Question ID: 2552
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: Template S.04.04
Status: Final
Date of submission: 06 Jan 2023
Question
Regards the new S.04.04 QRT for 2.8 and the associated LOG guidance (in the draft business package supporting SII taxonomy 2.8.0).
We have a slight doubt particularly in relation to what is in scope for C0020 and C0030 how they overlap.
One would think that FPS by definition means business written in a "country different from the country of establishment" (the labelling within C0020) and hence (given that S.04.04 is written on the basis of the underwriting entity) C0020 is just the sum of C0030 (which provides the breakdown of the FPS business by the undertaking/branch).
And this would assume all business done by the undertaking and the branches not done via FPS (ie "typical undertaking/branch activity") is only reported in C0010. Is that the case?
It's quite a tricky scenario to cover with an example but if you are able to follow and comment on our case below (or present, e.g. like done in Q&A #1977 for S.04.01, your own summary of the different scenarios) we feel that would be beneficial to clarify the requirements.
Scenario:
- Undertaking X has home country A and the undertaking has FPS in country B
- Undertaking X also has a branch Y in country B and the branch has FPS in country C and D and it also writes business itself in country B and non-EEA business from country E
Is the below correct:
for Z0020 = undertaking X
C0010 is all business done by the undertaking (including non-EEA business)
C0020 is the business in country B by the undertaking FPS with country B by undertaking X (i.e. not the business done by branch Y)
C0030 (for which R0010 = country B) will have same amount as in C0020
for Z0020 = branch Y
C0010 is the total of the business the branch writes itself in country B and the non-EEA business from country E
C0020 is the business in country C and D totalled
C0030 (for which there will be two copies, one with R0010 = country C and one with country D) will have breakdown of C0020 into these 2 countries respective amounts
EIOPA answer
C0020 includes all the business underwritten through FPS in country different from the country of establishment while C0030 includes information by underwriting entity and by EEA country and includes business underwritten in the considered country through FPS. Please note that non-EEA business is not to be reported in this template. In your example it would mean that the following will be filled in the:
for Z0020 = undertaking X
C0010 = all business underwritten by the undertaking in country A, including non-EEA business which is underwritten in country A
C0020 = all business in country B by undertaking X via FPS (i.e. not the business done by branch Y)
C0030 – if it is for undertaking X and country B = will have same amount as in C0020
for Z0020 = branch Y
C0010 is the total of the business the branch Y writes itself in country B
C0020 is the business of Y in country C and D totalled
C0030 (for which there will be two copies, one with R0010 = country C and one with country D) will have breakdown of C0020 into these 2 countries respective amounts.