Skip to main content
European Insurance and Occupational Pensions Authority



Question ID: 2299

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Topic: Reporting Templates

Article: N/A

Status: Final

Date of submission: 27 May 2021


I am reaching out to get clarity on how to accurately assign 3rd and 4th position CIC values for ETC (Exchange Traded Commodity) instruments.

The definition of an ETC is: 'An Exchange Traded Commodity that tracks the price of a physical or future underlying commodity, basket of commodities or a commodity index. An ETC is listed and traded on an exchange in a manner similar to common stock.'

They do not seem to fit neatly in the CIC matrix found on page 199 in the following link:

Wondered if it may be possible to get some official guidance and agreement on what the correct classification should be for such instruments please?

EIOPA answer

It is expected that ETCs need to be reported with CIC Category 5 "Structured notes" and the sub-category that fits the risk exposure (like "commodity risk - 56") or "other"."

​Only in case the ETC can be categorised as an AIF (to be decided on a case-by-case analysis taking into account the specificities of the relevant instrument), the ETC needs to be classified with CIC category 4, CIU. If no other sub-category fits, the asset needs to be reported with the sub-category "Other" - 49.​