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European Insurance and Occupational Pensions Authority



Question ID: 2526

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

Topic: Reporting Templates

Article: FSR templates S.14.04 and S.14.05

Status: Final

Date of submission: 16 Nov 2022


Our question regards new FSR templates S.14.04 and S.14.05 (in the draft business package supporting SII taxonomy 2.8.0).

We appreciate there is a comment in release notes regards S.14.04 and C0240 being used in table 1 and 2 but that comment relates to the re-use of the C0240 column name (for different things) and our concern is not necessarily on this point. We also note Q&A #2476 but still have some residual doubts.

Neither C0240 (both table 1 and 2) or C0245 are included in the LOG guidance, which usually is ok for line identifiers in the taxonomy - in practice an incrementing integer and have no business value.

However, C0245 in table 2 does have ""value""; it is a key to table and it is not simply an incrementing integer (within table 2) and not having this relationship explained in the LOGS seems to us unsatisfactory.

Further regards C0240 in table 1; there is a break in the EIOPA convention for naming line identification columns in this case: normally whenever a line identifier column is included in a table it is simply named ""line identification"" but in this case it is name ""Line identification (internal protfolio ID)"". Is this meaningful? Do EIOPA actually want a code (that is consistent across future submissions) in this field?
If (even partially) so we think it would be better to have a new column in the table to capture this (probably still retaining a - standard - line identifiication column, for technical reasons) perhaps named "Portolfio ID" and include this in LOGS with an explanation of what it represents (and have an equivalent column in table 2, also explained in LOGS and the relationship with table 1).

We have similar concerns regards S.14.05 and would similarly suggest a new Portfolio ID column added to the templates in xbrl (and LOGS), again explaining what this represents in table 1 and the relationship in table 2

EIOPA answer

We would like to inform that the draft ITSs has been submitted to European Commission in March reflecting EIOPA's final outcome and considering all comments received by then. As such, changes in the instructions at this stage of the process are not possible.

Template S.14.04.11 reuses column code C0240 for two different key columns, which may be confusing for some filers. Therefore, EIOPA considers potential column code amendment in the future.

For the S. template, information should be provided on portfolio level with the internal portfolio ID to be reported in c0240 column. Furthermore, the relation between .01 and .02 tables can be described as one-to-many, therefore it is expected that C0240 from the (first) Portfolio table will be aligned with C0240 values reported in (second) Portfolio detail table. Therefore, EIOPA expects actual code to be reported.

Finally, regarding the suggestion for the new columns, we would like to inform that currently no such changes are planned. However, depending on the overall feedback we may consider introducing some clarification in the release package and modelling amendment for the future taxonomy release.​