Question ID: 16
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 13, 35
Template: S.32.01
Status: Final
Date of submission: 28 Jan 2014
Question
Please confirm our understanding of how to report "third country insurance and reinsurance entities" in QRT G01-L-S.32.01.
Article 13(1) of the Solvency II Directive defines insurance undertakings as European only.
Article 13(3) separately defines "third country insurance undertakings"
• The LOG for QRT G01-L-S.32.01 gives a list of "types of undertaking" in cell D1, but this list does not mention third country insurance / reinsurance undertakings. As such third country insurance / reinsurance undertakings will be classified as "13. Other"
• Cell H1a “Total Balance Sheet (for (re)insurance undertakings)” will include European insurance undertakings, but will exclude third-country insurance / reinsurance undertakings because these will be shown in Cell H1b
• Cell I1a will include written premium of European insurance and reinsurance undertakings, but will exclude third-country insurance / reinsurance undertakings because these will be shown in Cell I1b
• Cells J1 and K1 will only be populated for European Insurance / reinsurance undertakings. No underwriting or investment performance measures will be shown for third country insurance / reinsurance entities.
Is the above correct?
EIOPA answer
In relation to the treatment of third country insurance or reinsurance undertakings in template S.32.01 (G01) please consider the following clarifications:
• The cell D1 “Type of undertaking” classifies the type of undertaking according to the activity, therefore a third country insurance or reinsurance undertaking should be classified as 1, 2 or 3, according to its activity;
• The cell H1a “Total Balance Sheet (for (re)insurance undertakings)” should include the Total BS for the third country insurance or reinsurance undertakings. In the this case local GAAP should be used and not Solvency II BS as indicated in the LOG;
• Cell I1a “Written premiums net of reinsurance ceded under IFRS or local GAAP for insurance undertakings” should include the written premiums for the a third country insurance or reinsurance undertakings;
• Cells J1 “Underwriting performance if applicable” and K1 “Investment performance” should also be reported for the third country insurance or reinsurance undertakings.
The definition of the referred cells in Annex II (LOGs) will be improved and further clarified in the future ITS, e.g. the references to solvency II only apply to EU insurance and reinsurance undertakings.