Question ID: 3198
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.09.01, S.29.02
Status: Final
Date of submission: 04 Dec 2024
Question
Could you please provide some context on some of the Validation Rules between QRTs S.09.01.01 and S.29.02.01, where these rules seem to contradict the ITS.
Background of the question
In the ITS we can find under S.29.02 - Excess of Assets over Liabilities - explained by investments and financial liabilities that "The difference between template S.29.02 (last table) and information in template S.09.01 is the inclusion of the revenue from own shares and the exclusion of Property held for own use." To us this results, by definition, in a potential difference in the values we report in S.29.02.01 in the fields C0010/R0070, R0080, R0090 (Dividends, Interests, Rents) and those we report in the S.09.01.01 in the fields C0070, C0080, C0090 (Dividends, Interests, Rents). Yet, there are three cross checks to verify if the amounts in both QRTs are equal: BV1126, BV1127 and BV1128. Could you please tell us whether we should follow the ITS and therefore will potentially not fulfil the validation rules, or whether we should fulfil the validation rules, but therefore will potentially not be in line with the ITS?
EIOPA answer
The ITS must be followed. The validation is of warning severity, so there may be the case that the equation is not valid.