Skip to main content
European Insurance and Occupational Pensions Authority

2465

Q&A

Question ID: 2465

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

Topic: Reporting Templates

Article: Annex II and III

Template: S.05.01

Status: Final

Date of submission: 22 Jul 2022

Question

Insurance and reinsurance undertakings in Bulgaria apply International Financial Reporting Standards (IFRS). The new IFRS 17 Insurance contracts will be applied as from January 1st, 2023. Given that the application date of the amended Solvency II Technical Standards on Reporting and Disclosure is expected to be December 31st, 2023, we would like to ask for EIOPA written guidance on the following question: Several items in the QRTs shall be reported from an accounting perspective, i.e. in our case IFRS as Directive 91/674/EEC will not be applicable. In this regard, we would like to know how undertakings should report in QRTs during the 1st one-year period (as from the application date of IFRS 17 (01.01.2023) until the application date of the reporting technical standards (31.12.2023)) the items such as “premiums written” and “premiums earned” taking into consideration that IFRS 17 does not define these terms and Directive 91/674/EEC will not be applicable. The question is of EU-wide importance as not only Bulgarian insurance and reinsurance undertakings apply IFRS. Without uniform and substantiated interpretation it is possible different NSAs to come to different conclusions with regard to application of QRT S.05.01 in the interim period. Therefore we seek EIOPA’s guidance on the uniform reporting in EC on “premiums written” and “premiums earned” before the amendments of ITS on reporting apply.

EIOPA answer

Article 1(11) and (12) of Delegated Regulation (EU) 2015/35 defines written/earned premiums in alignment with the definition used in the Directive 91/674/EEC. While the current Implementing Regulation (EU) 2015/2450 (ITS on Reporting) refers to the Directive 91/674/EEC in its draft amendments this reference is deleted and a reference to Article 1(11) and (12) of Delegated Regulation (EU) 2015/35 is included.

Acknowledging, that the application date of IFRS 17 (January 2023) precedes the implementation date of the ITS amendments on reporting for the first 3 quarters in 2023 the insurance and reinsurance undertakings shall report written/earned premiums as defined in Article 1(11) and (12) of Delegated Regulation (EU) 2015/35 regardless whether they use IFRS 17 or local GAAP. The requirement is in line with the current ITS and with its amendments.