Question ID: 3184
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates, Validations
Template: S.22.01
Status: Final
Date of submission: 07 Nov 2024
Question
Is it possible that the validation rule BV2159-1 is not correctly implemented?
Background of the question
From the EIOPA_SolvencyII_Validations_2.8.2 we deduce that for columns C0010 (Amount wo LTG/trans), C0020 (Amount wo TP trans), C0040 (Amount wo IR trans), C0060 (Amount wo VA and other trans), C0080 (Amount wo MA and other trans) and C0100 (Impact of all LTG), we need to fulfil the condition: R0090 (SCR) * R0120 (SII Ratio) = R0050 (Eligible OF). But we understand C0100 is defined as the total impact of all LTG (i.e. delta between C0080 and C0010), also for the ratios as this properly reflects the impact of the applied LTG measures have on the results. By doing this, the rule will not be valid. To solve the warning we would need to provide in R0120 the ratio of the delta on your EOF over the delta on SCR, which seems a bit strange as it would no longer reflect the actual impact the LTG measures have on your Ratio.
EIOPA answer
The BV2159 should not include the C0100 and thus it was decided to deactivate this validation for the time being. The issue stemmed from faulty instructions which will be corrected during the next ITS review.