting activities on the amount of environmentally  sustainable non-life underwriting, as per Art. 8 of the Taxonomy Regulation TR (see link below). It is proportionate to ask companies to report this also for other purposes, and prudentially relevant, as it can contribute to establishing insurance penetration rates for certain perils.  The information on risk-prevention measures is a type of information which non-life undertakings may report to establish compliance with the taxonomy climate adaptation objective under the Climate Delegated Act technical screening criteria. It is prudentially relevant to ask for this information, as it can help supporting the analysis of the undertaking’s underwriting strategy."]
["Reporting","S.14.03",null,"The wish to receive reporting of underwritten cyber risks is recognised; however, EIOPA’s proposed template is too granular, impossible to populate in many instances as the data is not available, and will be costly and burdensome to complete for the remaining fields.  For example, an insurer writing excess layers behind several primary carriers will have a variety of policies in his portfolio, with different coverages. And reinsurers underwriting this portfolio will have even less granular information about the coverages provided.\nFurthermore, the split of the various fields in very granular sub-categories does not correspond to the reality of the market. For example, regarding the item C0040 (Cyber coverage in the Product Category), the portfolio ceded to the reinsurer is often composed of several Product categories: cyber standalone, alongside some cyber as add-on. In this case, what answer is expected? Same for the item Product Category (C0030) which represents one of the following:  1st party, 3rd party, costs and related services. Cyber insurance products often cover the 3 categories simultaneously. In this case, which code should be selected? This question extends to items C0080 (sum insured), C0090 (premium), etc. that should be split per Product Category. For insurers, the insurance product is often a comprehensive policy offering coverages across the 3 product categories (generally with a combined policy limit) and, for reinsurers, their portfolios are often composite.\nIt is unclear how this information would give supervisors more insights in market trends for cyber insurance.\nIn its previous proposals EIOPA suggested that a threshold would be introduced, however disappointingly this was not the case in the final EIOPA proposals, as such forcing companies with smaller cyber portfolios to report this information, which is burdensome to gather.\nAgainst this background, EIOPA is urged:\n- to make this template less granular and to explicitly recognise the use of estimates and proxies,\n- to propose a threshold to allow for some proportionality,\n- to limit the reporting to affirmative cyber risk products, and\n- to limit the reporting to direct business (as in the new versions of templates S.14.01 and S.14.02), as corresponding figures from active reinsurance business cannot be adequately reported or would not be comparable. Example: the number of claims for reinsurance quotas is not available, and claims payments are only available for pure cyber quotas, but not for mixed contracts. International standards for a uniform taxonomy for recording exposure and damage data must be taken into account.","Public","IRSG","EIOPA disagrees. Infrmation is onsidered important and EIOPA believes that even more granular information should already be available to undertakings for their internal risk management purposes. Furthermore, EIOPA considers  the granularity of information to be a good compromise between the policy-by-policy reporting and the reporting in bundles. Regarding threshold, please note that such have been included in the instructions."]
["Reporting","S.25.05",null,"The 10 newly introduced templates requiring standardised reporting for Internal Model companies require granular and mostly inconsistent information, which does not fit the specific structure of full or partial internal models, thereby requesting estimations that would in all likelihood lead to results that do not make sense.  \nIRSG opposes results from standardised reporting on internal models to be used as a basis for comparison between companies or as a basis for assessing the evolution of internal model capitalisation over time. Some of the data requests would even dictate how to model certain risks which is against the freedom of modelling risks recognised in the Solvency II directive.\nIn addition, the level of granularity requested is often not available and EIOPA should make clear for every field that no data is to be expected if not readily available in the model. EIOPA should also better consider the case of reinsurance activities. Reinsurers manage portfolios consisting of heterogeneous risks, with less granular data on every underlying product than the cedents, and requesting to single out sub-portfolios for the sake of the QRT reporting is disproportionate.  \nIRSG is also of the opinion that the QRT reporting package is not a suitable platform to report model changes. The national supervisors are already properly included in their reporting process on a quarterly basis and there is no additional need to double report them in an annual QRT set.\nEventually the additional data request is so extensive that it would require for internal model users to engage in major and costly IT system projects unlikely to be completed for YE2022 reporting. As a result, the first year of application should be postponed and the implementation phased-in (see also comments above re timing of introduction). \nEIOPA specifies that detailed information shall only be reported if requested figures can be calculated with “reasonable effort”, where national supervisors can decide what constitutes a “reasonable effort”. This will likely lead to a situation where undertakings from different countries will be confronted with varying requirements and will lead to national “gold plated” requirements. If new templates are introduced EIOPA needs to formulate direct and detailed reporting conditions. ","Public","IRSG","The granularity of data collected for each risk category reflects some NCA experience from on-going model supervision (sometimes combining different local supervisory practices) and also reflects the experience gained by EIOPA’s IM consistency studies. Undertakings are not requested to change their IM to be able to follow the structure of the templates. If the model does not allow producing some of the requested data, then that data does not need to be reported. EIOPA is trying to minimise “artificial data”. However, if the model supports the production of such data in a sensible manner, then it has to be reported. Interpretation of IM reporting will rely heavily on NCA’s knowledge of the internal models they supervise as well as the risk profile of the supervised undertakings or groups.\n\nReporting of current QRTs (S.25.02 and S.25.03) is agreed with the NCA."]
["Reporting","S.26.08",null,"The suggested demand requiring undertakings using internal model to also report according to the standard method needs to be questioned. This parallel reporting should only be requested when a company has applied for partial internal model / internal model as part of the application process, not for companies with an already existing and approved internal model.","Public","IRSG","Please note that the comment relates to amendments of the SII Directive while the current package is not proposing any chnages to the reporting related to Article 112."]
["Reporting","S.29.01",null,"NSAs do not use these templates for interactions with companies, therefore the added value of these templates is not clear.  Furthermore, these templates are particularly onerous to complete.  In addition, new and changed QRTs require significant effort.  Against this background, it is suggested to revert to the initial set of templates. ","Public","IRSG","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Disclosure",null,null,"IRSG notices the removal of the S.05.02 template and its replacement in the form of the S.04.05. The change does not seem to provide any additional information to the customers and users of the SFCR and does not reduce the reporting burden for the industry. As such IRSG is of the opinion that the old template should be kept.\nIRSG notes the introduction of the Solvency and Minimum Capitals ratios in the S.22.01 template. While these figures constitute only an insignificant change, they provide a benefit for the customers and users of the SFCR. According to the annotated templates EIOPA also intends to add additional reporting requirements, however, since these are not reflected in the updated instructions IRSG assumes this to be a miscommunication and that there will be no additional reportable columns in the public version of the S.22.01 template.\n","Public","IRSG","Noted.  Elements of the information published in the old S.05.02 template are no longer contained in the supervisory reporting package (e.g. net of reinsurance premium figures by country).  We consider there are clear benefits to the quality of publicly disclosed information where it is derivable directly from the supervisory reporting.  Retention of the existing template is an added burden for industry in that information would be maintain purely for disclosure purposes (i.e. not required for supervisory reporting).\nThe changes proposed at S.22.01 were further removed considering stakeholders feedback."]
