Question ID: 2695
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.18.01
Status: Final
Date of submission: 13 Jun 2023
Question
We have a question regards the new S.18.01 data point (C1000 R1000, "Identification of material non-life lines of business, Lines of business included") added to the 2.8 taxonomy and associated LOG guidance (as set out in the DRAFT business package supporting 2.8.0 taxonomy). This field can hold multiple selections. Normally in such cases EIOPA require (and enforce through a regex based validation rule) a comma-separated list of representative codes (taking the item number from the associated label). Is this also the requirement for this datapoint? For example, if the filing entity wants to report "5 — 5 and 17 Other motor insurance" and "6 — 6 and 18 Marine, aviation and transport insurance", should this been entered in C1000 R1000 as "5,6"? Also we would like to ask for clarification on the guidance, which states: "Identify the material lines of business considered in this template." A strict reading of this is that EIOPA wish this datapoint to indicate only the material lines of business for which information has been entered into S.18.01 and not included immaterial lines of business - which in Q&A#2606 EIOPA confirmed the optionality of filing with 100% coverage - that have also been included) For example, if an insurer has lines of business 1,3,5 material and 6,8 immaterial but has completed S.18.01 for all business (so S.18.01 includes information for lines of business 1,3,5,6 and 8) then C1000 R1000 should be "1,3,5" (putting aside the matter of convention to be used). Is that correct?
EIOPA answer
EIOPA confirms that, in the example given, a value of “5,6" is expected to be reported. The way in which this and other multiple-choice fields are reported is described in the EIOPA XBRL Filing Rules, section V.5 Multi value elements reporting is applicable. We also consider introducing proper check in the future. Please note that based on the currently used approach we expect the patter to be as follows: "^(1$|1,){0,1}(2$|2,){0,1}(3$|3,){0,1}(4$|4,){0,1}(5$|5,){0,1}(6$|6,){0,1}(7$|7,){0,1}(8$|8,){0,1}(9$|9,){0,1}(10$|10,){0,1}(11$|11,){0,1}(12$|12,){0,1}(25$|25,){0,1}(26$|26,){0,1}(27$|27,){0,1}(28$){0,1}$", which should block any duplicate values.
Regarding field content, EIOPA expects that only material lines of business will be provided in R1000 C1000.