Question ID: 3406
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.06.02, SE.06.02
Status: Rejected
Date of submission: 20 Aug 2025
Question
This question is referred to the answer to Q&A 2299 (how to assign cic code for ETC (Exchange Traded Commodity) instruments. EIOPA expected that ETCs need to be reported with CIC Category 5 "Structured notes" and the sub-category that fits the risk exposure (like "commodity risk - 56") or "other". But this approach doesn't match with Annex V (Definitions of the CIC Table) Could you please explain criteria to define and ETC like a Structured bond. If I have to report an ETCs (i.e. investing in commodities like gold) and in the fund's prospectus is reported that the securities are “transferable securities” for the purpose of the UCITS Directive why it cannot be defined as cic code 49 or 46?
Background of the question
Q&A 2299
EIOPA answer
The question has been rejected because the matter it refers to has been answered in Q&A 2299. It has to be noted that the answer explicitly refers to the possibility that an ETC can be categorised as an AIF.
In general, reporting entities are expected to apply a consistent, well-reasoned, own assessment when assigning CIC codes, considering the risks and characteristics of the respective asset.