Question ID: 3462
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: 14 Nov 2025
Question
QRT S.06.04 - KPI transition risk R0010: we would like to know if we have to include in the total of investments (ratio denominator) also the loans on policies and loans to individuals (rows R0240 and R0250 of the S.02.01). Our doubt is due to the fact that those positions don't have a NACE code in the LoA (S.06.02 QRT),because it's not applicable as mentioned in the log EIOPA for column C0230. Therefore they are not included in the ratio numerator (only positions with NACE codes A-N are included).
EIOPA answer
Loans on policies and loans to individuals (rows R0240 and R0250 of the S.02.01), and more broadly, loans and mortgages should be excluded from the denominator, as the instructions require reporting the investments exposed to transition risk in relation to the total investments. Therefore, other assets such as loans and mortgages, re-insurance recoverables/receivables and own shares should be excluded.
For more information on the NACE codes relevant for this template, see also 3038 - European Insurance and Occupational Pensions Authority.