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European Insurance and Occupational Pensions Authority

2531

Q&A

Question ID: 2531

Regulation Reference: (EU) 2023/895 - ITS for the disclosure of solvency and financial condition report

Topic: Disclosure Templates

Article: N/A

Template: S.04.05

Status: Final

Date of submission: 21 Nov 2022

Question

Following up on our question regards the reporting thresholds for S.04.05 (where EIOPA confirmed that this template should always be reported i.e. there is no threshold, contrary to what is implied by the S.01.01 R0106 options), can we ask for some further clarification on this and related templates S.04.03 and S.04.04. 1. Please, to be clear, is S.04.05 required even if the home country represents 100% of "activity" 2. Assuming S.04.05 is always required, does that mean S.04.03 is always required as well? Because S.04.03 is the "base" table for S.04.04 and S.04.05 - although technically in xbrl S.04.03 doesn't need to be reported for S.04.05 to be reported - it would seem strange that S.04.05 was reported but S.04.03 was not, given the business relationship between the two. We note that in S.01.01 for R0104 there is the option "2 - Not reported as no activity outside the home country" which would imply S.04.03 is NOT always required but that may just be an inconsistency. 3. Can EIOPA confirm the case for S.04.04. From S.01.01 R0105 (for which there is the option "2 - Not reported as no activity outside the home country") it would appear that S.04.04 is not required when no activity outside home country. Is that the case?

EIOPA answer

In case of no activity outside the home country S.04.05 is not to be reported. In this case S.04.03 and S.04.04 are not to be reported either. This is reflected also in the individual instructions (Annex II) of the templates as rows R0100 (S.04.02), R0105 (S.04.04) and R0106 (S.04.05) include “Not reported as no activity outside the home country" option.