Question ID: 2689
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: 35 of SII Directive
Template: S.04.03, S.04.04
Status: Final
Date of submission: 12 Jun 2023
Question
We have a question regards the new S.04.03 and S.04.04 QRTs added to the 2.8 taxonomy and associated LOG guidance (as set out in the DRAFT business package supporting 2.8.0 taxonomy). Would EIOPA expect the following to hold (e.g. in NCA Plausibility checks): if S.04.03 C0030 = ""2 – Non-EEA branch"" then S.04.04.01.01 C0020 = 0 all rows R0020-R0050 in S.04.04.01.01, joining the S.04.03 and S.04.04 tables based on the ""Underwriting entity code"". Our basis for this is that if the entity is a non-EEA Branch then it cannot write any business via FPS and hence S.04.04.01.01 C0020 (which represents the total of FPS business) must be 0/empty in all rows.
EIOPA answer
EIOPA confirms that if the entity is a non-EEA Branch it cannot write any business via FPS. This is also reflected in the modelling for column C0020 Location of activity defined as EEA countries [other than home country] and Not local [EEA] (thus non-EEA should not report this column).
We would like to clarify that in general, “non-applicable facts for a report MUST not be reported rather than reported as „0" or as empty string" (EIOPA XBRL filling rules rule S.21 – Treatment of unreported facts).