The titel of QRT S.04.04 is Activity by country - location of underwriting. However the log file states that the report should include the country for business underwritten in case of freedom to provide services. When using co-pilot to search for a clear definition for Location of underwriting and country of business underwritten it shows that these countries could differ: Question to co-pilot: what determines the country of the business underwritten under freedom to provide services and can this differ from the location of underwriting Copilot Sent by Copilot: The country of the business underwritten under the freedom to provide services (FOS) framework is determined by where the insured risk is located or where the policyholder resides or operates. This can indeed differ from the location of underwriting, which is where the underwriting activities, such as risk assessment and pricing, are conducted.

Please see 2 simplified examples and explanations to clarify the expected reporting in S.04.04 and S.04.05:

Example 1: Direct business within EEA

Policyholder from Country A goes in Country A to an insurer also from Country A to insure his house in country B for 100€ written premium. No branch is involved in this example. Country A and B are within the EEA.

This is FPS business with home country A to host country B. Country B is both location of risk AND country of underwriting.   

The business has therefore to be reported as business by the headquarter (identified in S.04.03) as follows:

                S.04.04 R0020 C0020 = 100€

                S.04.04 R0020 C0030 = 100€ with R0010 = Country B

                S.04.05 R0020 C0010 = 100€

                S.04.05 R0020 C0020 = 100€ with R0010 = Country B

(Template S.04.05 under the condition of the thresholds)

For direct business with the EEA (both FPS and FoE, life and non-life) we would in general not expect any differences between S.04.04 “location of underwriting" and S.04.05 “location of risk". The physical place where the insurance contract has been priced, is signed, offered or agreed on, is in this context not decisive for the identification of “location of underwriting" in S.04.04 for direct business with the EEA.  

In S.04.04 we expect to have the same approach towards the identification of the host country as in S.04.01 in the taxonomies before 2.8.0.

Example 2: Reinsurance within EEA
 

                Primary (re)insurer from country A signs a reinsurance contract with a reinsurer from country B.

The reinsurer from country B reports this business in S.04.04 in C0010 “Business underwritten in the country of establishment" and in S.04.05 in C0020 with R0010 = Country A.

For reinsurance contracts, we would generally expect a difference between the “location of underwriting" and the “location of risk" in 04.04 and S.04.05 if the ceding (re)insurer and the reinsurer are from different countries.