Question ID: 2690
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.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 C0020 = “Head office” then S.04.04.01.02 EEA country <> S.01.02 R0050, joining the S.04.03 and S.04.04 tables based on the "Underwriting entity code". if s.04.03 C0030 = “EEA Branch” then S.04.04.01.02 EEA country <> S.04.03 C0040, joining the S.04.03 and S.04.04 tables based on the "Underwriting entity code". Our basis for this is that by definition FPS cannot take place in the country of establishment and hence there should not be any entries in S.04.04.01.02 with country equal to the home country of the reporting entity (for cases where S.04.04 related to the "Head Office" entity) or with country equal to the branch country of establishment (for cases where S.04.04 relates to an "EEA Branch" entity)
EIOPA answer
Freedom to provide services / Freedom of establishment can't take place in the country of establishment i.e. country of the head office. Considering the above the plausibility checks are true, but unnecessary limiting.