Question ID: 3466
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: 24 Nov 2025
Question
I am writing to seek further clarification regarding the recent revision to Q&A 2975. We have reviewed the revised guidance, but there remain some points of ambiguity which, if interpreted as written, could have significant implications for the classification of our bond portfolio and, consequently, our regulatory reporting and capital requirements. Specifically, I would appreciate your guidance on the following points:
1. Treatment of Non-EU/EEA Government Guarantees: The revised answer indicates that instruments fully, unconditionally, and irrevocably guaranteed by non-EU/EEA central governments should be categorised under CIC code
2. • Does this mean such instruments should never be classified as government bonds, even if the guarantee is equivalent in strength to an EU/EEA government guarantee? • Additionally, could you please confirm whether this applies regardless of the currency of denomination?
2. Practical Impact and Consistency: The revised classification rules could result in a significant reclassification of bonds previously treated as government exposures, potentially affecting capital requirements and risk management practices.
• Has EIOPA considered the potential impact on insurers’ balance sheets and capital calculations?
• Is there any transitional guidance or further clarification planned to ensure consistent application across the industry? Given the material impact these changes may have, I would greatly appreciate a detailed response or reference to any additional guidance that may assist in ensuring accurate and consistent reporting.
Background of the question
recent revision to Q&A 2975
EIOPA answer
Please note that Q&A 2975 has been revised to improve the clarity of the answer. In addition, it also has been amended to cover additional cases which have been raised in your Q&A.
The following clarifications have been added to Q&A 2975:
- Bonds, which are issued by Non-EU/EEA central governments , supra-national government institutions, regional governments or local authorities should be categorised with CIC 1.
- Instruments that are fully, unconditionally, and irrevocably guaranteed by non-EU/EEA central governments but not issued directly by non-EU/EEA central governments should be categorised with CIC code 2.
For further specific cases, see also 3518 - European Insurance and Occupational Pensions Authority.
In light of these amendments, EIOPA believes that no additional guidance is required for this aspect.
In general, the Q&A process provides a tool for EIOPA to ensure the consistent and effective application of European legislation within its scope of action. Hence, considerations regarding the impact on the market are embedded in the process.