Question ID: 2655
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: N/A
Template: S.06.02
Status: Final
Date of submission: 26 May 2023
Question
Regards the updates within 2.8 taxonomy and the associated LOG guidance (in the draft business package supporting SII taxonomy 2.8.0) for the new data points C0296 and C0297. Can EIOPA confirm that: a) Where CIC is not 9 or is 95 (95 not being mentioned in the current LOG guidance but we expect this exception to be confirmed shortly in a separate Q&A) then C0296 and C0297 should always be left blank (or option “9 - Not applicable”, but in xbrl terms this is the same thing, given this is represented by the default member of the MC domain) b) Where CIC is 9 but not 95 then C0296 and C0297 should never be left blank (or are there cases where it would be allowed e.g. for immaterial exposures?) Note we asked part of this question in the consultation phase and received the below answer: Q: C0296 guidance, why have option 9 if the field is only applicable for CIC 9 anyway? If its purpopse is to report ""unknown/immaterial"" perhaps its description could reflect that? A: The objective of having option 9 is to avoid having this item empty for CIC categories different from 9. However, in the taxonomy option 9 in the related hierarchies is assigned to the default value and hence will in effect be empty in the xbrl submission, so we raise this question again.
EIOPA answer
From the XBRL perspective, providing 9 - Non applicable option (expressed as <s2md:ei2723 (…)>s2c_MC:x0</s2md:ei2723>) for metric column is not equal to leaving it empty. Not reporting default member would be true for the keys and semi open axes.
EIOPA confirms that there shall be always a value reported in C0296 and C0297 and more specifically:
1. For CIC categories other than 9 and CIC 95 it is expected to be reported 9 – Not applicable option to be reported.
2. For CIC category 9 (other than 95) columns C0296 and C0297 should always be reported.