Question ID: 3095
Regulation Reference: (EU) 2023/895 - ITS for the disclosure of solvency and financial condition report
Topic: Reporting Templates, Risk concentration, Group Solvency Requirement
Template: S.37.02
Status: Final
Date of submission: 17 May 2024
Question
In COMMISSION IMPLEMENTING REGULATION (EU) 2023/894 of 4 April 2023 S.37.02 it says the following: S.37.02 – Risk Concentration – Exposure by currency, sector, country General comments: The tables shall include the risk concentration between entities in the scope of group supervision and third parties. All exposures should be represented by currency, sector and country, starting from the maximum exposure to the minimum one. In case the country, sector or currency is not relevant the figures may be reported under an ‘Other’ category. The ‘sector’ should be presented in the split for NACE code 1st level of disaggregation (letter). The tables shall be based on all the exposures (full balance sheet) after credit or insurance risk mitigation technique and exemptions (net amount). For NACE code "K" it is not valid according to Dictionary. In S.37.01 it is regulated to report on 4th level and not on any other level but in S37.02 as above it should be right to report on NACE code 1st level. We believe that the Instructions and the dictionary says different things for S.37.02 in this aspect. What should we report? 1st level or 4 level for Sector code K.
EIOPA answer
EIOPA confirms that there is an error in the XBRL taxonomy. The constraints (usable/non-usable) of the hierarchy members that can be found in the dictionary part are not reflected in the table definition layer.
Please also note that the NACE codes reporting is defined in S.06.02 and S.11.01 as follows: “Identify the economic sector of issuer based on the latest version of the Statistical classification of economic activities in the European Community ('NACE') code (as published in an EC Regulation). For NACE sections A to N full four-digit reporting of the NACE codes ` remaining sections the letter reference of the NACE code identifying the Section shall be used as a minimum for identifying sectors (e.g. 'P' or 'P8501' would be acceptable)".
However, in S.37s the old version of definition was used “Identify the economic sector of the external counterparty based on the latest version of NACE code (the first level of hierarchy – the letter)." The stakeholders face the issue exactly for this template when they try to fill the Sector following the instructions. While, for the other two templates there is no issue as the instructions are aligned with the modelling.
Therefore, we would like to kindly ask for reporting the full code. Please note that the exact NACE list is used for all fields where reporting sectors is required. As for the instructions and the issue with the implementation, EIOPA will review the issue in the 2.8.2 minor release.