In Q&A 3164 EIOPA gave an example for defining Country of Underwriting (S.04.04) and Country of Risk (S.04.05) stating: "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"." Since there is no difference expected, what then is the additional reporting value of QRT S04.05 compared to S.04.04 for Direct business?

In case of direct business, no differences are expected between S.04.04 and S.04.05 for most of the contracts. However, for specific contracts, there might be differences between the location of risk and location of underwriting. For example, location of risk is defined for vehicles of any type as their country of registration. This country can be different from the country of underwriting. This example highlights that location of risk and underwriting can be different and the in-force version of the reporting templates accommodate this possibility.