Question ID: 3007
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.22.01
Status: Final
Date of submission: 20 Feb 2024
Question
For C0060/R0010 Without volatility adjustment and without other transitional measures - Technical Provisions total amount of gross technical provisions without the adjustments should be reported. This suggest that only the amount of the adjustment on the gross technical provisions should be included. However there is also an impact on the amount recoverable from reinsurance. Should this impact amount not also be included since the QRT eventually states the impact on Own funds which will be impacted by both the impact om gross technical provisions and amount recoverable from reinsurance?
Background of the question
QRT S.12.01 and S.17.01 both reporting line for Technical provisions without volatility adjustment and without others transitional measures. The definition suggests that this amount would have to reconcile with S22.01. However Annex II definition for these lines in S.12.01 and S.17.01 state that it should hold the total amount of technical provisions without the mention that this should be the gross or net amount. S.22.01 Annex II does mention gross technical provision however we would expect to report the net amount since impact on recoverable from reinsurance also impact own funds amount.
EIOPA answer
The requirement to report gross amounts in S.12.01 and S.17.01 is given in their general comments section of Annex II in the ITS 894/2023 and not repeated in individual cell instructions. Regarding S.22.01, the relevant cell instructions explicitly require reporting gross amounts. See e.g. C0010/R0060 item description for Annex II, section S.22.01, in the ITS above.