["Financial stability guidelines",null,null,"EIOPA has proposed several changes to financial stability reporting.\nIn particular, it proposes to include the annual balance sheet S.02.01.01 in the quarterly financial stability group entry point which leads to a situation where groups will need to provide a more detailed balance sheet for financial stability reporting purposes than for the quarterly Solvency II reporting (where S.02.01.02 is required). IRSG assumes that this is a miscommunication and S.02.01.02 is the intended template for the financial stability requirement.  \nEIOPA has proposed several changes in this area, in particular the new requested liquidity templates (S.14.04/05) will be challenging to complete. \nThe IRSG does not support the inclusion of new detail in the QRT. In particular for the S.02.01, S.23.02 and S.39.01 which require finalized figures on Group level. As the financial stability reporting deadline for groups is only 7 weeks (compared with quarterly at 11) it is not realistic to expect more detailed figures already by the shorter deadline. Expecting undertakings to provide more data under this circumstance will only increase data quality issues and require them to provide estimated figures instead of actual figures.","Public","IRSG","Please note that the statutory accounts coulmn is only to be submitted annually. Moreover, EIOPA does not publish these figures. \n\nEIOPA acknowledges that the financial stability figures, considering the shorten reporting deadlines (7 weeks), are reported on a best effort basis, and could marginally differ from the figures reported in the prudential reporting. Further, the deadlines for accounting might differ among countries, thus there is not an harmonsised framework."]
["Reporting","S.13.01","Solo","S.13.01 – Projection of future gross cash flows – Future guaranteed benefits and Future discretionary benefits – \nC0010 &C0015/C0050&C0055/C0090&C0095/C0130&C0135/C0170&C0175\nEIOPA proposes to split the \"future benefits\" into two components, “future guaranteed benefits” and “future discretionary benefits”. We query the added value of requesting further granularity. The request is burdensome  from a practical and technical point of view and will provide limited additional benefits.In any case a threshold should be introduced for when the item is not material.\n\n","Public","Amice","EIOPA disagrees with the proposal to drop the split between future guaranteed benefits (FGB) and future discretionary benefits (FDB). EIOPA understands that under stochastic valuation different scenarios would lead to different allocation of cash flows. However, this issue does not only affect to the split of cash flows between FDB and FGB but also to the total amount of cash flows which is currently being reported. For this reason, the LOG already clarifies that reconciliation with BE is not required, but additional guidance has been included. "]
["Group reporting questions",null,"Group","EIOPA intends to align the intragroup transactions templates (S.36) and the risk concentration templates with the Financial Conglomerates Directive which will ensure consistency of reporting. IRSG is concerned that this alignment could introduce additional reporting requirements for undertakings not being a financial conglomerate which would not be appropriate.\nIRSG is also concerned that EIOPA intends to distinguish between “significant” and “very significant” transactions. From an operational point of view, it is recommended to only differentiate between “significant” and “not significant” transitions in order ensure clarity of reporting requirements. \nChapter 5.9.   IRSG is of the opinion that Option 1 is the most feasible one to implement for regular reporting purposes. Option 2 is both cumbersome to implement and does not contribute towards comparability across groups which would result in a costly solution which cannot be relied on to compare regulated undertakings, especially from different countries. Option 3 relies on narrative content which limits the quantitative nature of reported figures and leaves room for interpretation both the preparer and receiver of information. As such, similar to Option 2 this approach cannot ensure consistency of data and approaches between groups.","Public","IRSG","Noted. Based on the inputs received, the selected option for S.37.01 is option 1 with some changes: „proportional or otherwise justifiable break-down agreed with the group supervisor“"]
["Reporting",null,"Both","Summary : We support the two objectives presented by EIOPA (simplify and strengthen on relevant aspects, starting at 31.12.22, before the Solvency 2 review). However, we noticed that the simplifications regard to statements/information that concern eventually only a small number of insurance undertakings (S.06.01, S.15.01, S.15.02...) or that do not generate significant resource gains. As for the additional information, while some is relevant and welcomed (sustainable investment apart from a few remarks on the maturity level of the data/methodologies, EPIFP), others seem time-consuming to us and we question their relevance (S.14, S.29).\nIn this regard, we regret that we have not always found in the elements of consultation justification for the usefulness of the introduction of this or that information / state, which would have allowed a more fruitful dialogue (eg \"premium\" notion for real estate in detailed investment state, variations analysis S.29)\n\nTherefore we propose various adjustments in relation to the proposal made, and in particular additional simplifications in relation to the device presented. The main ones are as follows :\n- Decrease S.14.01 granularity and limit additional information on S.14.01/02. The objective is to make the granularity of the requested data consistent with the granularity of the Solvency 2 calculations that are carried out, at the risk of degrading the quality of the information provided.\n- Delete the S.29 or condition them to a threshold of significance in amounts if these elements are of interest for macro studies.\n- Review the thresholds for the application of the deferred taxes states.\n- Optimize the proposed changes to S.06 on investments (S.06.02 and S.06.04)","Public","FNMF","Please note that following the comments received further changes have been introduced in the ITS amendments package. For example on S.29s - to revert to the current templates, S.14.01 - decrease granularity, S.14.02 - move to line of business reporting, drop the LAC DT templates, remove the ECB add-on write offs/write downs in S.06.02, S.06.04 - drop the sutainable investments ratio. For detailinformation review the resolutions of the individual comments."]
["Reporting",null,"Both","Proportionality principle : Although some exeption thresholds were increased in some QRTs; it should not represent a significant change for insurance undertakings subject to Solvency II. We wish EIOPA had incorporated the possibility for small and medium-sized entities to have a lighter version of the reportings which would significantly reduce affected resources to the production of those elements.","Public","FNMF","EIOPA considers the changes proposed to increase the proportionality. Please note that the concept of the low risk undertakings is also further developed in the Solvency II review. "]
["Reporting",null,"Both","Changes and additions to the current QRTs : EIOPA's proposals include too many changes on a large number of QRTs which will bring important costs in terms of human and material resources. We would like EIOPA to reconsider their proposals in order to minimise the impacts on currently existing QRTs.","Public","FNMF","Please consult the final package as further changes have been introduced to reflect on the comments received."]
["Reporting",null,"Both","New QRTs : The production of these new templates would require a huge amount of work for insurance undertakings. It would demand important changes in information systems that would generate a substantial cost. This conflicts with EIOPA's stated purpose to optimise the costs generated by the production of Solvency II templates. ","Public","FNMF","Please consult the final package as further changes have been introduced to reflect on the comments received."]
["Reporting","S.06.02","Both","Regional administrations and local authorities :\nWe understand that the request would identify assets classified under CIC code \"13/14\" but which would not benefit from favourable prudential treatment in spread/concentration under the Delegated Regulation. In the absence of a specific standard, there may be discrepancies in interpretation that will drown out the relevance of the information. It is a safe bet that from one actor to another the answer provided is different. This raises questions about the quality of the information that will be entered in this field.\n\nAlternatively, it is proposed to :\n- Either to delete the field and instead launch a study at EIOPA level to further clarify recognition of issuers falling into the 2015/2011 \n-Failing that, if the objective is to distinguish assets that are subject to favourable prudential treatment from others, the definition of CIC codes 13/14 could be refocused on assets issued or guaranteed by a \"2015/2011\" authority. The others being switched to CIC classification \"19\", as EIOPA already proposes to extend this code for bonds guaranteed by the ECB/Member States that do not fall into the previous categories. Thus, supervisors will have information on the associated prudential treatment by reading the CIC code. For instance the CIC definitions could be modified as follow : \n\n13 - Regional government bonds : Regional government or autonomous communities debt instruments offered to the public in a public offering on the capital market and Debt instruments offered to the public in a public offering on the capital market and bonds that are issued or fully, unconditionally and irrevocably guaranteed by regional governments listed in Article 1 of Commission Implementing Regulation (EU) 2015/2011 of 11 November 2015\n\n14 - Local authorities bonds : Bonds issued by local authorities, including cities, provinces, districts and other municipal authorities and bonds that are Debt instruments offered to the public in a public offering on the capital market and bonds that are issued or fully, unconditionally and irrevocably guaranteed by local authorities listed in Article 1 of Commission Implementing Regulation (EU) 2015/2011 of 11 November 2015\n\n19 - Other : Other government, regional government and local authorities bonds and bonds that are fully, unconditionally and irrevocably guaranteed by the European Central Bank, Member States' central government, central banks,  regional government and local authorities not classified under the above categories\n","Public","FNMF","EIOPA disagrees. Please note that CIC 13 and 14 also covers debt securities issued by non EU or EEA states. Therefore, changing the approach as proposed will have a huge impact on the present classification of such debt securities."]
