Question ID: 3077
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
Status: Final
Date of submission: 18 Apr 2024
Question
My question is relating the relationship between S.37.01 and S.37.02 . I understand that S.37.01 requires only significant risks to be reported whereas S.37.02 requires all risks to be reported. My confusion is where we have an insurance policy with a counterparty which does not meet the threshold of S.37.01 to be reported, but is still an exposure- does this need to be reported in S.37.02? We do have thousands of policies that we are struggling to report this way in S.37.02.
EIOPA answer
According to Article 244 of the Solvency II Directive and Article 376 of the Solvency II Delegated Regulation, supervisors are required to monitor risk concentrations.
S.37.01 follows a proportionate approach as it is subject to a threshold defined by the group supervisor in order to detect significant risk concentrations counterparties. However, S.37.02 takes a different perspective and enables supervisors to identify and monitor exposures aggregated by currency, sector and country and is pivotal to assess the vulnerability of the group. Therefore, S.37.02 should include all type of exposures and should not be limited by a threshold defined for S.37.01 (e.g Art. 244(3) of the SII Directive).
For further information, especially the relationship with asset templates, please see also 3003 - European Insurance and Occupational Pensions Authority.