Question ID: 2843
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.36.03, S.36.04
Status: Final
Date of submission: 25 Oct 2023
Question
We wish to flag a difference between the ITS and the annotated templates (after the 2.8 hotfix). The ITS has S.36.03.01 IGT - Off-balance sheet and contingent liabilities S.36.04.01 IGT - Insurance and Reinsurance. While the annotated templates (after the 2.8 hotfix) have S.36.06.01 IGT - Off-balance sheet and contingent liabilities and S.36.07.01 IGT - Insurance-reinsurance. i.e. the template codes are different. Can EIOPA please clarify if this is an error and if it is proposed to be updated in future updates?
EIOPA answer
The recodification of S.36.03 and S.36.04 was intentional. EIOPA goal was to align templates, including their order, with the FICO reporting.
As the amendment was incorporated after the finalisation of the ITS, it was not feasible to align the instructions at this stage. It is worth to note, that as the difference lies in codification of both tables, the business character for both tables is retained.
EIOPA considers adjust both the names and codes of these templates in the next ITS amendment.