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