Question ID: 2503
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Group Own funds
Article: 222
Template: S.23.01
Status: Final
Date of submission: 27 Sep 2022
Question
On group template S.23.01, most basic own funds items are subdivised into two parts: a main part and the non-available part at group level. For instance minority interests (R0200) and non-available minority interests at group level (R0210). For each of theses cases, should the non-available part be included in the main item on the row above?
Background of the question
We are asking for clarification purposes, as template instructions do not specify if the non-available at group level part for relevant items should be included in the main part, but guidelines set in article 222 of directive 2009/138 consider these part of the related undertaking's SCR, and they should not appear in the group SCR. Following this approach, this means that R0020, R0060, R0080, R0100, R0120, R0150, R0170, R0190 and R0210 should not be included in their respective above items. However since they are included in deductions (as the total of non-available own fund items in R0270), by doing so they would actually be deducted twice: the total basic own funds after deductions on R0290 would not include them in the first place (because the according sums are not reported on R0010, R0050, R0070, R0090, R0110, R0140, R0160, R0180 and R0200), then substract them as deductions from R0280.
EIOPA answer
This understanding is correct, the non-available part should be included in the main item (reflecting available and non-available) and the non-available part is specified in the row “non-available …". R0020, R0060, R0080, R0100, R0120, R0150, R0170, R0190 and R0210 in S.23.01 is summed into R0270.