Q&A

Question

Could you please clarify what is the intention of the aricle 4 relating to the re-submission of the reported information? What kind of circumstances should result in re-submission? Beside general answer please confirm or adjust our understanding of the below specific circumstances regarding information reported for Q4:

1) a material error or fraud idenfitied by the company after the first submission (for example in S.02.01, S.06.02, S.08.02) --> re-submission required;

2) material auditor's adjustments identified during the review of annual information --> re-submission of Q4 not required; the auditor's adjustments must be included in the annual report (or if annual information already reported --> in the re-submission of the annual report);

3) material changes resulting from different methodology of valuation between 4Q and annual reporting (for example, according to the Delegated Act, the methodology of calculation of technical provisions and/or capital requirements can differ between quarterly and annual periods) --> re-submission of Q4 not required, because annual information is most likely to differ from 4Q due to lack of simplifications in annual methodology;

4) material change in valuation of participation resulting only from different methodology of calculation between quarterly and annual periods (as above mentioned in the point 3) --> re-submission of 4Q not required; such changes must be included in the annual report. Maybe in a such situation the final S.06.02 should be reported within annual report using the option 1 in S.01.01.01?;

5) material change in valuation of assets included in S.06.02 / S.08.01 resulting from impairment (i.e. the receipt of information after the balance sheet date indicating that an asset was impaired at the balance sheet date, or that the amount of a previously recognised impairment loss for that asset needs to be adjusted) --> re-submission of 4Q not required, but changes in valuation must be included in the annual report (short time between submission of 4Q and annual information) and the final S.06.02 / S.08.01 must be reported within annual report (option 1 in S.01.01.01). We understand that if the impairment relates to other quarters (Q1, Q2 or Q3) --> re-submission is required.

EIOPA answer

1) We confirm, in fact for any template in case of fraud or material error information should be submitted;

2) It depends. In case the mistake affects the list of assets or list of derivatives, which annual submission is not due when Q4 was submitted, then also Q4 for these templates need to be submitted. An annual submission of this templates to correct the mistake in the Q4 submission is not adequate;

3) We confirm, the ITS indicate the cases where this is expected, namely in the Balance-sheet and technical provisions (article 7);

4) No, in case the mistake affects the list of assets or list of derivatives, which annual submission is not due when Q4 was submitted, then also Q4 for these templates need to be submitted. An annual submission of this templates to correct the mistake in the Q4 submission is not adequate;

5) No, in case the mistake affects the list of assets or list of derivatives, which annual submission is not due when Q4 was submitted, then also Q4 for these templates need to be submitted. An annual submission of this templates to correct the mistake in the Q4 submission is not adequate. In the other cases resubmission of quarterly information is also required.