Question ID: 2704
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.14.03
Status: Final
Date of submission: 19 Jun 2023
Question
Regards the new Cyber risk template (S.14.03) in 2.8 taxonomy, and the associate LOG guidance (in the draft business package supporting SII taxonomy 2.8.0). We have a question regards the new data point C0030 , "Product Identification"). 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 "(1) First Party Loss" and "(2) Third Party Loss" together, should this been entered as "1,2"? Would the following be an acceptable implementation for checking of C0030 (e.g. in Plausibility tests): if S.01.02.01 R0060 <> "6 - Reinsurance undertakings" then C0030 = 1 or C0030 = 2 or C0030 = 3 This is based on the LOG guidance: "In principle, only one item can be chosen from the list to characterise the Product Identification; however, in exceptional cases and in case of reporting from Reinsurance undertakings, multiple selection is allowed"
EIOPA answer
‘1,2’ is proper pattern to be reported in this field. Examples of how to report the multiple-choice options are described in more detail in EIOPA XBRL Filling Rules in section ‘Multi value elements reporting is applicable’.
Regarding provided suggestions for new validations, EIOPA agrees that check for specific pattern would provide added value for filers and considers implementing such check for the future taxonomy release (pattern: “^(((1$|1,){0,1}(2$|2,){0,1})(3$){0,1}){1}$” with ERROR (blocking) severity). However, EIOPA would not want to provide validation limiting multiple choices only to reinsurance undertakings, as there may be some scenarios where such values are appropriate, even for other types of undertaking.”