["Reporting","S.06.02","Both","Cryptoassets : This item could be subject to a specific CIC rather than adding a field to the QRT which would require additional developments and make the template more burdensome.","Public","FNMF","Item C0295 allows the identification of assets that have a link to a crypto-asset. The CIC should be the code attributed to the “basis” asset. If it is a (new) asset category, not classifiable under the existent CIC categories, them CIC 09 should be used. "]
["Reporting","S.06.02","Both","Property location : We wonder about the cost/profit ratio of that information. In fact, the concept as it is described in the recommendation of the ESRB of 21 March 2019 is unclear and require specific analyses for each asset held, for an information unlikely to be uniform from one entity to another.\n\nThus, it seems the assets of insurers will usually distinguish :\n\n - On the one hand, operating real estate, possibly owned or even via one or more dedicated structures (real estate, SCI, ...)\n- On the other hand, \"yield\" real estate, which will then be held more likely via specialized funds (OPCI, SCPI, ...)\n\nConsequently, unless there is a misunderstanding, the information obtained via the S.06.02 state, wich is not using look through approach, will thus necessarily be fragmented and biased. (with focus on operating assets, provided that they are not themselves held by an intermediate structure).\n\nIn addition, collecting information, whether look through or not, on a basis as \"unclear\" as an ESRB recommendation seems unreasonable to us, in particular on the \"premium\" aspect.\nOn the classification requested in field C0296 (based on ESRB/2019/03), it seems to us that the CIC codes already provide satisfactory granularity.\nFinally, asking for information such as latitude and longitude is absolutely not in line with reporting standards, while the address that may pose significant standardization problems depending on the country (i) of the entity that reports (ii) the rental property place (iii). \n\nAs a result, we propose to delete the new fields relating to real estate.","Public","FNMF","The ESRB has issued Recommendation of 21 March 2019 amending Recommendation ESRB/2016/14 on closing real estate data gaps (ESRB/2019/3). Recommendation D 2. (b) requests information on flows and stocks of valuation adjustments on CRE direct investments, broken down into property type and property location. In S.06.02 it is collected already information on each property and the CIC allows the identification of CRE investments. Therefore only two additional items need to be collected: “Property type” and “Property location”.\nAccording with the definitions in the Recommendation:\n-\t“Property type” -  distinction between:\no\tresidential, e.g. multi-household premises;\no\tretail, e.g. hotels, restaurants, shopping malls;\no\toffices, e.g. a property primarily used as professional or business offices;\no\tindustrial, e.g. property used for the purposes of production, distribution and logistics;\no\tother types of commercial property.\n-\t“Property location” – distinction between:\no\tPrime;\no\tNon-prime.\n\nPlease note that the requested additional information on the location e.g. lingitude and latitude is important for the assessment of the physical risk to be reported in S.06.04. "]
["Reporting","S.06.02","Both","Expiry date : This item could be blended in the same column as the field \"Maturity date\". In fact, the distinction on the CIC code and on wether the security is identified by an ISIN code requires developments in the tools and makes the QRT analysis complicated. ","Public","FNMF","The comment is not clear. The instructions of S.06.02 make no reference to an \"Expiry date\"."]
["Reporting","S.06.02","Both","Generally speaking, the list of assets QRT is a heavy workload that EIOPA's project will make even heavier. In fact, many developments in the software tools will be needed and some items require a learning process that will be costly in terms of human resources. Finally, we wonder about the cost/profit ratio of some of the extra information. We would like EIOPA to reconsider the changes made to that QRT in order to rationalise and minimise them.","Public","FNMF","Noted. EIOPA further discussed the changes proposed and ecided to remove the ECB add-ons from the list of newly introduced items to the template."]
["Reporting","S.06.04","Both","Sustainable investissement : We are supportive of the propositions. We would like however to highlight that , the quality of the information that will be first collected is not guaranteed given methological limitations and differences between the undertakings (ESG data, management companies...) : we will have to settle for our best effort, especially regarding the physical risk and the transition risk KPIs (R0020 and R0030) which remain to be standardised by a regulation.\nIn particular on the physical risk, the proposal in S.06/02 to report latitude / longitude or the address seems unrealistic and biased, while we are not aware of metrics, unlike the climate risk where we see some methodologies emerging, which nevertheless seem controversial in terms of accuracy and scientific as well as financial relevance (measurement of temperature alignment of the portfolio in °C ...).","Public","FNMF","Noted. EIOPA's proposal has been amended: the share of sustainable investments will not need to be reported as part of the Solvency II reporting.\nOn the physical risk metric: EIOPA is of the view that tthe reporting on geo-location of property investments are are a relevant objective measure, to map the location against regions at risk. See for example the draft application guidance on running climate change materiality assessment and using climate change scenarios in the ORSA, currently under consultation, for methodologies."]
["Reporting","S.12.01","Solo","The proposals seem relevant.","Public","FNMF","Noted"]
["Reporting","S.17.01","Solo","The proposals seem relevant.","Public","FNMF","Noted"]
["Reporting","S.14.01","Solo","The amount of extra information in comparison with the QRT in its current state is substantial (number of contracts, written premiums, commissions paid,fiscal treatment, …) and recquires new developments which will mobilise numerous resources.","Public","FNMF",{"$f":"+G197","v":"EIOPA notes that the new information required goes along with implementation efforts. Though, the additional information is considered necessary and should - at least in parts - already be available. E.g. the information on the yearly interest rate guarantee should be known to each undertaking, the same holds for the amount on which the interest rate is guaranteed, which may even be a local statutory figure.  Also, approximations are allowed for some of the figures required to reduce the burden. \n\nIn view of the concerns expressed and the implementation effort required, EIOPA however decided to limit the set of newly introduced information:\n-  Information on the amount of  premiums written by distribution channels is essential to allow for an assessment of relevance of sales channels. Currently availble soruce of information on distribution channels are limited. The added information allows to determine the business models used to commercialise certain products and possible concentration risks. EIOPA notes that the new information required may be a burden. However this information is deemed necessary to assess concentration risks and determine the changing distribution patterns - i.e., more reliance on own channels. Moreover, information on written premium by distribuition channels should be already available to insurance undertakings as they should know the channels through which they are writing premium/selling certain products to monitor risks arising from distribution. This information for several Member States and in a more granular manner (i.e., more granulirity in terms of distribution channels) is published annually by InsuranceEurope itself showing that for several markets this information is available. Aware of the possible burden to undertakings, to strike a balance between supervisory needs and and limiting the reporting burden EIOPA has reduced the number of new cells by reducing the granularity required on premiums written by distribution channel, no longer requiring a split between regular and single premiums.  \n- Commissions represent a key information on products being extensively used for understanding insurance undertakings' business model and sales strategy, including to identify whether the possible higher commissions could raise solvency issues and/or increase mis-selling which in turn could lead to solvency risks. This includes information on expected future commissions to allow an assessment of the commissions paid during the whole life-time of the contract. EIOPA also notes the burden to the industry but also notes that the information on commissions paid during the year should be already available as it should be calcualted for both pricing purpose and when commissions are paid to intermediaries. The information on expected future commissions is part of the calculation of the best estimate liabilities, approximations can be used to determine the necessary information. To strike the balance between supervisory needs and possible burden to the industry EIOPA dropped the breakdown between commissions for new contracts for single and regular premium products and no longer requires the information on expected future commissions for new contracts.\n- Information on expected future premiums is important to assess the volume of the business across the whole life-time of the contract and provide a volume measure to which the commissions are compared (i.e. to determine a sensible commission rate). We acknowledge the additional burden on undertakings and the necessity for approximations and simplifications. Also, to reduce the burden, the information does no longer be separately provided for new business.\n- Further, to reduce the burden the information on number of surrenders during the year was simplified and no differentiation for new contracts is required.\n"}]
["Reporting","S.14.01","Solo","Some items (administration expenses, future premiums, future commissions, Best Estimate) are calculated by homogeneous risk groups, conflicting with a breakdown by product.","Public","FNMF","EIOPA acknowledges the burden on undertakings. In view of the concerns raised, some of the items mentioned are no longer required, such as the information on administration expenses and future premiums and commissions for new business. However, some of the information remains which is considered essential to assess e.g. the volume of commissions for a certain product for conduct supervision purposes. Approximations may be used to allocate future commissions or future premiums to the level of product categories."]
