Question ID: 2896
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision, (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Topic: Reporting Templates
Article: Article 11 of the Delegated Regulation 2015/35
Template: S.03.01
Status: Final
Date of submission: 14 Nov 2023
Question
In answer #2577 EIOPA stated that cash deposits that are recognized should also be reported in QRT S.03.01. and that government bonds pledged as collateral should also be reported in S.03.01. In former statements/answers EIOPA made counter instructions: In #934 EIOPA answered that Template S.03.01 should be filled in considering only the off-balance sheet items. Therefore, the assets in the balance-sheet that are pledged as collateral should not be reported in S.03.01. In #1322 EIOPA answered that Company shares [pledged] have not to be reported as a collateral pledged in S.03.01 (this template is only for off-balance sheet collaterals). Unit B (lender) will report in S.03.01 in R0100 collateral held for loans made or bonds purchased because it will be off-balance sheet item (company shares remain on Unit A balance sheet) Moreover in answer #2577 EIOPA stated that cash held as collateral should also be reported in S.03.01. In former statements/answers EIOPA made counter instructions: In #1073 EIOPA answered that collateral received in the form of cash should not be reported as an off-balance sheet item in S.03.01 but as an asset in the balance sheet. Could you please clarify? Is the origin statement that only off-balance positions should be included in the Off-balance sheet items QRT S.03.01 not valid anymore?
EIOPA answer
Answer to 2896: Q&As 934, 1073 and 1322 are correct.
Q&A 2577 has been reviewed accordingly. S.03.01 should only include off-balance sheet items, with the only exception of material contingent liabilities, which in Solvency II shall be recognised in the Balance Sheet according to Article 11 of the Delegated Regulation 2015/35 and should also be reported in S.03.01.