Question ID: 3441
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.06.02
Status: Final
Date of submission: 29 Oct 2025
Question
Certain investment funds publish official Net Asset Values (NAVs) several weeks after the respective quarter-end date. Due to following processes (NAVs are input for valuation of technical provisions under IFRS17 and Solvency II), we are not able to use such updated prices in a way that ensures full consistency with the IFRS/local GAAP and Solvency II valuation of technical provisions. Could you please confirm that a) in the absence of timely availability of final quarter-end valuations (e.g. for illiquid or infrequently priced investment funds) b) provided that the difference is immaterial for the respective insurance undertaking and c) the approach is consistent with IFRS 13 and documented in the valuation policy the use of previous month-end valuations (NAVs) is compliant and doesn't represent any reporting mistake in S.06.02?
EIOPA answer
The submission of correct and meaningful information to supervisory authorities is a pivotal prerequisite for effective supervision and policyholder protection.
Therefore, the Solvency II Directive includes several requirements for undertakings to ensure efficient management and reporting concerning asset information.
The prudent person principle in Article 132 of the Solvency II Directive requires undertakings only to invest in assets and instruments whose risks the undertaking concerned can properly identify, measure, monitor, manage, control and report, and appropriately take into account in the assessment of its overall solvency needs in accordance with point (a) of the second sub paragraph of Article 45(1).
Furthermore, and in accordance with Article 35(5) of the Solvency II Directive, insurance undertakings are required to have appropriate systems and structures in place to fulfil the reporting requirements under Solvency II.
According to Article 40 of the Solvency II Directive the administrative, management or supervisory body of the insurance or reinsurance undertaking has the ultimate responsibility for the compliance with such requirements.
In addition, Article 3 of the ITS on Reporting clarifies that undertakings are responsible for the quality of the information reported:
Insurance undertakings need to re-submit information as soon as practicable where
- the information originally reported has materially changed in relation to the same reporting period after the submission of that information to the supervisory authorities or to the group supervisor; or
- the supervisory authorities or the group supervisor request it due to material data quality issues.
In light of the legal requirements, Eiopa encourages you to contact your supervisory authority directly as the final answer will depend on a case-by-case analysis.