Question ID: 3505
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: Rejected
Date of submission: 03 Feb 2026
Question
Undertakings using the standard formula may use internal ratings for internal credit quality assessment purposes in cases, where no external rating by an ECAI is available. We understand that those internal ratings shall not be reported in S.06.02, C0340. Internal ratings according to Art. 176a as well as Art. 105 which may be used as basis for the CQS represent an exception here. Does EIOPA agree that only CQS based on external ratings as mentioned before shall be reported in S.06.02, C0340? Nevertheless, where no external rating by a registered ECAI is available an internal rating may provide valuable additional supervisory information on the asset quality of an undertaking. Thus, for undertakings using the standard formula, we would appreciate to use S.06.02, C0350 in order to report such internal ratings. Does EIOPA agree with it or is S.06.02, C0350 restricted to internal model users? In the latter case, where else could such internal ratings be reported in S.06.02?
EIOPA answer
The question has been rejected as the matter it refers to is sufficiently clear from the instructions of template S.06.02 in the Commission Implementing Regulation (EU) 2023/894 of 4 April 2023 laying down implementing technical standards for the application of Directive 2009/138/EC of the European Parliament and the Council with regard to the templates for the submission by insurance and reinsurance undertakings to their supervisory authorities of information necessary for their supervision.
The instructions of Cell C0350 for template S.06.02 refer to “Internal rating of assets for undertakings using internal ratings”, however it does not distinguish between type of undertakings, e.g. SF users or Internal model users, and therefore C0350 is not restricted to internal model users.