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European Insurance and Occupational Pensions Authority



Question ID: 2571

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

Topic: Reporting Templates

Article: Article 35 of SII Directive

Status: Final

Date of submission: 06 Feb 2023


About the new "Currency" field introduced by taxonomy 2.8.0:

1) The rule states that “the breakdown by currency is only be required to cover 90% of reinsurance recoverables. For the remaining 10% it is possible to group it under "other currencies".” Is the 90%/10% threshold to be calculated just on the overall total or it is to be applied for the recoverables towards each reinsurers (e.g. line by line)?

2) In applying the 90%/10% rule the amount of recoverable to be used should include the adjustment for counterparty default?

3) How should we represent the case when recoverable towards a single reinsurer are in several currencies? By splitting the overall amount (in the balance sheet currency) into several rows? 

Below is provided an example, please confirm which interpretation is correct:
Two reinsurers, X and Y. EUR 90m ceded reserves to X, original amounts in EUR. For Y, EUR 10m recoverables, of which 70% in EUR, 20% USD, 10% GBP.


X EUR 90m
Y EUR 10m


a)    90% of total recoverables are in EUR so no need for further details:
Y EUR 10m other currencies

b)    90% of total recoverables are in EUR but also individual exposure towards Y must be detailed (up to 90%):

Y EUR 7m   EUR
Y EUR 2m   USD
Y EUR 1m   GBP/other currencies

c)    Exposure in other currencies towards Y should be split from that in EUR but there is no need to provide currency details since below 10% of overall total:

 X EUR 90m EUR
 Y EUR 7m   EUR
 Y EUR 3m   other currencies

EIOPA answer

1. The threshold should apply to the overall total. This means that for some reinsurers 100% of the recoverables may be broken down by currency, while for other the percentage may be lower than 90%. However, the approach should be consistent for all reinsurers, this means that the currencies reported individually (i.e., not grouped within “other currencies") should be the same for all reinsurers. For example, if USD is reported individually for reinsurer A, it cannot be grouped within “other currencies" for reinsurer B.

2. Yes, the amount of recoverables to be used for the threshold should include the counterparty default adjustment.

3. Yes, reporting by currency may require splitting the overall amount in different rows for the same reinsurer (one per currency plus an additional one for “other currencies" if applicable).

​​Regarding the example, interpretation c) is correct, as identifying EUR individually is enough to cover the 90% threshold, but EUR should be identified individually for all reinsurers. This means in the example (at least) three rows would be needed:

Reinsurer X, EUR (90M)
Reinsurer Y, EUR (7M)
Reinsurer Y, other currencies (3M).