We have a questions following the introduction of the materiality threshold(s) to the non-life business QRTs (as set out in the DRAFT business package supporting 2.8.0 taxonomy). We seek clarification on the materiality threshold for QRTs S.20.01, S.21.01 and S.21.03. In each of these template’s general comments section there is similarly worded guidance on the threshold, which for S.20.01 is: “This template shall be reported for each material non-life line of Business for direct business, as defined in Annex I to Delegated Regulation (EU) 2015/35, representing a coverage of 90% of the non-life technical provisions”. S.20.01, S.21.01 and S.21.03 should only include business written on a direct basis. Our interpretation of the threshold is that only direct business should be considered for the denominator in this calculation i.e. the sentence above would more specifically state: “This template shall be reported for each material non-life line of Business for direct business, as defined in Annex I to Delegated Regulation (EU) 2015/35, representing a coverage of 90% of the non-life technical provisions FOR DIRECT BUSINESS”. Otherwise meeting this threshold becomes confusing. For example if an insurer writes direct and accepted reinsurance for fire and property only (no other lines of business), and for direct fire TP is 5k EUR and for accepted proportional reinsurance for fire TP is 495k EUR. In that case direct is only 1% of total TPs and so clearly immaterial, but if we do or do not report LoB fire in S.20.01 then we aren’t meeting the 90% threshold either (basically we cannot meet the threshold given that 99% of the business cannot actually be reported in S.20.01) - so becomes unclear if it the direct part should be reported at all. In anticipation of your response, if only direct business is to be used as the denominator for S.20.01, S.21.01 and S.21.03 then please confirm that this would mean an insurer (that has both direct and accepted reinsurance) must calculate separately the material LoBs for direct only business (for S.20, S.21.01 and S.21.03 purposes) and for all (regardless of whether direct or accepted reinsurance) business (for S.18 and S.19 purposes).