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European Insurance and Occupational Pensions Authority

2594

Q&A

Question ID: 2594

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

Topic: Validations

Article: 35 of SII Directive

Status: Final

Date of submission: 08 Mar 2023

Question

We would like a clarification about some discrepancies we noticed in the Solvency II list of validations published in the PWD3 of the Taxonomy 2.8.0.

#1: The following Business Validation rules show an incoherence between the columns "Where" and "Label". BV1218-3, BV1219-3, BV1686, BV1688, BV1692, BV1693, BV1697, BV1698, BV1702, BV1703, BV1716, BV1718, BV1727, BV1732 In fact, the "Where" column includes the assets with CIC like ##09 in the not(matches()) statement, while the "Label" column does not. Could you please indicate which column we should take into consideration?

#2: Some rules, such as BV1703 and BV985-4, concern the same annotated template and fiels, but have different "Where" conditions. Could you please clarify the meaning of these rules? Why has BV1703 been added and not BV985-4 modified? In this particular case, if BV1703 validation is met, the same happens for BV985-4. We would like more insight into this decision.

#3: Some rules, such as BV1727 and BV954-3, are identical but with different Severity. We would like to know the reasons behind the decision to put two rules that only differ in severity.

#4: The last part of the "Where" condition in rules BV1716 and BV1718 is unclear --> "^..((71)|(75)|(8.)|(9.)|(.9))$")) Does it refer to all CIC codes like ###9 or is it a typo and it refers to CIC codes ##09? This ambiguity arises from the fact that rule BV1216-3 (which also refers to the Custodian) has this "Where" condition --> "^..((71)|(75)|(8.)|(9.)|(09))$")), therefore we think they should be consistend with each other. Thank you.

EIOPA answer

  1. This difference is intentional. As the filter for those validations uses ‘Not’ operator, the requirements should be understood as ‘other than’ specified CIC codes. It is important to note that it is not equivalent to conclude that opposite statement is true for those CIC codes. For example, the BV1218-3 will not be checked for CIC 71, 75, 87, 88, any CIC in category 9 and 09. In case of the CIC ‘##09’ as it covers other investments not classified elsewhere, it is impossible to ensure that the validation will hold for every possible type of “other investments”. Therefore, in some cases CIC ‘##09’ are excluded from the scope of the validation.
  2. We are happy to inform that this pair of validation have been analysed already and as a result BV1703 was removed as duplicate of BV985-4
  3. Thank you for providing the list. Similarly, to the point second, we plan to analyse these validations and remove potential duplicates
  1. On the last point, we can confirm it is a typo which has been already internally addressed. Therefore, we are happy to inform that these CIC codes will be corrected for the final release.