Question ID: 3503
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Status: Rejected
Date of submission: 30 Jan 2026
Question
I have a question regarding the two QRTs S.04.04 (Location of underwriting) and S.04.05 (Location of risk). The blocking validation BV1863 is defined as follows: “{t: S.04.04.01.01, r: R0020, c: C0010, z: Z0001} + {t: S.04.04.01.01, r: R0020, c: C0020, z: Z0001} = {t: S.04.05.01.01, r: R0020, c: C0010, z: Z0001}”. This implies that the total gross written premiums reported in S.04.04 for a given line of business and a given underwriting entity must be equal to the total gross written premiums reported in S.04.05 for the same line of business and the same underwriting entity. However, the log file for S.04.05 states that “Template S.04.05 focuses on the location of risk”, while the log file for S.04.04 states that template S.04.04 focuses on the location of underwriting. Does this mean that, in template S.04.05, the item (R0020, C0010) for a given line of business and a given underwriting entity should be populated as follows: • Option 1: with the total gross written premiums underwritten by the underwriting entity; or • Option 2: with the total gross written premiums of all underwriting entities for which the location of risk corresponds to that underwriting entity? If option 2 is correct, it would not be possible to comply with validation BV1863, since the log file for S.04.04 requires items {t: S.04.04.01.01, r: R0020, c: C0010, z: Z0001} +{t: S.04.04.01.01, r: R0020, c: C0020, z: Z0001} to reflect the total business underwritten by the underwriting entity. In addition, the total gross written premiums by location of risk reported in QRT S.04.05 would not cover the company’s total underwritten business. This would also be inconsistent with the blocking validations between S.04.04 and S.05.01, for example BV1970: “sum({t: S.04.04.01.01, r: R0040, c: C0010; C0020, z: Z0001, filter: [s2c_dim:BL] = [s2c_LB:x93]}) = {t: S.05.01.01.02, r: R2210, c: C0240, z: Z0001}”.
EIOPA answer
The question has been rejected as the issue it deals with is already sufficiently clear from the instructions of S.04.04 and S.04.05 in the ITS on Reporting. EIOPA confirms that S.04.04 looks at the risk from the perspective of location of underwriting while S.04.05 is focused on location of risk. Both templates are broken down by Lines of business and Code of undertaking. However, as the undertakings should report all business for both S.04.04 and S.04.05, the gross written premium reported in them shall aligned. Given that S.05.01 should also contain all insurance business the existing validation BV1970 sums all undertakings on S.04.05 and compares to S.05.01 data (aligning the values by LoB) and as such is correct.