Question ID: 3592
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Status: Final
Date of submission: 11 Jun 2026
Question
In Public working draft 2, for the SD.27.03 QRT: In the QRT instructions, the “number of risks” is defined as: “Best estimate of number of risks. The number of risks should be counted as individual physical structures covered under a policy.” We would appreciate further clarification on how this definition should be consistently interpreted and applied in practice, as several situations give rise to ambiguity. In particular, we would welcome guidance on the following points: Definition of an “individual physical structure” How should a structure be defined in cases where multiple buildings are: physically connected (e.g. via shared walls, corridors, or technical links)? partially connected but separable (e.g. semi-detached or linked industrial halls)? Minimum separation criteria Is there any minimum physical distance or separation criterion (e.g. in meters or construction characteristics) that distinguishes separate structures? Single address vs multiple structures How should cases be treated where multiple distinct buildings exist under a single address (e.g. industrial sites, campuses)? Is counting based on addresses considered acceptable as a proxy, or should a more granular approach be applied where feasible? Shared infrastructure or dependencies Should structures sharing critical infrastructure (e.g. utilities, roofs, foundations) be considered: one single risk, or multiple risks? Policy vs physical view In case of policies covering multiple structures: should the count strictly reflect the physical reality (number of structures), or can contractual aggregation (e.g. insured as one risk under a single sum insured) be taken into account? Materiality and proportionality To what extent can simplifications or proxies (e.g. address-based counting, exposure bands) be used in case detailed structure-level data is not available? Given the potential impact on exposure reporting (notably for NatCat QRTs), further clarification would ensure consistent application across undertakings and improve comparability of reported data. We would appreciate any additional guidance or references (e.g. existing Q&A or examples) that clarify the intended interpretation. Furthermore we would also like clarification if deductible & loss limits need to be left blank for all industrial properties, or only for those with layered business and/or coinsurance, as in the exposure field the latter is suggested, but in the instructions for deductible & loss limit this is more generalised to all industrial insurance.
Background of the question
Question is based on the business package instructions of the Public working draft 2.
EIOPA answer
The definition of “number of risks” in the QRT 27.03 is intentionally flexible to accommodate different insurance policy arrangements and market-specific conditions.
The number of risks should be counted as individual physical structures covered under the insurance policy. Undertakings are allowed to use estimates, where necessary, to reflect the policy characteristics to the best of their ability while ensuring consistency in their approach. Counting the number of risks based on addresses may be used as an acceptable proxy when the undertaking considers this estimate appropriately reflects its policy characteristics.
The fields “Deductible” and “Loss Limit” shall not be reported when the field “Asset Type” is equal to “Industrial”.