Question ID: 3367
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.27.01
Status: Final
Date of submission: 18 Jun 2025
Question
We believe that the answers to Q&A 1445 and 1182 is not clear enough on how to fill out C1510 for each country and for the total. 1) Should the income protection part be left out since C1420 and C1430 shall not be reported for each country? Meaning that C1510 should be calculated as 0.4 * Nc * Mc ? 2) Is the answer to 1) the same for all the rows i.e. countries R4100 to R4400 and the total R4420? 3) In 1182 you agree with R4420/C1510 being 0.000075 * 'Income protection pandemic exposure' + 0.4 * 'Sum of gross catastrophe risk charge for all countries' meaning 0.000075 * 'R4420/C1430' + 0.4 * 'SUM of C1510 from R4100 to R4400'. This does not make sense to us, since the SUM of C1510 from R4100 to R4400 already has the 0.4 taken into account, and you would use the factor twice?
Background of the question
Q&A 1445 and 1182
EIOPA answer
1)It is true that C1420 and C1430 shall not be reported for each country. However, the reporting by country of C1510 apart from the calculation 0.4 * Nc * Mc should include also the income protection namely, the term" 0,000075 * E". In fact, the instruction says that C1510 is the “Capital requirement before risk mitigation, for each of the countries identified, arising from the health sub-module pandemic." The health sub-module pandemic includes also the income protection pandemic exposure (see Article 163(1 and 2) of the Delegated Regulation). Q&A 1182 will be revised.
2) This implies also for all the rows i.e. countries R4100 to R4400.
3) The reporting of R4420/ C1510 shall be the 'SUM of C1510 from R4100 to R4410' filled-in in accordance with point 1 and including already the 0.4.