Question ID: 2528
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: 35 of SII Directive(New Cross Border QRTs S.04)
Status: Final
Date of submission: 17 Nov 2022
Question
We have a question regarding new S.04 QRTs: How do the regulators expect the XBRL data to be reported to them? Reading this part of EIOPA Log below, it seems that S.04.04 and S.04.05 must be reported for each legal entity and each branch, so it seems to be not the same way we are used to: "Z0020 / Underwriting entity code / The identification code of each individual underwriting entity as reported in template S.04.03" Or is it meant that the data is still reported only on legal entity basis, so no XBRL file for each branch needed? This is a bit confusing.
Background of the question
Currently our entities report on legal entity basis, so for example XXX SE sums up the data of its branches in Japan, Australia, Germany etc. within the QRTs (e.g. old S.04.01 or S.05.02).
EIOPA answer
EIOPA confirms that S.04.03, S.04.04 and S.04.05 must be reported for each legal entity and each branch. The reporting instructions of each of these templates should be read in conjunction with the reporting instructions for the other 2 templates. Across these three templates, entities shall report all business from two distinct perspectives: location of underwriting and location of risk.