["Reporting","S.14.01","Solo","The item about the fiscal treatment of the product seems impossible to fill in as the insurance undertakings does not have any information regarding their clients' fiscal situation.","Public","FNMF","It is not the intention of the cell to reflect policyholder’s individual fiscal situation but rather the fiscal treatment of the contract type considered"]
["Reporting","S.14.01","Solo","The S.14.01 state is currently filled with a \"by product\" granularity . This granularity is very heavy and does not make sense as the actual calculations of Best Estimate are not performed at this level. We therefore ask to lighten the granularity of S.14.01 to resume that proposed for S.14.02 (by product category).","Public","FNMF","The intent is to provide information on the level of product categories consistently for all information provided in S.14.01."]
["Reporting","S.14.02","Solo","The current QRTs already provide a lot of information regarding non-life guarantees and the production of this new QRT would further increasing the production of undertakings that have non-life guarantees.\nThis applies particularly to fields common with new items added in S.14.01 (see above).","Public","FNMF","We are aware of the complexity. To reduce the burden due to the new reporting requirements and in particular in relation to new product cateries,  the template now requires reportign by line of business. Reporting by product categories only required for four product categories for whcih risks have been identified and for which it is difficult to quantify risks given they reporting is split in a number of lines of business or multiple product category fall under the same line of business. Moreover the requirement to report on add-ons with the main product category has been removed to simplify.\n"]
["Reporting","S.29.05","Solo","S29 QRTs are usually quoted as generating a heavy workload for a little supervisory relevance, especially for small entities. In addition, the French supervisor (ACPR) frequently emphasizes the low quality of these templates. In the context of the objective of simplification highlighted by EIOPA in this consultation, we would like to ask for the removal of these QRT, or at least pair them with a significance threshold (for instance: get over than 500 M€ of tehcnical provisions). \nIf not possible, we at least support the separation of the Best Estimate variation analysis QRTs between Life and the Non life undertakings, which should allow the mixt entities whose Life activity is not significant to reduce their current production. However  the new Non life template integrates a finer granularity of information than the currently one and new elements which will recquire human and financial resources (epecially extra IT developments). The increase of the complexity and of the granularity will do nothing to address the low quality of the templates abovemntioned. We offer to remove the new elements of the QRT and to stick with the current granularity (with no distinction by line of business). ","Public","FNMF","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]
["Reporting","S.17.01","Solo","S.17.01.01 – Non-Life Technical Provisions – General comments\nEIOPA proposes to simplify the quarterly template S.17.01 by deleting the information on the transitional measures. We agree with this proposal. However, EIOPA’s new proposal to report the EPIFP per LoB is burdensome. Such information is already been reported in the RSR according to Article 309 of the Delegated Regulation. We question why there is a need to introduce the EPIFP at this level in the QRTs. We propose that \n• a threshold on the EPIFP per LoB is included. \n• an alternative/combination with a threshold per LOB could also be a EPIFP / OFs threshold - e.g. where EPIFP is > 10% of OFs, additional disclosure should be made - but only in relation to material LOBs (e.g. those that make up 75-90% of the total EPIFP).\n\n\n\n","Public","Amice","The information included in the RSR is frequently included in the QRTs as the objective of both reports are different. In any case, this shows that the information is relevant and undertakings are able to provide it, so it should not create any relevant buden for the undertakings.\nEIOPA considered an introduction of a threshold. However as Article 309 (6) of Delegated Regulation already require reporting of this information in the RSR and assessing the complications of calculating the threshold EIOPA decided to not introduce the threshold. Besides, this information will be required only annually. "]
["Reporting","S.01.01","Both","Across all S.01.01 templates there is this new requirement:\n\"When a template is submitted only with zeros or without figures, then S.01.01 should indicate \none of the “non reported” options\"\nWe have a concern on how this will be implemented/checked in xbrl (if indeed it will) and can envisage some (albeit edge-case) exceptions where 0 has different meaning. \nWill there be a check to ensure that a QRT (group) that has facts but all are value 0 then the S.01.01 equivalent line should be \"Not reported\" (one of the available options)? And, if so, what about cases where the fact is a \"meaningful\" 0 i.e. the true value is not 0 but it is rounded to 0 (appreciate this is pretty exceptional).","Public","Solvency II Solutions","Noted. Log has been clarified."]
["Reporting","S.01.01","Solo","Why for S.04.04 and S.04.05 is there the option:\n\"18 — Not reported as no direct insurance business\"\nDoesn't seem like if you have only reinsurance business you have an exception from reporting s.04.04 and s.04.05 anyway so this option seems irrelvant/confusing.","Public","Solvency II Solutions","Agree. Removed"]
["Reporting","S.01.01","Both","No option given to indicate not reporting S.06.04 if no relevant investments are held","Public","Solvency II Solutions","Amended"]
["Reporting","S.01.01","Solo","S.20.01 has an option:\n\"3 — Not due in accordance with instructions of the template\"\nbut it appears to us that if the insurer is non-life and has direct insurance business then S.20.01 must be reported. Unless the 90% threshold for S.20.01 (this is more a question on how the S.20.01 threshold should be applied) applies to total non-life (direct and accepted reinsurance); in which for an insurer with both it will be possible to have diret business and yet no need to report S.20.01 I suppose.\nThe exact same comment applies to S.21.01 and S.21.03","Public","Solvency II Solutions","It would apply only to cases where no direct line of business is material, because rensruance is covering more than 90%."]
["Reporting","S.01.01","Both","For S.26's and S.27 the option 17:\n\"17 — Reported for SF sub-modules\" \nlooks a bit unclear to us. What does this option represent (and are there still scenarios where these templates should be reported twice i.e. once for \"true\" SF basis for unmodelled risks and once for modelled risks but on a SF basis)?","Public","Solvency II Solutions","This option is there to inform that a template is partially reported with standard formula data. The rest of the standard formula data is not reported because a partial internal model is used and covers those risks. For clarity the text has been changed to:\n\n17 — Partially reported due to use of partial internal model"]
["Reporting","S.26.08","Both","We see an inconsistency between Article 14 requirement for reporting S.26.08 at entity level (because it is no included in the list of these QRTs that do not need to be reported at entity level where RFF's exist) and the S.01.01 options for S.26.08, which include:\n\"11 — Not reported as reported at RFF/MAP level\"","Public","Solvency II Solutions","SR.26.08 has been added."]
