There is a difference in the ITS description for S.13  “Future Benefits” and S.12 R0230 “Future guaranteed and discretionary benefits”. Differences in ITS descriptions do not exist for any other cashflow type, ie. Future expenses and other cash out-flows, Future premiums, Other cash in-flows.

For example, consider a Unit-Linked contract with a surrender option but with no guarantees (ie. where surrender value basis is pre-determined but amount not guaranteed).

It seems correct, based on the ITS and SII Delegated Regulation,  to include such future surrender benefits in the BE (S.12 R0030) and also in the S.13 Future Benefits (C0050).

However, it is not clear from the ITS whether such surrender benefits should be included in S.12 C0030 R0230 (Future guaranteed and discretionary benefits), as future unit-linked surrenders are not guaranteed in amount and also explicitly excluded from the description of discretionary benefits.

Can you please advise whether such surrenders are to be included in S.12 C0030 R0230 and so consistent with present value of the S.13 C0050?