IORPs that invest in derivatives must have accounts on guarantees. These accounts could be in institutions that are not banks and therefore they are not considered as deposits. In our national balance sheet there is an specific account for this item, but there is not in the EIOPA Balance sheet PFE0201 and neither in CICs that have to be reported in the template of assets (PFE0602). We would appreciate if you confirmed us the correct way to report this item in the PFE0201 balance sheet and in the PFE0602.

We can confirm that there is indeed no dedicated line item in the EIOPA IORP reporting framework for guarantee or margin accounts held by IORPs in connection with their derivative positions, particularly where those accounts are held at non-bank counterparties.

Our view is that these accounts should be reported under R0200 ("Other investments") in the PFE0201 balance sheet. EIOPA's Q&A 2147, addressing where unclassifiable assets should be reported in the IORP framework, makes clear that where the asset in question is an investment, it must instead be shown as "other investment. Margin and guarantee accounts, being directly linked to derivative positions, are in our opinion investments.

In PFE0602 the appropriate code would be ##09. This is also reconciled by the validation rules linking balance sheet and list of assets.