Question ID: 3500
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: Rejected
Date of submission: 22 Jan 2026
Question
With reference to your answer to our previous Q&A 3462, we ask you to confirm us: 1) in the denominator we have to consider the total investments only (row R0070 QRT S.02.01); therefore we exclude index and unit linked assets, loans and mortgages, reinsurance recoverables, receivables, cash & cash equivalents, own shares, any other assets, etc. Is it right? 2) in the numerator we consider all assets which have NACE codes A-N, excluding index and unit linked portolio: this means that cash and loans with a NACE code are included. Is it correct? Thanks for your feedback
EIOPA answer
The question has been rejected as the issue it deals with has already been clarified in Q&A 3462 and is sufficiently clear from the instructions of template S.06.04 in the ITS on Reporting.
Q&A 3462 has clarified that the denominator of the ratio should rely on the total investments and therefore excludes other assets, such as loans and mortgages, re-insurance recoverables/receivables. The instructions refer to the consistent identification of investments exposed to climate related transition risk and therefore nominator and denominator should be based on the same values, i.e. total investments.
Furthermore, the instructions of template S.06.04 clarify that the identification of investments exposed to transition risk shall be consistent with the classification made and reported through the four-digit level NACE codes for NACE sections A to N, as prescribed in S.06.02. For further details, see again 3038 - European Insurance and Occupational Pensions Authority.
Please also note that EIOPA intends to further clarify the instructions of the template in the ongoing revision of the ITS on Reporting.