Question ID: 2074
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: 35
Template: S.25.03
Status: Final
Date of submission: 25 Nov 2019
Question
We would like to confirm that our interpretation of the reporting the revised SR.25.03.01 is correct. We note that the additional deferred tax disclosures for S.25.03 only applied at solo level and not at group level. However, we also noted that both solo and group reporting of SR.25.03 uses the same template, being SR.25.03.01. We noted that in relation to the new fields, the validation file for the 2.4.0 Hot Fix includes validations which operate at the .04 group entry point. This strongly implies that the new tables are expected to be populated at group level in relation to SR.25.03 but this runs counter to EIOPA's response to Insurance Europe's question documented in 'EIOPA-BoS-19-362_Annex_Agregate comments ITS amendments_public.docx' which states that, in relation to S.25.xx.01/SR.25.XX.01, 'EIOPA confirms this approach. It is only applicable at solo level'. Can EIOPA please address the ambiguity in the reporting requirements.
EIOPA answer
Your interpretation is correct. The new tables with tax data in S.25.XX are only to be filled in at individual level.