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European Insurance and Occupational Pensions Authority
 

2714

Q&A

Question ID: 2714

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.02.02

Status: Final

Date of submission: 23 Jun 2023

Question

In general, the reporting instructions update coinciding with the 2.8 taxonomy clarify how to treat negative amounts within the materiality threshold calculations (e.g. S.02.02, S.12.02, S.17.03 etc.) and also where non-life and life business is present (e.g. S.30.01 through S.30.04). These cases are not specified though for S.31.01 and immaterial currencies apropos C0155. 1. Can EIOPA please confirm if any special treatment is required for negative reinsurance recoverables (e.g. as specified in S.02.02 in the 2.8 updated logs) and we note in eiopa-bos-20-754, EIOPA state in para 2.33: ""This should be applicable in all templates with thresholds using Technical provisions value."" so we believe this should be the case (although we also note para 2.491 from the same document but it is unclear what this is in relation to exactly e.g. new fields or the threshold?). Further can EIOPA confirm (as implied via Q&A 2571) that the calculation is based on overall total (and not separately for non-life and life business). 2. Can EIOPA please confirm the threshold for reporting by currency in S.31.01 is 90%. We ask because in S.02.02 (where this information was previously given by currency), the threshold was reduced to 80%. 3. In anticipation of your answer confirming that an approach similar to S.02.02 is required (""In case the value of technical provisions, as reported in R0030 and R0120 in S.12.01 and R0060 and R0160 in S.17.01, is negative, for the purposes of the calculation of the threshold above the absolute value of those notional amounts should be considered without netting of technical provisions between different LoBs"") and that there is one overall calculation (not a split between non-life and life) we would like confirmation of how this should be performed in practice: - the denominator for the materiality threshold in S.31.01 is the sum of absolute amounts in S.12.01 C0020, C0040, C0050, C0070, C0080, C0090, C0110 thru C0140, C0170 thru C0200 row R0080 and sum of absolute amounts in S.17.01 C0020 through C0170 rows R0140 and R0240 -- we note that the S.02.02 guidance does not include the Gross TP calculated as a whole rows i.e, S.12.01 R0010 S.17.01 R0010. Is that correct, seems like they should be referenced as well. In which case the above would include S.12.01 R0020 and S.17.01 R0050 (Recoverables from TP calculated as a whole rows) - the numerator is the sum of absolute amount of S.31.01.01.01 C0100 where C0155 is ""Other currencies"" The division should not be > 0.1 for the materiality threshold to be successfully met. Do you agree? We acknowledge that in part you may disagree due to the fact that in S.31.01 there is netting allowed between different lines of business and hence we are not comparing like-with-like but we welcome your view. Of course if our assumption of an analogous approach to S.02.02 is not correct we would appreciate confirmation of if/how the above would be performed.

EIOPA answer

1. Regarding negative recoverables, the threshold in S.31.01 C0155 should be considering notional amount without netting recoverables. The threshold is unique and should be applied based on total recoverables, i.e., without differentiating between life and non-life".

2. The threshold is 90%.

3. The threshold is designed to cover most of reinsurance recoverables and any formula applied should be aligned with this purpose. It should be noted that in the formula proposed negative recoverables are not being addressed consistently, which in some cases may lead to undesirable side effects. For the denominator the formula proposed by the inquirer applies the absolute value function at LoB level (a bit more granular indeed, as the formula proposed is applied at S.12.01 column level). Conversely, for the numerator, the absolute value function would be applied per reinsurer but without considering LoBs. This inconsistency, in some specific cases, could breach the specific purpose of the threshold in C0155. Considering the threshold relates to the breakdown of S.31.01 in different rows, the numerator should be defined based on S.31.01 data as described by the inquirer: the absolute value of C0100 by reinsurer where C0155 is “other currencies", i.e., no breakdown by currency. Therefore, to be consistent, the denominator should also be based on the absolute value of C0100 by reinsurer without considering the breakdown by currency. It should be noted that any approach should consider all reinsurance recoverables, i.e., including those associated to technical provisions calculated as a whole. Finally, under the proportionality principle other approaches as the one described in the question are acceptable provided they do not lead to a material deviation in the scope of the template.​