Question ID: 3463
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision, (EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII)
Topic: Reporting Templates
Status: Rejected
Date of submission: 14 Nov 2025
Question
In 2016, Banque de France reformed the French negotiable debt securities market (TCN) and merged Certificates of Deposit (issued by credit institutions) and Commercial Paper (issued by non-financial corporations) into a single category called Negotiable European Commercial Paper (NEU CP) for short-term instruments (maturity up to 1 year) and created NEU MTN (Negotiable European Medium-Term Notes) for medium-term instruments (higher than 1 year). (Document basing on which we were implementing the changes into our system: "Reform of the negotiable debt securities market (TCN) May 2016"). As this reform was part of the modernization under the Place de Paris 2020 initiative, we would appreciate your perspective on the following points:
1. How does EIOPA interpret the 2016 French reform in the context of CIC classification?
2. Which CIC codes should be assigned to instruments classified as Negotiable European Commercial Paper (NEU CP) and Negotiable European Medium-Term Notes (NEU MTN), considering that NEU CP contain both former Commercial Paper and Certificates of Deposit?
3. Is there any possibility of aligning these instruments under a single CIC code or reconsidering the classification of Medium-Term Notes ?
Background of the question
For below ISIN’s the Instrument type are the same. But one is a Commercial paper and other is a Certificate of deposit and CIC is different for both. This may appear inconsistent at first glance, particularly when a CD is classified under a type code that implies CP. However, this inconsistency stems from a broader classification. Is it correct to have only NEU CP? Shouldn’t we have NEU CD as well? ISIN Instrument type CIC FR0129288066 NEUCP FR24 FR0129405355 NEUCP FR24 ISIN Instrument type CIC FR0128955939 NEUCP FR23
EIOPA answer
This question has been rejected because it seeks an interpretation of national legislation, which falls outside the scope of this Q&A process.