Question ID: 2816
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Validations
Template: S.23.01
Status: Rejected
Date of submission: 05 Oct 2023
Question
The following issue refers to Rule BV396. First of all we wonder why this rule applies for the Annual SII report but not for the quarterly submission as at Q4? The other question is contentwise: The formula refers to the balance sheet position "Amounts due in respect of own fund items or initial fund called up but not yet paid in". According to our understanding this amount that has not yet been paid in could refer to any kind of own fund item in the S.23. sheet. Under this assumption it is not clear to us why this position is only aligned with the positions "Ordinary share capital" as well as "Initial funds, members' contributions …" We experienced a case with an amount due in respect of "Share premium account related to ordinary share capital" that has been called up but not yet paid in. In this case the balance sheet positions as mentioned above are filled out but for the S.23. sheet this amount has to be assigned to the "Ordinary share capital" incorrectly in order to not break the validation rule. Can you give us some guidance on that?
EIOPA answer
BV396 it is not applied for Quarterly transmission because S.23.02 template is reported only for annual frequency.
Definition for both fields within the S.23.02 includes ordinary share capital part but the question is if the "amount of ordinary shares that have been called up but not yet paid in [...], including own shares" include also the premium of share premium account related to ordinary share capital.