Question ID: 2785
Regulation Reference: (EU) 2023/895 - ITS for the disclosure of solvency and financial condition report
Topic: Disclosure Templates
Article: N/A
Template: S.04.05, S.05.02
Status: Final
Date of submission: 05 Sep 2023
Question
We would like confirmation on a discrepancy between the definition of "country" to be used between the solo public template S.04.05.21 and the public version S.05.02.04. Both templates have the same title "Premiums, claims and expenses by country" but the rules for how to derive a country for a contract differs between the two templates. For direct business in S.04.05 there is a series of rules to use and in S.05.02 there is a different set of rules to be used (which in various scenarios would lead to a different country needing to be used). Is that intentional?
EIOPA answer
EIOPA is aware of the different expectations in defining the “country" in the public reports of S.04.05.21 and S.05.02.04. The idea behind this is that the solo disclosure mirrors the country definitions for country of risk in S.04.05.03, allowing the solo disclosure to be built directly off the solo supervisory reporting – and is different from that in place prior to the 2020 review. The group disclosure on the other hand is retaining the approach that was in place prior to the 2020 review.