As per your definition

Undertaking specific reinsurance code that links the dominant treaty of reinsurance programme which also protects the risk covered by the facultative reinsurance. The Reinsurance program code shall be in line with the Reinsurance program code of S.30.03 - Outgoing Reinsurance Program in the next reporting year.

The field allows to link the risk reinsured on a facultative basis with the treaty program that eventually reinsures the same risk. The field is mandatory but this means that a risk should always be protected by a treaty protection. Perhaps the definition should be modified explaining that even if a risk is not protected by a treaty the fields has to be filled with a code that group all possible facultative cessions (if there is one, just one)

Furthermore, on the same field, recently we have already arose the following question: if we speak about End Year 2017 reporting, in S.30.03 treaties whose period of validity includes or overlaps year 2018 (the majority with inception date 01/01/2018) are reported. If in S.30.01 (End Year 2017) a risk with inception date 25/12/2017 and expiry date 24/12/2018 is reported and this risk is covered also by a treaty cession (risk attaching) with inception date 01/01/2017 and expiry date 31/12/2017 (not reported in S.30.03 relevant End Year 2017 but already reported in S.30.03 End Year 2016) the field has to be filled?

Your answer is

In your example you should not connect the risk reported in S.30.01 with the treaty cession with inception date 01/01/2017 (not reported in S.30.03) but connected to the current treaty cession active in 2018.

If we follow this rule we report that the risk is protected by a wrong treaty cession (2018) that for example could have a different reinsurer panel. Or the treaty could have been not renewed in 2018. How we managed this ?

EIOPA answer

Please be aware that in the draft proposal for the ITS amendments we have clarified that S.30.01 is prospective and as such should reflect the treaties effective and valid during the next reporting year for the selected 10 most important risks in terms of reinsured exposure for each line of business. The most important risks of the next reporting period for which the validity date of the treaties cover as well the next reporting period should be reported.

Your proposal regarding clarification in the instructions of C0020 "Reinsurance program code" will be considered during the next ITS amendment.