Question ID: 3610
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Template: S.02.01, S.06.02
Status: Final
Date of submission: 06 Jul 2026
Question
Could you please clarify EIOPA's position with respect to applying CIC 86, CIC 87, CIC 88 and their respective link with the Balance sheet fields R0240 and R0250 as it seems to be inconsistent throughout different publications.
Background of the question
At Q4 2023 a change in relation to CIC attribution was made for Mortgages and Loans: CIC 86 - Loans on policies CIC 87 - Loans to AMSB CIC 88 - Loans to other natural persons Where 87 and 88 should prevail over the above CICs 8*. In Q&A 2753, it was further specified that in the MCBS we should report: R0240 - Loans on policies - all policy loans independent on whether they are flagged with CIC 86, CIC 87 or CIC 88 R0250 - Loans to other natural persons - the remaining policy loans under CIC 87 and CIC 88 However, in the latest ITS (V2.10.0), it seems that the opposite is required: R0240 - Loans on policies - the loans flagged under CIC 86, plus those those under CIC 88? R0250 - Loans to individuals - CIC 87, plus those under CIC 88 which are not policy loans? We are also not sure why specifically AMSB (CIC 87) is mentioned in R0250 and not the other natural persons (CIC 88). Cfr. the ITS which state that: - R0240: Loans made to policyholders, collateralised on policies (underlying technical provisions). With regard to ‘statutory accounts values’ column (C0020), where- the split between loans on policies, loans and mortgages to individuals and other loans and mortgages is not available, this item shall not be reported. R0250: Financial assets created when creditors lend funds to debtors - individuals, with collateral or not, including cash pools. With regard to ‘statutory accounts values’ column (C0020), where- the split between loans on policies, loans and mortgages to individuals and other loans and mortgages is not available, this item shall not be reported. Loans to natural persons in case of AMSB, no matter if mortgage or loans on policies or uncollateralized, are to be included as well.
EIOPA answer
EIOPA agrees that the changes in the last ITS amendments (included in taxonomy 2.10.0) require amendments to the answer of Q&A 2753. Therefore, the answer to the Q&A 2753 will be amended.