Question ID: 2953
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.19.01
Status: Final
Date of submission: 16 Jan 2024
Question
Following the changes to the ITS, we have identified a potential issue with the taxonomy validations between S17 and S19. In the new ITS it states that for the Undiscounted Best Estimate Triangles, the values should be reported "net of salvage and subrogation and excluding any expenses, as well as any future premiums." No such guidance has been issued for S.17 (R0160/R0250). However, in the EIOPA QRT taxonomy 2.8.0 validations, there are a number of validations (BV1438 - BV1453, & BV1474 - BV1486) that advise reconciliation between the two templates. However, if we are to assume that the same values are desired in S.17, then this would also lead to an inconsistency, as there are a number of validations (e.g. BV393_1-3) that advise reconciliation between the best estimate in S.17 and the total non-life TPs in the balance sheet (S.02) Can you please advise.
EIOPA answer
Please note that there seems to be a mistake and the BE triangles are to be reported including (and not excluding) any expenses. This will be clarified in the next ITS amendments.
(The instructions should actually read “net of salvage and subrogation and including any expenses").