Question ID: 2721
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: 26 Jun 2023
Question
Following up on Q&A 2613. It's not clear if the answer fully address our question. We asked 2 separate questions addressing C0050 (LoB) and C0040 (Cyber coverage) separately. The answer from EIOPA was: "For these reasons, scenario mentioned in point 1 and 2 should never happen. In both cases, it is expected filer would split the information by the Line of Business and Cyber Risk Coverage and report it in separate rows" But the reasons are not clear actually. In our question 1 we do not have any difference in Cyber coverage per se, so it is not clear what the "reason" are. Can EIOPA please confirm that if two products "share the same Product Identification, for same set of LoB and the same set of Risk Coverage" then they should be reported "using a single line" as per the guidance in the LOG and re-iterated in Q&A 2613. Really we are honing in on "set of LoB" in this guidance because to be a "set" it must be more than one but in the taxonomy C0040 can only accept one LoB (it is an enumeration data type) and so in fact this guidance could not be followed without a fix in the taxonomy.
EIOPA answer
If there is one commercial product referring to one product identification/LoB/risk coverage, only one line identifier will be reported and C0010 is empty.
If there is more than one commercial product referring to one product identification/LoB/risk coverage, only 1 line identifier is reported and C0010 is filled in.
If a commercial product refers to multiple LoBs or different risk coverages, then there will be as many line identifier reported as needed to reflect the number of LoB/risk coverages. C0010 is empty.
As such, the word "set" in LoB is in in fact wrong.