["Reporting",null,"Solo","Article 14 refers to:\n\"ii) for captive insurance or reinsurance undertaking table S.27.01.01.01 and S.27.01.01.27 of Annex I\"\nbut (so far as we can tell) Annex I doesn't define \"sub-tables\" of S.27.01 (ie the xbrl level breakdown of S.27.01) so we find this reference (though we understand what it means) to be legally/technically incorrect perhaps?","Public","Solvency II Solutions","Agree. Amended"]
["Reporting","S.01.01","Solo","The options for S.29.03-29.05 do not seem complete. We would expect another 1 option (at least) to indicate not reported due to non-life or life business. And possibly others for the case of composite and “material business model for a composite insurer”","Public","Solvency II Solutions","Please note that based on the comments received and after futher analysing EIOPA decided to keep the current S.29s templates in the current ITS amendments package."]
["Reporting","S.04.03","Solo","Shouldn't this QRT have a \"Type of code\" field; to distinguish between LEI and SC?","Public","Solvency II Solutions","The instructions in the ITS are clear as to the priority ordering of codes. In general, reporting follows a defined scheme with a code type preceding the relevant number. Therefore, distinguishing between different code types is perfomred within single field. For example reporting Legal Entity Identifier will follow  \"LEI/{code}\" pattern. Please note, that reporting of Codes and Types of Codes reporting is described in details in EIOPA XBRL Filling rules section IV.3 Codes and Type of Codes (https://dev.eiopa.europa.eu/Taxonomy/Full/2.6.0/Common/EIOPA_XBRL_Filing_Rules_2.6.0.pdf)"]
["Reporting","S.04.04","Solo","We feel it could be made clearer that items (as we assume they all are) are to be reported gross of reinsurance","Public","Solvency II Solutions","Noted - the ITS instructions are clear that these items are gross, but this is not included in the item titles on the template."]
["Reporting","S.04.05","solo","Just to clarify; there is no materiality threshold for this template, or an option to report information for countries below some threshold together in a single \"line\" (like there is in S.12.02 and S.17.02 for BE) or to only report top X countries (As there was in S.05.02 previously)?\nWe can understand no materiality threshold for S.04.04 but for S.04.05, given the nature of location of risk and the associated rules detailed in the General comment, this could be extremely challenging to determine a 100% coverage and some materiality threshold would most likely be very beneficial to filers while not posing any prudential concerns for EIOPA","Public","Solvency II Solutions","Supervisory experience since the introduction of Solvnecy II has shown that the existing templates do not provide sufficient information on location of risk to enable effective cross-border supervision.  Therefore, we do not consider retention of the existing templates as a viable option.\n\nThe observations on proportionality are noted.  It is not possible to introduce a threshold for template S.04.04 on location of underwriting (where information is required for cross-border statistical exchanges), but a threshold (e.g. 5% of GWP by LoB) could be considered for location of risk reporting in S.04.05."]
["Disclosure","S.04.05","Solo","There is a gap now in populating the public S.04.05.21 template in that this cannot be fully derived from the private S.04.05.01 (which was not present previously between public and private S.05.02 QRTs) due to the lack of breakdown in S.04.05.01 between direct/prop RI accepted/non-prop RI accepted. \nWe would highlight the definite benefit to the quality of publicly disclosed information where it is derivable directly from the private QRT info (for obvious reasons viz. software providers, like us, that have QRT-only modules can auto-populate the SFCR QRTs from the private QRTs and establish validations to ensure these reconcile).\nWe would suggest that given how granular the location of risk must be considered for S.04.05.01 to be populated in the first place that including the same split within S.04.05.01 (between direct and RI accepted) would not be incrementally significantly burdensome compared to current proposed S.04.05.01","Public","Solvency II Solutions","The split between direct/prop RI accepted/non-prop RI accepted is implictly present in the template due to the granularity selected for the lines of business in the Z-axis.  E.g. per the techncial instructions \"1 - Medical expense insurance\" and \"13 – Proportional medical expense reinsurance\" are distinct lines of business.  It is our understanding and intention that the utilisation of the z-axis in S.04.05.01 should allow for a direct derivation of the information required for S.04.05.21 and so w do not consider there to be such a gap."]
["Reporting","S.06.02","Solo","More of a general question perhaps but in S.06.02 the distinction between CIC 8 where the mortgage/loan is to a natural person is part of the applicability rules for several data points e.g. C0210 is not applicable to \"This item is not applicable to CIC category 8 — Mortgages and Loans, when relating to mortgage and loans to natural persons.\"\nAnd surely the new CIC categories 87 and 88 now define definitely (via C0290) this case. e.g. C0190 guidance:\n\"Regarding CIC category 8 — Mortgages and Loans, when relating to mortgage and loans to natural persons, this item shall contain ‘Loans to \nAMSB members’ i.e. loans to the Administrative, Management and Supervisory Body (‘AMSB’) or ‘Loans to other natural persons’, according to its nature, as those assets are not required to be individualised. Loans to other than natural persons shall be reported line–by–line\"\n imples that the two new CICs (87 and 88) represent all loans to natural persons.\nTherefore it seems strange to us that the S.06.02 guidance has not been updated at all to reflect CIC 87 and 88 e.g. couldn't the LOG guidance (and associated xbrl validation, in time) be updated to refer to 87 and 88 rather than the more nebulous: \"This item is not applicable to CIC category 8 — Mortgages and Loans, when relating to mortgage and loans to natural persons.\"","Public","Solvency II Solutions","Agree. Amended"]
["Reporting","S.06.02","Both","C0294 guidance is bit confusing (in light of the accompanying changes to the CIC 13 and 14 definitions), particularly the reference to \"... regarding assets classifiable with CIC 13 and 14.\"\nSeems to us that if the item has CIC13 or 14 then by defintion the only option here is 1? Perhaps if this field is to disclose which RGLA bonds the insurer holds that are not listed in the ITS (because if they are then you know that already from the CIC) then it could be described slightly differently and made a Y or N field (and perhaps made applicable only for CIC 1?)","Public","Solvency II Solutions","Please note that CIC 13 and 14 also covers debt securities issued by non EU ou EEA states. Therefore, there are assets classifiable under CIC 13 ou CIC 14 which aren't listed in the ITS."]
["Reporting","S.06.02","Both","C0296 guidance, why have option 9 if the field is only applicable for CIC 9 anyway? If it's puropse is to report \"unknown/immaterial\" perhaps its description could reflect that?\nBroadly the same comment for C0297","Public","Solvency II Solutions","The objective of having option 9 is to avoid having this item empty for CIC categories different from 9."]
