Question ID: 1128
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 20 Apr 2017
Question
We are wondering about the treatment of reinsurance receivables and payables in the SII balance sheet. In the comment to the position it is defined as past-due receivables and payables. The strict interpretation of this definition in Germany led to the result that all reinsurance receivables in the German market will be shown as claims reserves and the position R0370 and R0830 will be zero. We are not sure that this was the intention of EIOPA.
However, reinsurance receivables and payables consist of premium, provisions and claims receivables and payables. There is any insecurity about the amount of these positions. In our opinion the consideration as claims reserve is inappropriate and misleading. May you can help us and explain your original intention or the correct interpretation.
EIOPA answer
Past-due premiums or cash-flows and premiums or cash-flows that are due for payment by the valuation date should be recognised as receivables, i.e. not in the technical provisions. Cash-flows of premiums due for payment from the valuation date onwards and that are within the contract boundary are included in the technical provisions.