Question ID: 2716
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.30.03
Status: Final
Date of submission: 23 Jun 2023
Question
Regards the changes to template (S.30.03) in 2.8 taxonomy, and the associate LOG guidance (in the draft business package supporting SII taxonomy 2.8.0). In 2.8 taxonomy EIOPA has replaced a series of commission related data points with a smaller set of commission related data points. Previously each of the old data points had clarification in the LOG guidance: “This item is only applicable for proportional treaties.” This clarification is missing from all of the replacement fields: C0390 Sliding scale commission C0400 Minimum claim ratio on which the amount of sliding scale commission is dependant C0410 Maximum claim ratio on which the amount of sliding scale commission is dependant C0420 Minimum commission C0430 Maximum commission C0440 Expected commission 1. To us, all of these are equally only applicable for proportional treaties. Would EIOPA agree that where C0090 (Type of treaty) is 1, 2, 3, or 13 (i.e. non-proportional treaty) then C0390 through C0440 would be expected to be empty? 2. When C0390 is applicable (ie C0090 (Type of treaty) is not 1, 2, 3, or 13) then C0390 should not be empty? Further if C0390 is “Yes” then C0400 and C0410 should not be empty or 0 else C0400 and C0410 should be empty? 3. Where commission is fixed then C0420, C0430 and C0440 are all equal? 4. Where C0420, C0430 and C0440 are applicable (e.g. proportional treaties) but there is no commission arrangement, should these fields be left empty (as opposed to set to value 0)?
EIOPA answer
1. C0390 – C0440 should be reported where relevant, i.e., where commissions are defined within the reinsurance arrangement. For treaties where no commissions have been defined, e.g., most non-proportional treaties, C0390 – C0440 should be empty.
2. If the treaty does not include commissions, C0390 should be empty. If C0390 is “No", then C0400 and C0410 should be empty. If C0390 is “Yes", then C0400 and C0410 should be filled in.
3. Yes, in case of fixed commissions, C0420, C0430 and C0440 should be equal. Please also see Q&A 2692.
4. Yes, where there is no commission arrangement, C0420, C0430 and C0440 should be empty.