Question ID: 2599
Regulation Reference: (EU) No 2015/2452 - procedures, formats and templates of the solvency and financial condition report
Topic: Disclosure Templates
Article: Template S.04.05
Status: Final
Date of submission: 14 Mar 2023
Question
Regards new for 2023 reporting public disclosure template S.04.05.21 and associated LOG guidance; can EIOPA please provide guidance on the following scenario. We think we have noticed a slight gap in the information available from the private (2015/2450) version of this template; S.04.05.01, due to the 95% materiality limit on reporting information by country in S.04.05.01. If it is the case that the information by country in S.04.05.21 (for the countries disclosed there) must represent 100% of each countries' amounts then this partially "undermines" the 95% materiality threshold in S.04.05.01 - because in fact for some countries for the purposes of completing S.04.05.21 we actually need 100% by-country information. And then it would mean S.04.05.21 cannot necessarily (when "other countries" amounts are included in S.04.05.01) be populated directly from S.04.05.01, but will need to be supplemented with additional information (i.e. breaking down the "Other countries" amounts from S.04.05.01 into the specific countries so as to assign those to the countries disclosed in S.04.05.21). Can EIOPA please advise if it is acceptable for S.04.05.21 to be completed based only on the specific country information available in S.04.05.01 i.e. "other countries" amounts in S.04.05.01 do not need to be broken down and additionally included in S.04.05.21?
EIOPA answer
The 95% threshold for “other countries" in S.04.05.01 means that for at least 95% of the gross written premium the reporting will be on country by country basis. As an example if a reporter shows 95% of their business split across countries A, B & C and 5% in “other countries", the correct interpretation is that the 5% is not in country A, B or C.
Template S.04.05.21 requires disclosure of information reported for the home country and for the top five non-home countries (by amount of gross written premium), or for sufficient countries (if fewer) to represent 90% or more of total gross written premium. This will mean that the 95% threshold in S.04.05.01 will give enough information for the submission of 90% of information in S.04.05.21.