["Reporting","S.06.02","Both","We feel C0301 should be reported in table 1 and not table 2 of S.06.02. Could there not be scenarios where an insurer holds the same asset both within and without a DA Art 171a qualifying portfolio? In such cases the reporting could not be done (without some unnatural manipulation of id codes etc.). Further, Art 171a is an insurer-specific designation and hence not a \"good fit\" for table 2 conceptually (although we appreciate some other fields in S.06.02 are quasi reference data/filer specific, such as CQS)","Public","Solvency II Solutions","Agree. Amended"]
["Reporting","S.06.02","Both","We have an improvement suggestion for C0360.\nIt stems from our doubt as to what residual modified duration actually means (it's not a commonly used financial term, I've never actually come across it anywhere else) for reporting and exactly the significance of the instruction, from Q&A 970 that in reporting the value should be given as a % and NOT in years (which is particularly tricky to interpret given that for the financial concept of duration is essentially both years and a percentage, at least in practical usages of it the two they are often interchangeable).\n\nOur understanding of the difference between these two is the differing treatment of early redemption options: modified duration (as per EIOPA \"Guidelines on the treatment of market and counterparty risk exposures in the standard formula\" GL#2 and the Appendix) should use stochastic methods to treat the uncertainty of such options being utilised whereas residual modified duration is a simpler measure to calculate as it assumes the bond is redeemed at the first call date.\n\nIn any case, we hope with a simple example our understanding will be confirmed by EIOPA (as it will cover very many practical cases) but if not it should help us understand better the difference in the definitions between the two terms:\n- ‘residual modified duration’ as required for S0602 C0360 and S0801 C0230; and\n- 'modified duration' as required for, inter alia, SCR spread risk Art 176\n\nExample:\nFor a fixed coupon bond with no call or put options i.e. a plain vanilla bullet bond; let's say the modified duration is 2.5 years. Are we correct to state that, in general, we should also report this in S.06.02 C0360 as 2.5 (and it should be 2.5 and not 0.0250)?\nFurther, same question but in this case the coupon is variable (but there are still no early redemption options) - would the modified duration and residual modified duration be the same (setting aside that the duration required to be used in Art 176 has a minimum value of 1)?\n\nOr there is some fundamental difference between the definitions of these two terms (other than the difference in treating early redemption options) than even in such cases the durations should differ between these two purposes?\n\nAnd ultimately, we request whether EIOPA can consider unifying the duration used in S.06.02 and that used in SCR (such as spread risk) as an improvement for filers (is there really a significant benefit in having two, seemingly almost exactly the same, definitions for duration?).","Public","Solvency II Solutions","The instructions define this item as the modified duration calculated based on the remaining time for maturity of the security, counted from the reporting reference date. The notion of residual was introduced to make clear that what is required is the modified duration at the reporting reference date and not the initial duration, calculated at the issue date.\n\nThe common definition of modified duration is “the effect that a 100-basis-point change in interest rates will have on the price of a bond”, thus the requirement for a percentage in this item.  \n\nThe Macaulay duration is commonly defined as the weighted average term to maturity of the cash flows from a bond. \n\nFrom an investments analysis point of view, it may be more adequate to measure the impact on a bond portfolio from a shift in the interest rates, which is directly obtained from modified duration reported as a percentage."]
["Reporting","s.08.01","Both","General comment as this concept applies in several places in the instructions. We feel it would be beneficial if EIOPA could clarify (either in the general comment section to S.08.01 or in indivdual field guidance) whether references to OTC derivaitves includes (or makes any distinction between non- and) cleared OTC derivatives (as per EMIR definitions) and, where applicable, if the counterparty information for such derivatives should be the CCP or the \"end counterparty\"","Public","Solvency II Solutions","OTC derivatives are the ones not traded through an exchange market. When a derivative is cleared through a CCP, the CCP is the counterparty."]
["Reporting","s.08.01","Both","Can C0270 clarify that this counterparty code should tie in with the C0260 e.g. it's not 100% clear to us (but may be our lack of knowledge in this niche) for the case of an exchange traded derivative whether C0270 should also (like in C0260) give the code of the exchange as opposed to the CCP \"behind\" the exchange","Public","Solvency II Solutions","Yes, it should tie to item C0260"]
["Reporting","S.26.02","Both","A useful clarification (and if possible, aligning with S.08.01 approach regards derivatives) would be whether the singlename to be used in reporting is (for exchange traded derivatives) that which derives from the exchange or CCP  and (for cleared OTC derivatives) that which derives from the CCP or the \"end counterparty\"","Public","Solvency II Solutions","Please note that the instrucions of item C0260 provide guidance for  this. It should be the name of the exchange market for exchanged traded derivatives; or the name of Central Counterparty (‘CCP’) for Over–The–Counter derivatives where they are cleared through a CCP; or  the ame of the contractual counterparty for the other Over–The–Counter derivatives."]
["Reporting","S.31.01","Both","We feel this is an opportunity to clarify a commonly held uncertainty on S.31.01; namely, how (if) to report recoverables where the reinsurer is not actually known at the time of reporting.\nAs per GL#78 of EIOPA GL on Valuation of Technical Provisions, it is possible that the precise make up of the reinsurer (panel) counterparties relating to recoverables recognised in the balance sheet is not known at the reference date.\nHow, and if, should these be reported in S.31.01? And regardless could the general comment to S.31.01 clarify whatever the approach should be?\n\nNote: we are aware of in EIOPA Q&A#499, which touches on this point:\nQ/ 10. In S.31.01 is it admitted to report recoverables relevant to “unknown” counterparts ?\nA/ No, company needs to know from which entity the recoverables belong. If the counterpart is unknown how will the recoverables be received?\n\nBut we don't believe this EIOPA answer complies with TP GL#78 (it implies GL#78 never applies) and hence we're not sure if it is infact correct not to include these cases in S.31","Public","Solvency II Solutions","EIOPA confirms that the reinsurance should be included in this case. Considering that the replacement of the reinsurance arrangement should not be conditional on any future event which is outside of the control of the insurance or reinsurance undertaking (GL 78.c) it should be possible to fill identify the reinsurer on best effort basis."]
["Reporting","S.31.01","Both","Can EIOPA add any clarity as to when C0155 would not be applicable? Does it relate to materiality as we don't see any materiality threshold in S.31.01, which seems slightly strange given the currency inclusion was (Seemingly) introduced to cover the missing asset reporting from S.02.02, but S.02.02 had/has materiality thresholds.","Public","Solvency II Solutions","The breakdown by currency will only be required to cover 90% of reinsurance recoverables. For the remaining 10% it will be possible to group it under \"other currencies\"."]
["Reporting",null,"Both","In general, EIOPA use the term \"premiums written\" (in new QRTs such as S.04.04 but also in old QRTs like S.05.01) whereby we believe most users would (for the given definition) use the terms \"premiums receivable\". Not sure if EIOPA would consider this suggestion (appreciate you probably don't want to rename all such fields though).","Public","Solvency II Solutions","Further clarification have been introduced in S.05.01 to clarify the reporting in case of IFRS 17 users."]
["Reporting","S.27.01","Both","We feel this is an opportunity to clarify some commonly held uncertainties on S.27.01 regards reporting the results of aggregate reinsurance covers.\n\nFor example, in the windstorm section columns C0100 and C0110. The context being that C0120 must be C0090-C0100+C0110 as per BV271 (Blocking validation).\n\nThis is problematic because reinsurance recoverables are not actually actually against that gross (disaggregated) loss in C0090; C0090 is before (higher level) diversification benefits (e.g. with non-EEA windstorm losses) but the risk mitigation must be applied post such diversification (if the reinsurance relates to an aggregate cover an a higher level of losses eg global) being applied (and the gross loss at the region level thus being updated to a different, lower amount, that takes into account the diversification benefit between EEA and non-EEA).\nHence we have for reporting a gross and risk mitigation on two different bases and the resulting net SCR (C0120) is incorrect (unless we manipulate, presumably C0100 and C0110, in some way).\n\nFor example:\nAssume following gross (disaggrated, within their respective regions) losses\n- Ireland gross SCR (C0090 R0480) of 1000\n- US gross SCR (C0090 R0790) of 1000\n\nWith, for simplicity, only one reinsurance cover being an aggregate global cover of 1500 XL 500 and no resinstatement premiums.\n\nAs per GLs on application of RI program for CAT module, the total WS SCR (applying diversification) is calculated as 1414 (QRT(1000^2+1000^2). The XL cover is applied against this loss and hence we have retained (global, net) SCR of 500 and recoverables of 914. At this stage we seek guidance on how to report this:\n- should we diaggregate the reinsurance recoverables of 914 to Ireland and US rows in S.27.01 ie C0090 R0480 of 457 and C0090 R0790 of 457 (but this gives an incorrect C0120 amount for both rows as the net SCR for both is not 543); or\n- should we diaggregate the net SCR of 500 to Ireland and US rows in S.27.01 ie C0120 R0480 of 250 and C0120 R0790 of 250 (and then \"back-out\" from here the reinsurance recoverables in C0100 as 750 in both rows)\n\nObviously the latter option respects BV271 and allows the total net SCR to be calculated from the individual S.27.01 (region) row net SCR values (although see next question for reporting net total diversification amount) - but it is incredibly complicated to do, particularly where we have more compliated reinsurance programmes with different aggregate cover levels eg regional and then global and recoverables and reinstatements.\n\nFurther, could EIOPA please extend their answer the above question to explain how the subsequent total diversification of net SCR should be reported (eg for windstorm the data point C0120 R0810). We are very confused by this data point because in pretty much any conceivable approach the individual net SCR amounts reported already take into account diversification via the disaggregation applied in generating the gross losses - so conceptually reporting diversification benefits of net SCRs is seemingly irrelevant.","Public","Solvency II Solutions","C0090-C0120 should be after diversification effects, including R0600 which will be amended accordingly. BV271 will be deactivated to report the right amount in C0120."]
