With regard to the draft of ITS published on 31 March 2022 (https://www.eiopa.europa.eu/document-library/technical-standard/draft-a…) and Q&A 1853 please find below our doubts regarding S.02.01 – when the item should be presented in reinsurance recoverables and when in reinsurance receivables / payables? In the definition of Reinsurance recoverables there is a reference to gross technical provisions (“It corresponds to the amount of reinsurer share of technical provisions”), but the presentation of the item depends on the gross payment between undertaking and policyholders (or vice versa). Please see the simplified example – the policyholder did not pay the premium -> the undertaking has receivables from the policyholder, but according to the literal interpretation of new definition, premium on reinsurers’s share should be presented in the reinsurance recoverables - this definition seems to create a situation when the presentation depends on the payment between policyholder and the undertaking, not on the insurance risk / uncertainty of the amount. Moreover the practice of reinsurance agreements and settlements does not fully correspond to this definition. Namely, in case of reinsurer's share in premium, in many types of reinsurance contracts, it is defined in terms of the portfolio, and not tied to specific insurance contracts. Premium payment to the reinsurer may also occur at different moments (e.g. payment in advance, payment with settlement after the contract, renewal payments during the contract). Moreover, in many cases payments to the reinsurer do not depend on gross premium payment. As a result, it cannot be established, if in the case of particular unpaid premium by policyholder there was settlement with the reinsurer. As a result, an attempt to determine whether, and to what extent, liabilities to the reinsurer are related to paid or unpaid gross premiums, would be a purely theoretical model generating significant labor-intensity. In Q&A 1853 EIOPA determined the difference between reinsurance recoverable and receivable taking into consideration risk’s character (“(…)in the item 'recoverable', there is an uncertainty on as to the amount that is to be expected from the reinsurer. In other words, it reflects an insurance risk. The balance sheet item 'receivable' is not subject to such uncertainty because it refers to an amount that has been agreed between cedent and reinsurer, only the amount has not been paid yet. Taking the above into consideration, everything related to the 'best estimate' of the technical provisions should be represented in 'reinsurance recoverables'”). Our understanding of that Q&A is as follows: 1) reinsurance receivables/payables occur when the amount is agreed between cedent and reinsurer, but there is a risk that the amount will not be paid by the counterpart (i.e. credit risk), 2) reinsurance recoverables occur when the amount is an estimate of a random variable and may ultimately have a different valuation (of course, there is additionally a risk of whether it will be paid), 3) amounts included in /related to the 'best estimate' of the technical provisions should be represented in 'reinsurance recoverables', while insurance receivables / payables should be represented in the reinsurance receivables / payables (not in reinsurance recoverables as could be interpreted literally on the basis of new definitions included in the draft of ITS). We ask for the confirmation of our viewpoint that when the policyholder does not pay the premium -> the undertaking has receivables from the policyholder and the reinsurer’s share should be included in the reinsurance payables (which would be in accordance with Q&A 1853) as oppose to the literal interpretation of new definitions in the draft of ITS, according to which premium on reinsurers’ share would be presented in the reinsurance recoverables.