Question ID: 1171
Regulation Reference: (EU) No 2015/2451 - templates and structure of the disclosure of specific information by supervisory authorities
Topic: Disclosure Templates
Article: 317
Status: Final
Date of submission: 16 Feb 2017
Question
The delegated act (article 317) states that “Aggregated annual statistical data concerning the supervised undertakings and groups in accordance with Article 316 shall be disclosed in respect of each calendar year within three months after the date by which the undertakings having a financial year ending 31 December are required by Article 312(1)(c) to submit annual quantitative templates.”
A strict reading of article 317 can imply that NSA have to publish the aggregated data on insurers and on groups at the same time. However, as NSA receive annual quantitative template of groups 6 weeks later than the solo, it would be difficult to disclose aggregated group data at the same date. Can we then consider that the extension of the deadlines established by article 373 (“deadlines referred to in Article 312 shall be extended by 6 weeks” ) for the group is also applicable to NSA disclosures ?
EIOPA answer
Considering the reference in the delegated regulation to the annual reporting (reference in article 317 of the Commission Delegated Regulation (EU) 2015/35 to Article 312 of the Commission Delegated Regulation (EU) 2015/35), NSAs can disclose aggregate data for solo and groups separately 3 months after the respective reporting deadlines for solo insurers and groups.