Question ID: 3452
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Minimum Capital Requirement (MCR), Reporting Templates
Template: S.28.01
Status: Rejected
Date of submission: 03 Nov 2025
Question
“We have one error in S.28.01 QRT BV918 with regards to position R0230/C0050. This is the first quarter when we have Unit Linked business and the value of technical provisions is negative since portfolio is very profitable and the business just started. However the validation restricts us from having a negative value. The instructions of the positions refer to “floor equal to zero”. Does this mean that we should report 0 in this case?”
EIOPA answer
The question has been rejected as the issue it deals with is already clarified in the instructions of Cell R0230/C0050 (Index–linked and unit–linked insurance obligations – Net (of reinsurance/SPV) best estimate and TP calculated as a whole) for S.28.01 in the Commission Implementing Regulation (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision. EIOPA confirms that if the calculation would lead to a negative value, zero should be put in Cell R0230/C0050 .
For additional background on the validations, see also 558 - EIOPA.