Question ID: 33
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Status: Final
Date of submission: 13 Mar 2014
Question
The “Technical Annex VI: Data checks” “contains the checks that data received should comply with”.
From EIOPA answers to Insurance Europe comments, we understand that EIOPA recognizes that some logical cross-templates checks exist which are not listed to date in the “Data checks“ Annex (such as checks between D1/BS-C1 or D2O/BS-C1 even if those QRT are within the scope of the preparatory guidelines).
We understand that these additional cross checks (which are clearly indicated in the Logs of D1 and D2O) should be met for the sake of the overall consistency of the SII reporting but it is not clear if this will be a requirement to be met a later stage of Solvency2 implementation by companies (i.e. post 2016 ?).
We would like a clarification of EIOPA regarding the completeness of theoretical checks - especially related to BS-C1 - (on which to build IT process for QRT production and avoid interpretation of correlations between QRT) and the practical checks (to be met to reach minimal compliance) on the complete list of QRT (and not only the QRT included in the preparatory guidelines).
EIOPA answer
EIOPA acknowledges the importance of identifying the full set of validations as soon as possible, however it is not possible to publish them before the finalisation of the templates.
EIOPA will publicly consult of the full reporting package, including validation at the end of 2014. Although they need to be revised the validations identified in the LOGs of the July 2012 report should be considered as a good basis for implementation.