Question ID: 3128
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision, (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Topic: Reporting Templates
Article: 1(35) of the Delegated Regulation 2015/35
Template: S.12.01, S.13.01
Status: Final
Date of submission: 19 Jul 2024
Question
We would like to clarify a topic about Future discretionary benefits (FDB) and Future guaranteed benefits (FGB). According to the definition of FDB in the ITS (COMMISSION IMPLEMENTING REGULATION (EU) 2023/894) for S.12.01, we understand that the Line of Business (LoB) “Index-linked and unit-linked” (UL/IL) cannot have FDB. This would mean that all Future benefits should be entered in the column FGB in S.13.01 as there is no other option – even if the future benefits for UL/IL are not guaranteed. Is our understanding correct? If not this, what would be the correct approach for the Future non-guaranteed benefits, especially for UL/IL? However, we would be also interested in case of other Life insurance LoBs: where is it expected to report the Future non-guaranteed benefits? Should we understand the Future discretionary benefits column of S.13.01 in a different way than the FDB in S.12.01, and the column in S.13.01 was intended to include the Future non-guaranteed benefits as well for all LoBs? Furthermore, in S.12.01 there is only “Future guaranteed and discretionary benefits” for the majority of the LoBs (except for Insurance with profit participation) – is it correct to enter all Future benefits here, also Future non-guaranteed benefits to this row? Does this actually mean “Future benefits” instead of “Future guaranteed and discretionary benefits”?
EIOPA answer
Future Guaranteed Benefits (FGB) in S.12.01 (and S.13.01) should include all future benefits that do not meet the definition of Future Discretionary Benefits (FDB) in article 1(35) of the Delegated Regulation 2015/35. Therefore, benefits from pure Index-linked and unit-linked (UL/IL) should be reported as FGB.
FDB has the same meaning across all reporting templates, including S.12.01 and S.13.01, and it is the definition in Article 1(35) of the Delegated Regulation 2015/35.
Correct, in S.12.01, “Future guaranteed and discretionary benefits" should include all future benefits.