Question ID: 1512
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.29.04
Status: Final
Date of submission: 03 Apr 2018
Question
We want to confirm our understanding on item 992. "EIOPA confirms that for each LoB reported in S.29.04 only "Underwriting Year" or "Accident Year" should be reported."
For eg, case 1) contract A and contract B are both under one LoB, say 37-life. Case 2) Best Estimate under one tpye of contract (belongint to LoB 37-life) is composed by two parts: discounted future cashflows A plus outstanding claims B which is not included in A. Then should A and B be reported to the same category(either Underwriting Year or Accident), or could they be reported differently, say A is under Underwritig Year and B is under Accident Year?
EIOPA answer
The template is divided in between obligations managed by underwriting year (R0010 to R0140) and obligations managed by accident year (R0150 to R0290). Undertakings are required to report data on an accident year or underwriting year basis, in accordance with any requirements of the National Supervisory Authority. If the National Supervisory Authority has not stipulated which to use then the undertaking may use accident or underwriting year according to how they manage each line of business, as defined in Annex I to Delegated Regulation (EU) 2015/35, provided that they use the same consistently, year on year.
This question is applicable mostly for non-life and annuities business. In life business, other than annuities, it is expected underwriting year. This choice is not related to how the best estimate is calculated and which item compose the best estimate but rather, when information is requested by years (or periods in case of S.29.04) in each year/period the contract relates to.