Q&A

Question

Regarding QRTs 36.01, 36.02, 36.03, 36.04 (the QRTs regarding internal transactions), we have the following question:



In the respective (solo) log file passage, it says for the four mentioned QRTs:

"The insurance undertaking ... for IGTs between the individual undertaking and the mixed–activity insurance holding company and its related undertaking"



Arguing that those QRTs should only be filled with transactions if the respective solo insurer is part of a mixed-activity holding company (group), and therefore empty whenever an insurance company is not part of a mixed-activity holding company.



However, in the log file defining QRT S.01.01, where it is determined whether the respective S.36.xx QRT will be submitted, the only suitable option is:

    "12 – Not reported as no parent undertaking is a mixed–activity insurance holding company where they are not part of a group as defined under Article 213 (2) (a), (b) and (c) of Solvency II Directive [i.e. a normal insurance-only group]"

(other options being: 1 - Reported, 2- Not reported as no IGT, 0 - Not reported for other reason)



What does that mean regarding solo insurance companies belonging to a normal insurance-only group (according to Art. 213 2(a,b,c)) and having IGT transactions (i.e. the standard case)?

According to the log file for QRT 36.xx, this QRT should be empty, because the undertaking is not part of a mixed-activity insurance holding, but the only suitable option in S.01.01 is 12, which however cannot be applied in its current form, because the undertaking under consideration is part of a group as defined under Article 213 (2) (a), (b) and (c) of Solvency II Directive [i.e. a normal insurance-only group].



Is it possible that there is a typo in option 12 of S.01.01 and the intention was that it means:  

    "12 – Not reported as no parent undertaking is a mixed–activity insurance holding company where they are part of a group as defined under Article 213 (2) (a), (b) and (c) of Solvency II Directive [i.e. a normal insurance-only group]"

    ["not" omitted].

This choice would mean that solo insurance companies that are part of a regular insurance group (according to Article 213 (2) (a), (b) and (c) of Solvency II Directive) would not have to report the S.36.xx QRT, which is empty anyway given the log file definition.



It would make sense, because for such solo insurance companies, the same QRT would have to be submitted on group level, containing all the relevant information from the solo subsidiaries and therefore submission on the solo level would be redundant. 

EIOPA answer

Your interpretation of the requirements is correct, i.e. an undertaking belonging to a "group referred to in points (a), (b) or (c) of Article 213(2) of Directive 2009/138/EC " is not required to report the template at a sololevel. In this case the reporting of IGTs is performed only at group level.



Templates S.36.s should be reported only by individidual undertakings which are not part of a group referred to in points (a), (b) or (c) of Article 213(2) of Directive 2009/138/EC and the parent undertaking of which is a mixed-activity insurance holding company.



Option 12 is to be used in the following situations:



- undertaking belongs to a group referred to in points (a), (b) or (c) of Article 213(2) of Directive 2009/138/EC



- undertaking does not belong to a group referred to in points (a), (b) or (c) of Article 213(2) of Directive 2009/138/EC, and the parent undertaking is not  mixed-activity insurance holding company.



The text of the option could be improved in the future.