Question ID: 2815
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: ECB Template E.04.01
Template: S.12.02
Status: Final
Date of submission: 04 Oct 2023
Question
We have noted an inconsistency between the instructions for S.12.02 and for E.04.01(new ECB QRT): - S.12.02 is not due when home country represents 100% of the sum of the technical provisions calculated as a whole and gross best estimate; - E.04.01 instructions state: "As in S.12.02, the home country must always be reported, while countries outside the materiality threshold should be reported aggregated in ‘other–EEA’ or ‘other–non EEA’. Countries that are inside the materiality threshold in S.12.02 are also to be reported country -by -country in template E.04.01." In our understanding, E.04.01 is due even if home country represents 100%, but it's not the same requirement for S.12.02. Our question is: if we don't fill in S.12.02 as we have 100% home country, should we fill in E.04.01?
EIOPA answer
Yes. E.04.01 always has to be reported, also when no cross-border business exists. Please note that instructions have been updated to clarify.