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European Insurance and Occupational Pensions Authority

2490

Q&A

Question ID: 2490

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.12.01

Status: Final

Date of submission: 20 Sep 2022

Question

The way the LOG file (in the draft business package supporting SII taxonomy 2.8.0) describes the exemption from reporting this QRT for the case of simplifications could be open to interpretation: ""In case the undertaking uses simplifications for the calculation of technical provisions, for which an estimate of the expected future cash–flows arising from the contracts are not calculated, the information shall not be reported."" We don't believe the intention is that if an insurer uses simplfications for TPs at all (e.g. for an immaterial LoB that represents 1% of the BE) then S.18.01 would not be required; instead in such cases S.18.01 should exclude amounts that relate to that part of the BE but S.18.01 should still be reported. Is that correct? And if so is there a materiality threshold e.g. if greater than X% of the Best Estimate is calculated without simplifications then S.18.01 should be reported. There is a synonymous case for S.13.01 so it would be appreciated if the answer could address S.13.01 as well. Further, can EIOPA please confirm that the S.18.01 90% LoB materiality coverage calculation should use as the denominator: all non-life technical provisions (or just the amount of non-life technical provisions for which a simplification is not used)? Also, a related question occurs for the cash flows datapoints in S.17.01 rows R0370 through R0440 (which are, more or less, just an aggregation of S.18.01 - ignoring materiality coverage - with discounting applied). Should those rows always be completed, for 100% of the Best Estimate amount and for 100% of business (ie all Lines of business)? Because one could possibly think there would be some exemptions to these rows as well if exemptions are being made to S.18.01, for example: - if S.18.01 is not required as per the instructions to the S.18.01 template (i.e. the use of simplifications) then these S.17.01 rows could be left completely empty as well? - Or (depending on the answer to my questions above), if S.18.01 should be completed if some BE is calculated using simplifications but not all; should these S.17.01 rows be completed to ""match"" ie excluding amounts relating to BE calculated using simplification for which cash-flows smounts are not estimated - And/or in terms of the 90% materiality coverage, should the S.17.01 rows R0370 through R0440 represent 100% of business or only the material lines of business (as indicated in S.18.01 C0100 R0100) Again, to the extent there is parallel exemptions from reporting S.13.01 due to use of simplifications it would be appreciated if you could confirm the treatment for S.12.01 (regards the cash-flow rows R0230 through R0280).

EIOPA answer

The assumption is correct: in case the undertaking is using a simplification that does not require to project cash flows to part of its business, S.13.01 and S.18.01 should be reported for the remaining part of the business, i.e. where such simplification is not applied.

The denominator for the threshold in S.18.01 should include all non-life technical provisions, regardless of the use of any simplification.

​There are no exceptions for S.17.01 R0370 – R0440 nor for S.12.01 R0230 – R0280 based on the use of such simplifications as for S.18.01 and S.13.01. As these templates do not require annual breakdown, the amounts can be reported on best effort basis in case such simplification is used.