Regards the changes to S.19 guidance for 2.8 and the associated LOG guidance (in the draft business package supporting SII taxonomy 2.8.0).

We have a slight confusion regards General comments points i. and iii.:

- para i. has a new part to this rule that states that only 90% coverage must be met, with LoB selected on descending TP basis. This indicates that potentially some LoB can be excluded completely from S.19.

- however, para iii. states that if a LoB is less than 10% it must be reported at total LoB level; so this indicates that every LoB must be reported (At least at the total LoB level)

As such the way it's drafted it seems point iv can nullify the benefit of the new 90% materiality threshold added to in point i for 2.8 taxonomy.

For example if an insurer has one dominant LoB making 99% of TP and then several immaterial others, can EIOPA confirm that point iii applies and those immaterial LoB still need to be reported?

Further, we'd note that the new 90% threshold in point i is given in terms of Technical Provisions, not gross BE Claims provision as it is in the other thresholds. Is that intentional? We can perhaps understand this was done for consistency with other related templates (S.20, S.21 etc.) but if in S.19 this 90% rule only comes into effect at the currency level (ie this rule is there to ensure where multiple currencies are relevant that reporting coverage does not fall below some level) then the benefits of consistency are lost as all those other templates are total LoB level anyway.