Question ID: 1400
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 25 Apr 2018
Question
Currently, there is a mismatch between the instructions for column C0080 in ITS 2015 2450 and XBRL business validation BV34.
This appears to be rectified in the proposed Amendments to the adopted Solvency II Technical Standards on Reporting and Disclosure that was consulted on earlier this year.
My issue is that the proposed remediation will harmonise the ITS to the XBRL validation but I think there is a problem here...
The Undiscounted Development Result will be the Provision at the start of the year minus Annuity Payments during the year minus the Closing Provision...
There is no reference to Annuity Provisions set up during the year. Further, it is feasible that an annuity payment could be made on a provision created during that year, thus rendering the formula in C0080 invalid.
Do you agree that there is a problem here (now and in the proposed amendment to the ITS)?
EIOPA answer
The validation reflects the Instructions for the cell as amended by Commission Implementing Regulation (EU) 2016/1868 of 20 October 2016.
It is acknowledged that there are two possible approaches to analyse the undiscounted development result with different pros and cons.
In any case supervisors have enough information being reported in the template to perform alternative indicators like the one described if they wish to do so.