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European Insurance and Occupational Pensions Authority
 

3282

Q&A

Question ID: 3282

Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision

Topic: Reporting Templates

Template: S.06.02

Status: Final

Date of submission: 06 Mar 2025

Question

One of our insurance entities was contacted by their local authority regarding Q4_2024 reporting. They asked them to fill column “C0145 Long-term equity investment” in the list of assets (S.06.02) also for assets without CIC 3 or 4. They demand that for all other CIC the element “9 – not applicable” must be filled in. Together with our system provider we analyzed this topic and found the following instructions. From the LOG File, we think it is clear that the column only has to be filled for CIC 3 and 4. But the EIOPA Q&A lead to some confusions. Reading the Q&A 2651, EIOPA confirms that there are 4 available options. They furthermore refer to Q&A 2655 which is clearly only about C0296 and C0297. Reading the Q&A 2756 (which was raised by an entity because the answer from 2651 was not clear enough) it is only expressed that for CIC 3 and 4 the only available options are the closed list elements 1,2 and 9. Therefore, these Q&A aren't clear enough in our opinion and unfortunately, there aren't any validation that can help us on this. Furthermore we can clearly confirm that from Q4/2023 with the XBRL taxonomy 2.8.0, all our Insurance entities have always left blank the cell C0145 for CIC different from 3 and 4 and there was never a feedback by any local supervisor on this topic. Our system provider says the same for his customers for Solvency II reporting. Additionally it is possible that one regulator says we need a value there; but in another country, the regulator is fine with the current implementation. In the end, it would be great if we could get a quick clarification on this topic from your side so that we have something “on paper” we can show the local authority. For sure there needs to be more clarification by EIOPA within both the new ITS for reporting and the next XBRL Taxonomy version (2.10.0 ?), too.

Background of the question

The problem we have now is that our system provider implemented the QRT in that way that C0145 is only editable for CIC 3 and 4, as this is correct from a functional point of view (see LOG file). Furthermore our system provider says that a short term change of this cell for this Annual reporting would lead to a burdensome impact to the solution because a lot of changes would have to be done (for example removing account restrictions, removing report check and report conditional formatting, change upload ETLs, change the XBRL file creation, align the documentation and the solution input files...). And all this during a already productive reporting period where a lot of QRTs are already finished!

EIOPA answer

The item C0145 in S.06.02 is indeed only applicable only to CIC categories 3 and 4. For all other CIC categories, there is no difference in the information content for the receiving supervisors between not reporting this item and selecting option 9. Therefore, it is acceptable not to report item C0145 for CIC categories other than 3 and 4.