Question ID: 2469
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates, Validations
Article: 35 of SII Directive
Template: S.06.02
Status: Final
Date of submission: 29 Jul 2022
Question
Due to the validation rules BV783 and BV784, we still have a problem with our Asset QRTs and the prices that we have to send in the columns Unit SII price (pct).
Prices have to be unique for an Asset ID Code. However the prices we are using are not totally unique, as we have the same investment held in different currencies, countries and time zones, and therefore we take an average price in order to deliver only one price per Asset ID Code. The current tolerance level provided with validation rules BV783 and BV784 does not allow us to satisfy the tolerance in ABACUS as it is far too low. To solve this issue we propose that either unit SII price (pct) should be a position field that doesn’t have to be unique per Asset ID Code or that a different approach tolerance level is adopted – we have tested various levels and our findings show that a tolerance level of 1% of the total SII amount would solve this issue. Please can either of these two solutions be implemented?
EIOPA answer
In the EIOPA filing rules (https://dev.eiopa.europa.eu/Taxonomy/Full/2.8.0/Common/EIOPA_XBRL_Filing_Rules_2.8.0.pdf#page=22) there is a clear description for asset quoted in multiple currencies. In such case it is possible to provide multiple rows for both S.06.02.nn.01 and S.06.02.nn.02 table for a single Asset ID Code.
Moreover, at present, the relationships described in the validations are defined with the assumption of exact equality, or an approximation defined by interval arithmetic. EIOPA implementation of this mechanism is described in more detail in XBRL Taxonomy Documentation – section VII.3.6.6 Evaluation of validation rules and interval arithmetic (https://dev.eiopa.europa.eu/Taxonomy/Full/2.7.0/Common/EIOPA_XBRL_Taxonomy_Documentation_2.7.0.pdf).