Question ID: 3384
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.06.04
Status: Final
Date of submission: 17 Jul 2025
Question
Could EIOPA clarify Q&A 2941. The answer is: "If an insurance undertaking is exempted from reporting annually the template S.06.02 it shall not report both templates S.06.03 and S.06.04. If the insurance undertaking is not exempted from annually reporting the template S.06.02 it shall report S.06.04." Given there are different bases for exempting S.06.02, it would be good if EIOPA could clarify which exemption is referred to in the sentence "If an insurance undertaking is exempted from reporting annually the template S.06.02 it shall not report both templates S.06.03 and S.06.04". For example we don't believe the case where the firm is exempted from reporting S.06.02 annually due to it having been reported in Q4 means that S.06.04 is not required annually.
EIOPA answer
The template shall be based on the S.06.02 Q4 submission. Only in case when an undertaking is exempted of quarterly reporting S.06.02 under Article 35a(1) of the Solvency II Directive shall the template be based on its annual submission.
This case has been clarified in EIOPA’s proposal for the revised Implementing Technical Standards on Reporting. These proposals are contingent upon the adoption by the European Commission.
Furthermore, 2941 - European Insurance and Occupational Pensions Authority has been revised accordingly.