On both S.21.01 and S.21.03, the following paragraph is a very big concern : "This template shall be reported for each material non-life line of Business for direct business, as defined in Annex I to Delegated Regulation (EU) 2015/35, representing a coverage of 90 % of the non-life technical provisions. Line of business shall be reported in accordance with the amount of technical provisions, i.e. the line of business with the highest amount of technical provisions." Where the 90% threshold is supposed to be applied. On companies with several LoBs, should we report LoBs until we reach a representation of 90% of technical provisions ? Is the threshold applied within the reported LoBs, meaning we only have to report the 4 mandatory LoBs + the eventual other mandatory LoBs depending on the NCA decision (as it was before taxonomy 2.8.0) Another issue with the paragraph quoted before is that the first sentence let us think we need to report one or several LoBs; but the second sentence implies, the way it’s formulated, that we should only report the most important one.

The scope of S.21.03 is limited to direct business and includes only four mandatory lines of business plus any additional line of business considered mandatory by NCAs' decision. Therefore, the threshold should be calculated considering only mandatory lines of business (i.e., four mandatory lines of business plus any additional life of business considered mandatory by NCAs' decision). The threshold is used to determine the mandatory LoBs included in the scope of the template, so immaterial LoBs are not required to be reported, but material LoBs (i.e., up to ensure a 90% coverage in terms of TPs) are fully reported. The last sentence, which should refer to “lines of business" in plural, means that the LoBs included to reach the 90% threshold should be the most material ones in terms of technical provisions.