Question ID: 3343
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: n/a
Template: S.25.05, S.26.08
Status: Rejected
Date of submission: 15 May 2025
Question
With Taxonomy 2.8.2, the metric for S.26.08.01.01 C0010 was changed from mi92 to mi2952, making it now identical to the metric for S.25 05.01.01 C0010. The ITS stipulate that all cells in S.25.05.01.01 C0010 must be identical to the corresponding cells in S.26.08.01.01 C0010, except for the diversification in cell S.25.05.01.01 C0010/R0020, which is only defined as “Amount of the diversification effects between risk modules”. The identical metrics in Taxonomy 2.8.2 make it mandatory that the diversifications in S.25.05.01.01 C0010/R0020 and S.26.08.01.01 C0010/R0020 must also be identical. However, ITS defines the diversification in S.25.05.01.0. C0010/R0020 as “between the risk modules” and the dedicated Q&A doc on the IM QRTs states that the diversification in S.26.08.01.01 C0010/R0020 is “between and within the modules.” The identiacal metrics are in a contradiction with these different definitions of the diversifications. Please advice whether the two diversifications, in S.25.05. C0010/R0020 and in S.26.08 C0010/R0020 must be identical or whether the metrics for these cells are incorrectly defined as identical.
Background of the question
Change in the metrics forces identical diversifications in S.25.05 and S.26.08 despite different definitions in ITS and Q&A document
EIOPA answer
The Q&A document is correct, please see updated version for the 2.8.2 release:
Internal Model templates 2.8.2 release QAs
S.25.05.01.01 C0010/R0020 is Amount of the diversification effects between and within risk modules.
S.26.08.01.01 C0010/R0020 is Amount of the diversification effects between and within risk modules. (identical to S.25.05.01.01 C0010/R0020)