Question ID: 2413
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: Article 35 of SII Directive
Template: S.21.02
Status: Final
Date of submission: 01 Apr 2022
Question
In S21.02, C0090 (Sum insured) is defined as "The highest amount that the insurer can be obliged to pay out under the policy", which suggests it might be reported net of deductible. C0100 (Original deductible policyholder) is defined as "Part of the sum insured which is retained by the policyholder" which suggests Sum insured might be reported gross of deductible. Similarly, C0150 (Net retention of the insurer) is defined as "The net amount for which the insurer acts as risk carrier, i.e.: part of the sum insured that exceeds the original deductible of the policyholder and is not reinsured" which also suggests C0090 may be gross of deductible. Could you please advise whether the amount included in C0090 should be reported net of the policy deductible or gross of deductible?
EIOPA answer
The sum insured, C0090 in S.21.01, is gross from deductibles reported in C0100, so the sum insured reported in C0090 may actually be higher than the highest amount the undertaking can be obliged to pay out under the policy. The LOG file will be revised accordingly in the next ITS amendments.