["Reporting","S.30.03","Solo","We feel this is an opportunity to clarify a commonly held uncertainty on S.30.03; namely the scope of the template. \n\nWe've included in this consultation response two highest level concerns/questions we have but there are many situations that are difficult to know how to report in S.30.03 (and we feel the new columns, particularly C0430, exacerbate/highlight the lack of workable guidance for S.30.03 given how complex reinsurance programs can be and further to LOG improvements explanatory notes would be very welcome).\n\nTopic 1 > Scope of S.30.03/04\n\"Period of validity\" is quite unclear to us, can EIOPA advise the scope of reinsurance contracts to be included in S.30.03, based on the following examples:\n-- Contract is Risks attaching/losses occuring/Claims-made basis (often with associated cut-off dates eg claims-made basis may include a cut-off of X years for the reinsurance to be valid)\n-- Regardless of above contractual basis, can EIOPA advise in clear terms such as \"S.30.03 should include all reinsurance contracts for which there is a related cash-flow within the Best Estimate\" eg it's currently unclear if a losses occuring based RI contract from previous years, for which there are related unsettled claims (either known or unknown) should be included within S.30.03","Public","Solvency II Solutions","The validity period should cover the period in which the reinsurance would cover a new risk, a loss that arose or a claim that was settled  depending whether the contract is risk ataching/ loss occuring / claims-made basis. \n\nThe scope of the template includes all reinsurance contracts that are still relevant for the undertaking, i.e. all contracts that are covering obligations within contract boundaries."]
["Reporting","S.30.03","Solo","Topic 2 > Multi-year program (with changing reinsurer panel year-on-year)\nTaking up from Q&A 1536: in this question it is noted that the reinsurance panel is different between the two periods/contracts but EIOPA advise that a \"single entry\" is entered in S.30.03 (which has information on limits etc.) but this then makes S.30.04 misleading in our view as one \"share reinsurer\" amount appears \"diluted\" whereas in reality it isn't becessarioy. \nWe feel such scenario are not handled correctly as per this Q&A and we feel the ITS should have (some, appreciate Q&A and/or explanatory notes would still be needed to cover more specific scenarios) some (better) guidance on how to treat multi-year contracts as this is obviously very common scenario. \nWe would suggest that it is important for users of S.30.03 to discern the panel per contract period, and hence either S.30.03 program info (ie columns C0010 through C0050) should be made different per contract period and/or S.30.04 also includes some Validity period column(s)","Public","Solvency II Solutions","EIOPA understands the issue and agrees to use different ID codes in S.30.03 every time the panel of reinsurers changes."]
["Reporting","S.30.03","Solo","New column C0420 we feel could do with some clarifications. Is this the sum of S.30.04 C0100 for the matching C0010-C0050? And if so why actually introduce this new data point if it's already available (can be derived) within the submitted data?","Public","Solvency II Solutions"," It should include the maximum coverage per layer of a reinsurance treaty. It should not coincide with the sum of S.30.04 C0100 for the matching C0010-C0050, as C0100 is a percentage and this cell is a monetary amount. The LOG has been improved."]
["Reporting","S.30.03","Solo","New column C0430 we feel could do with some clarifications e.g. is this ordering: within the reinsurance program code (ie C0010); or a lower level; or the entire program? \nGiven the complex nature of reinsurance programs and the fact they can relate to different risks attaching/losses occuring/Claims-made bases it is not necessarilty straightforward to \"order\" these across the whole program so some additional clarity would help.\nAlso we have to consider that S.30.03 should only be reported for the dominant LoB (and currency, where it covers multiple on same terms) e.g. if an LoB is covered (forgetting complications around different risk attaching bases etc.) by a multiline cover (where this LoB is not dominant) but also has  specific cover for that LoB it's not clear even with the ordering information that for this LoB the multiline cover comes into effect for this LoB before the specific LoB one. ","Public","Solvency II Solutions","This cell has been deleted. "]
["Reporting","S.26.08","Both","The top label \"Solvency Capital Requirement - for undertakings using an internal model\" could be made clearer to indicate also relevant for PIM","Public","Solvency II Solutions","\"Internal model\" is a general term that covers both partial and full internal models."]
["Reporting","S.29.03","Solo","In the annotoated template there are some improvements we think that can be made to make it clearer this is for life business only. Also it still has references to underwriting-year basis, which we believe is no longer necessary and hence a bit confusing.\nWe have the same comment for S.29.04 (also please note that the annotated template for S.29.04 still includes the accident year basis section).\nThe general comment to S.29.03 still includes the sentance:\n\"Undertakings are required to report data on accident year or underwriting year basis, in \naccordance with any requirements of the National Supervisory Authority. \"\nBut this doesn't appear necessary any longer for this template.\n","Public","Solvency II Solutions","Please note that following comments received EIOPA decided to keep the currents S.29s templates and not introduce the changes as publicly consulted in this ITS amendments package. Due to the dismissal of changes to S.29s, this comment is no longer relevant."]

