Question ID: 1258
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.30.01
Status: Final
Date of submission: 02 Oct 2017
Question
Field C0020 "reinsurance programme code" allows to link the risk reinsured on a facultative basis with the treaty programme that eventually reinsures the same risk.
How has to be filled the field if the risk is not reinsured also on a treaty basis ? Has it to be left blank?
If we speak about reporting year 2017, usually in S.30.03 treaties with inception date in 2017 will be reported. If in S.30.01 a risk with inception date 25/12/2016 is reported and this risk is covered also by a treaty cession with inception date 01/01/2016 (not reported in S.30.03) the field has to be filled so it links the protection program 2017 ?
EIOPA answer
Assuming that reporting year 2017, is meant as the reporting with reference to 31/12/2017, both templates S.30.01 and S.30.03 are prospective and as such should reflect the treaties effective during 2018. In your example you should not report in S.30.01 risk with inception date 25/12/2016, if the treaty has a validity of one year. Please note that the inception date is not relevant. The validity date is the one to be considered to assess if treaties need to be reported or not.
This interpretation will be made clear in the Instructions of the template in a future opportunity.
In S.30.01, the code in C0020 should always be reported. This code is undertaking specific, covering all the individual reinsurance placements and/or treaties which belong to the same reinsurance program.