Question ID: 2977
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.29.02
Status: Final
Date of submission: 11 Feb 2024
Question
We have some questions we think clarification would be helpful on E.04.01 (and the relationship with S.29.02):
1. There is some doubt with E.04.01 for non-life business, where investment income and expenses are allocated to technical provisions. The ECB instructions (and Q&A#2683) imply that such amounts (which are included in S.29.02) SHOULD be included in E.04.01 (otherwise the relationship between S.29.02 and E.04.01 wouldn't hold for non-life business), is that correct. Further, if that is so, then we assume they should be included in ER0050 (as Q&A#2940 confirmed that all other rows are for life business only).
2. Could EIOPA confirm that non-life annuities are considered life business for E.04.01.16 purposes? Or would EIOPA expect EC0020 through EC0040 to be empty for a non-life insurer even if they had non-life annuities exposures?
3. Should Q4 list of countries be the same as the prior annual S.12.02 e.g Q4 31.12.2023 list of countries in E.04.01 should be the annual 31.12.2022 S.12.02 list of countries? Or should it match the same reference date (even though that annual return will not be submitted until a couple of months after the Q4)?
EIOPA answer
1. Non-life business included in S.29.02 that is part of the technical provisions should NOT be part of E.04.01. The connection between S.29.02 and E.04.01 only holds true under the assumption that there are NO non-life products with investment income and expenses with a participation to policyholders. ER0050 should include all life and non-life business that is in excess of assets over liabilities, thus that is not attributed to the policyholder.
2. Non-life insurer regardless of whether they have or do not have non-life annuities exposures can leave ER0010 to ER0040 empty.
3. The list of countries should refer to the list of countries of the same reference date. Thus Q4 2022 S.12.02 and annual submission 2022 S.12.02 should have the same breakdown (same list of countries), even if the annual return will only be submitted later.
Please see further information in the ECB instructions.