Can we ask EIOPA to reconsider/confirm their answer to 1732: "In S.12.01 it is expected that C150/R230 is equal to C150/R240 + C150/R250" as it seems to contradict the initial purpose of having the R0230 line available in the first place (and not just R0240 and R0250).

Taking a company that only write UL/IL business as an example; future benefits does not need to be split into guaranteed or discretionary type in C0030, but for the EIOPA answer to 1732 to work this will have to be done for the purposes of populating C0150 R0230, R0240 and R0250.

However, splitting UL/IL business into these sub-components (guaranteed or discretionary) would seem to contradict EIOPA's earlier answer as to why S.12.01 C0030 only allows reporting in R0230:

Q&A 509 where EIOPA state: "According to recital (17) of the Commission Delegated Regulation 2015/35 “The definition of future discretionary benefits should capture the benefits of insurance and reinsurance contracts that are paid in addition to guaranteed benefits and that result from profit participation by the policy holder. It should not capture index-linked or unit-linked benefits.”. For this reason template S.12.01 only allows the reporting of future discretionary benefits for the LoB “Insurance with profit participation” (C0020). "

EIOPA answer

EIOPA agrees that there is no need to split UL/IL business into guaranteed or discretionary type and will accordingly review Q&A 1732.