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["Reference","lstName",null,null,"Reporting",null,"Disclosure",null,"Financial stability guidelines",null,"Third countries branches GLs",null,"Sustainable fnance questions",null,"LAC DT ",null,"Group reporting questions",null,"Impact assessment",null,"Other",null,"SoloGroupBoth",null,"PublicConfidential"]
["Reporting",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstReporting"},null,null,"S.01.01",null,null,null,null,null,null,null,"1. Do you consider relevant to introduce a materiality threshold for the reporting requirement on the share of sustainable investments for undertakings not subject to the Non-Financial Reporting Directive (NFRD)? If so, which threshold would you propose?",null,"Do you agree with the proposed threshold?",null,null,null,null,null,null,null,"Both",null,"Confidential",null,"Basic Information - RFF and matching adjustment portfolios"]
["Disclosure",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstDisclosure"},null,null,"S.01.02",null,null,null,null,null,null,null,"2. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related transition risk? If so, which threshold would you propose? ",null,"Other",null,null,null,null,null,null,null,"Group",null,"Public",null,"Basic Information - General"]
["Financial stability guidelines",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstFinancial_stability_guidelines"},null,null,"S.01.03",null,null,null,null,null,null,null,"3. What could be a methodology for standardised reporting of climate change-related physical risk exposure for other investments than property?",null,null,null,null,null,null,null,null,null,"Solo",null,null,null,"Content of the submission"]
["Third countries branches GLs",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstThird_countries_branches_GLs"},null,null,"S.02.01",null,null,null,null,null,null,null,"4. Do you consider relevant to introduce a materiality threshold for reporting the share of investments exposed to climate change-related risk? If so, which threshold would you propose?",null,null,null,null,null,null,null,null,null,null,null,null,null,"Balance sheet"]
["Sustainable finance questions",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstSustainable_finance_questions"},null,null,"S.02.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Assets and liabilities by currency"]
["LAC DT ",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstLAC_DT"},null,null,"S.02.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Additional branch balance sheet information"]
["Group reporting questions",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstGroup_reporting_questions"},null,null,"S.03.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Off-balance sheet items - general"]
["Impact assessment",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstImpact_assessment"},null,null,"S.03.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Off-balance sheet items - List of unlimited guarantees received by the undertaking"]
["Other",{"$f":"\"lst\"&SUBSTITUTE(TRIM(tblMainReference[[#This Row],[Reference]]),\" \",\"_\")","v":"lstOther"},null,null,"S.03.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Off-balance sheet items - List of unlimited guarantees provided by the undertaking"]
[null,null,null,null,"S.04.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Activity by country"]
[null,null,null,null,"S.04.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Information on class 10 in Part A of Annex I of Solvency II Directive, excluding carrier's liability"]
[null,null,null,null,"S.04.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Basic Information - list of underwriting entities"]
[null,null,null,null,"S.04.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Activity by country - location of underwriting"]
[null,null,null,null,"S.04.05",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Activity by country - location of risk"]
[null,null,null,null,"S.05.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Premiums, claims and expenses by line of business"]
[null,null,null,null,"S.05.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Premiums, claims and expenses by country"]
[null,null,null,null,"S.06.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Summary of assets"]
[null,null,null,null,"S.06.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"List of assets"]
[null,null,null,null,"S.06.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Collective investment undertakings - look-through approach"]
[null,null,null,null,"S.06.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Sustainable investments and climate change-related risks  to investments"]
[null,null,null,null,"S.07.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Structured products"]
[null,null,null,null,"S.08.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Open derivatives"]
[null,null,null,null,"S.08.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Derivatives Transactions"]
[null,null,null,null,"S.09.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Income/gains and losses in the period"]
[null,null,null,null,"S.10.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Securities lending and repos"]
[null,null,null,null,"S.11.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Assets held as collateral"]
[null,null,null,null,"S.12.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Life and Health SLT Technical Provisions"]
[null,null,null,null,"S.12.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Life and Health SLT Technical Provisions - by country"]
[null,null,null,null,"S.13.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Projection of future gross cash flows"]
[null,null,null,null,"S.14.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Life obligations analysis"]
[null,null,null,null,"S.14.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Non-life business - policy and customer information"]
[null,null,null,null,"S.14.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Cyber risk"]
[null,null,null,null,"S.15.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Description of the guarantees of variable annuities"]
[null,null,null,null,"S.15.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Hedging of guarantees of variable annuities"]
[null,null,null,null,"S.16.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Information on annuities stemming from Non-Life Insurance obligations"]
[null,null,null,null,"S.17.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Non-Life Technical Provisions"]
[null,null,null,null,"S.17.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Non-Life Technical Provisions - By country"]
[null,null,null,null,"S.18.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Projection of future cash flows (Best Estimate - Non Life)"]
[null,null,null,null,"S.19.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Non-life insurance claims"]
[null,null,null,null,"S.20.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Development of the distribution of the claims incurred"]
[null,null,null,null,"S.21.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Loss distribution risk profile"]
[null,null,null,null,"S.21.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Underwriting risks non-life"]
[null,null,null,null,"S.21.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Non-life distribution of underwriting risks - by sum insured"]
[null,null,null,null,"S.22.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Impact of long term guarantees measures and transitionals"]
[null,null,null,null,"S.22.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Information on the transitional on interest rates calculation"]
[null,null,null,null,"S.22.05",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Overall calculation of the transitional on technical provisions"]
[null,null,null,null,"S.22.06",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Best estimate subject to volatility adjustment by country and currency"]
[null,null,null,null,"S.23.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Own funds"]
[null,null,null,null,"S.23.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Detailed information by tiers on own funds"]
[null,null,null,null,"S.23.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Annual movements on own funds"]
[null,null,null,null,"S.23.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"List of items on own funds"]
[null,null,null,null,"S.24.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Participations held"]
[null,null,null,null,"S.25.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - for undertakings on Standard Formula"]
[null,null,null,null,"S.25.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - for undertakings on Full Internal Models"]
[null,null,null,null,"S.25.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement [Financial Stability]"]
[null,null,null,null,"S.25.05",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - for undertakings using an internal model (partial or full)"]
[null,null,null,null,"S.26.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Market risk"]
[null,null,null,null,"S.26.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Counterparty default risk"]
[null,null,null,null,"S.26.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Life underwriting risk"]
[null,null,null,null,"S.26.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Health underwriting risk"]
[null,null,null,null,"S.26.05",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Non-Life underwriting risk"]
[null,null,null,null,"S.26.06",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Operational risk"]
[null,null,null,null,"S.26.07",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Simplifications"]
[null,null,null,null,"S.26.08",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - for undertakings using an internal model (partial or full)"]
[null,null,null,null,"S.26.09",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Market & credit risk and sensitivities"]
[null,null,null,null,"S.26.10",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Credit event risk Portfolio view details"]
[null,null,null,null,"S.26.11",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Credit event risk for financial instruments"]
[null,null,null,null,"S.26.12",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Credit risk Non-Financial Instruments"]
[null,null,null,null,"S.26.13",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Non-life & Health Non-SLT"]
[null,null,null,null,"S.26.14",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Life & Health risk"]
[null,null,null,null,"S.26.15",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Operational risk"]
[null,null,null,null,"S.26.16",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Internal model - Model Changes"]
[null,null,null,null,"S.27.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Solvency Capital Requirement - Non-life and Health catastrophe risk"]
[null,null,null,null,"S.28.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Minimum Capital Requirement - Only life or only non-life insurance or reinsurance activity"]
[null,null,null,null,"S.28.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Minimum Capital Requirement - Both life and non-life insurance activity"]
[null,null,null,null,"S.29.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Excess of Assets over Liabilities"]
[null,null,null,null,"S.29.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Excess of Assets over Liabilities - explained by investments and financial liabilities"]
[null,null,null,null,"S.29.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Excess of Assets over Liabilities - explained by technical provisions"]
[null,null,null,null,"S.29.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Detailed analysis per period - Technical flows versus Technical provisions"]
[null,null,null,null,"S.29.05",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Detailed analysis per period - Analysis of changes of Best Estimate Non-Life"]
[null,null,null,null,"S.30.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Facultative covers for non-life and life business basic data"]
[null,null,null,null,"S.30.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Facultative covers for non-life and life business shares data"]
[null,null,null,null,"S.30.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Outgoing Reinsurance Program basic data"]
[null,null,null,null,"S.30.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Outgoing Reinsurance Program shares data"]
[null,null,null,null,"S.31.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Share of reinsurers (including Finite Reinsurance and SPV's)"]
[null,null,null,null,"S.31.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Special Purpose Vehicles"]
[null,null,null,null,"S.32.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Undertakings in the scope of the group"]
[null,null,null,null,"S.33.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Insurance and Reinsurance individual requirements"]
[null,null,null,null,"S.34.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Other regulated and non-regulated financial undertakings including insurance holding companies and mixed financial holding company individual requirements"]
[null,null,null,null,"S.35.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Contribution to group Technical Provisions"]
[null,null,null,null,"S.36.00",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"IGT - Summary template"]
[null,null,null,null,"S.36.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"IGT - Equity-type transactions, debt and asset transfer"]
[null,null,null,null,"S.36.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"IGT - Derivatives"]
[null,null,null,null,"S.36.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"IGT - Off-balance sheet and contingent liabilities"]
[null,null,null,null,"S.36.04",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"IGT - Insurance and Reinsurance"]
[null,null,null,null,"S.36.05",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"IGT - P&L"]
[null,null,null,null,"S.37.01",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Risk concentration"]
[null,null,null,null,"S.37.02",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Risk Concentration – Exposure by currency, sector, country"]
[null,null,null,null,"S.37.03",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Risk Concentration – Exposure by asset class and rating"]