Question ID: 3151
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: Article 1(11) and (12) of Delegated Regulation (EU) 2015/35
Template: S.05.01
Status: Final
Date of submission: 04 Sep 2024
Question
We have a question regarding reporting amounts for Proportional reinsurance accepted (items R0120, R0220, R0320 etc.) in the S.05.01 template. Are the instructions for Written / Earned premiums in the ITS 2023/894 valid not only for Direct business, but also for Proportional reinsurance accepted? The instructions say that „Written/earned premiums shall be reported as defined in Article 1(11) and (12) of Delegated Regulation (EU) 2015/35 regardless of whether a local GAAP or IFRS is used.“ The ITS also says „This template shall be reported from a consolidated accounting perspective, i.e.: Local GAAP or IFRS if accepted as local GAAP but using Solvency II lines of business.“. And there are some views that according to this sentence values previously reported separately as reinsurance accepted are to be under IFRS reported together within Direct business, not in a separate row. However we suppose that Proportional reinsurance accepted should be reported regardless of whether a local GAAP or IFRS is used. Will you please provide a clear answer to this?
EIOPA answer
The instruction “Written/earned premiums shall be reported as defined in Article 1(11) and (12) of Delegated Regulation (EU) 2015/35 regardless of whether a local GAAP or IFRS is used" applies to all premiums, including those from proportional reinsurance accepted.
Proportional reinsurance accepted should be always reported in a separate line, as proportional reinsurance accepted has LoBs (13 to 24 in Annex I of the Delegated Regulation 2015/35) independent from direct business LoBs (1 to 12 in Annex I).