Question ID: 2925
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.37.01, S.37.02
Status: Final
Date of submission: 08 Dec 2023
Question
Regarding templates S.37.01 and S.37.02, we have a couple of questions relating to the reporting of insurance policies:
1. We wonder what a reporting group should do in the event that the group cannot easily produce the appropriate sector code relating to reported insurance policies (C0250) in S.37.01 and S.37.02. We can see that EIOPA has previously provided guidance in the case of insurance contracts attributable to natural persons, in which case "Other" may be applied when sector is to be assigned, compare the answer provided to earlier question # 2535. But our question is about the case where the correct sector code for a legal person (= a company) cannot not be found, what should then be done when reporting insurance policies in S.37.01 and S.37.02?
2. In relation to data required in cells C0010-C0030 (with regards to the identity of the external counterparty) and C0045 (group to which external counterparty belongs), we further wonder when reporting in regards to insurance policies (C0250) in S.37.01, what a company should do in the event that it is missing or cannot find the appropriate LEI code for the counterparty (and linked to this, the appropriate group parent) in S.37.01. We are not aware of any guidance that EIOPA has provided previously in relation to this question.
EIOPA answer
1. To find the sector of exposure, the document (NACE Rev. 1 : Statistical classification of economic activities in the European Community (europa.eu)) provides a section 'Rules for classifying statistical units' which describes how NACE codes are classified and the entities should act accordingly. Please enter in a dialogue with your Supervisor for specific cases.
2. The ITS describes how to act while reporting the identification code of the external counterparty for which both a LEI or a Specific Code e.g. that is used in the local market can be used.