We are preparing our system to accommodate the expected S.06.04 QRT (and the revised scope of S.06.03) and we have several questions that we request EIOPA's view on. We hope that despite the guidance not yet being finalised some feedback will be possible, even if not definitive, to allow us to progress preparing our system, and also our clients, for the new requirements. 1. If an insurer performs full-through on a subset of the fund's underlying investments (and a data grouping approach to the remainder for example); should the fully-looked through part of the fund be included in S.06.04 and the data groupings part in S.06.03 2. Where full look-through is not performed but the data groupings approach is taken, are there any scenarios where those data groups could or should be reported across multiple rows in S.06.03 if the assigned underlying categories are applicable, or in all cases where full look-through is not performed then this (part of the fund as applicable depending on the answer to question 1 above) should they be reported simply as one row with 4, AA, 3 respectively for C0030, C0040 and C0050 3. S0604 table 1, CIC column log file instructions refer to the standard CIC table, the one that is to be used also in S0602 for example also. However, our understanding is that the scope of S0604 is total fund value and it is possible that the fund contains assets that do not fall within any cic category e.g. receivables. How should these be reported? CIC 09? We would also (assuming S.06.04 is to include assets that do not fall within S.06.02, like receivables, intangibles etc.) request the S.06.04 guidance offers further references to such assets e.g. is currency exempted on same basis that it is exempted for loans that do not need to be individualised 4. In general, for S.06.04, can EIOPA advise how fields should be completed for the 10% of the value of the fund for which look-through is not required to be reported. For descriptive fields such as item title and item name should some standard text be entered? And for closed lists like issuer sector, currency and country, where the reference NACE or ISO lists do not include (so far as we can tell) an appropriate option will the taxonomy include additional options e.g. like AA option available in S.06.03 in addition to the ISO country list and XA and EU options. It would be helpful if the LOG guidance could be more explicit on the available options (like in S.06.03 C0040 and C0050 specifically reference the "non-look through" options AA and 3 respectively) 5. We are assuming the following case would it be permitted but request EIOPA confirmation: if the same asset is underlying in two different funds, the allocation of that underlying asset to "non-look through" allocation in S.06.04 is independently assessed? eg if two different funds (both held by the undertaking) contain (exact same class etc. therein) shares of the same company but in one of the funds the exposure is less than 10% but in the other not. It would be permitted to report these shares for the fund where these are not material not looked-through 6. For updated (and existing in fact) S.06.03 C0050 - does the guidance applicable to S.06.04 C0150 (Currency) also apply e.g. Where the underlying asset relates to CIC 8 (non-individualised), 75  or 95 should currency in S.06.03 be left empty?

EIOPA answer

Please note that EIOPA is currently working on the ITS amendments. As the work is on-going and not finalised for publication, EIOPA can't provide more detailed information at this time.

The ITS amendments on reporting and disclosure 2022 are planned to be applicable in 2024 with first reporting to financial year 2023 and Q42023. The ITS amendments will be included in the Taxonomy 2.8.0. For the timeline including the foreseen publication date, please consult Supervisory reporting - DPM and XBRL | Eiopa (europa.eu)