Question ID: 1977
Regulation Reference: Guidelines on reporting and public disclosure
Topic: Reporting Templates
Article: 35
Template: S.04.01
Status: Final
Date of submission: 01 Jul 2019
Question
A Dutch reinsurer accepts business from Thailand (directly, not via a branch). Is our understanding correct that this should not be reported in s.04.01, as this concerns only freedom to provide services and freedom of establishment (inside the EU)? Where should this reinsurer report the business accepted from Thailand?
EIOPA answer
Because Template S.04.01 only asks for information on Premiums, Claims and Commissions regarding:
- Business underwritten in the home country, by the undertaking
- Business underwritten through FPS, by the undertaking in the EEA countries different from the home country
- Business underwritten through FPS in the home country, by any EEA branch
- Total business underwritten by all EEA branches in the country where they are established
- Total business underwritten through FPS, by all EEA branches
- Total of the business underwritten through FPS by the undertaking and all EEA branches
- Total business underwritten by all non-EEA branches
If the reinsurance business is performed by any material non-EEA country branches please reported the amounts in S.04.01.C0110. If the reinsurance business is issued by subsidiaries, please note that the template is only applicable at individual level and should not be reported at group level.
EIOPA clarifies, that business underwritten (direct business and accepted reinsurance) by the undertaking, by any of its EEA branches or by a non-EEA branch from outside EEA is considered cross-border business and has to be included in S.04.01. “Activity by country":
- Business underwritten (direct and accepted reinsurance) by non-EEA branches is to be reported in C0070 and, where country is material, in C0110 by country.
- Business underwritten (direct business and accepted reinsurance) from outside the EEA by the undertaking (and not by a branch) is to be reported in C0010.
- Business underwritten (direct business and accepted reinsurance) outside the EEA by an EEA branch, is to be reported in C0040 and, for the country where the branch is established, in C0080.
- Total business underwritten by all EEA branches in the country where they are established
- Total business underwritten through FPS, by all EEA branches
- Total of the business underwritten through FPS by the undertaking and all EEA branches
- Total business underwritten by all non-EEA branches
According to the second bullet point the business in Thailand has to be reported under C0010, as home business.