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European Insurance and Occupational Pensions Authority

2533

Q&A

Question ID: 2533

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

Topic: Reporting Templates

Article: N/A

Status: Rejected

Date of submission: 24 Nov 2022

Question

We would like to point out an issue with removing the breakdown of the "Amount of transitional on Technical Provisions" rows from quarterly S.12.01 and S.17.01. While on the face of it these appear to reduce the reporting burden; in reality it's negligible (or in some cases none at all) benefit because: a) the amount of transitional at the line of business level still needs to be reported in S.12.01 and S.17.01 because the total Technical Provisions with and without the transitional must be reported b) the reduction of reporting the breakdown of the transitional on TPs (between TPCAW, BE and RM) at line of business level is undone (to greater or lesser extent) because in S(E).02.01 the TP figures must be split out by TPCAW, BE and RM taking into account transitional on TPs So in reality some insurers (depending on the lines of business they write) would in fact have no reduction in reporting the breakdown in transitional on TPs and the cost is breaking some key validation checks between S(E).02.01 and S.12.01 and S.17.01 and complicating this area of reporting. We would suggest it would be better on balance to restore the rows relating to breakdown in the transitional on TPS in quarterly S.12.01 and S.17.01.

EIOPA answer

Thank you for your question. Please note that at this stage of the process changes in the instructions and templates are not possible. EIOPA will analyse your proposals in the future ITS amendments.