Question ID: 3615
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.36.05, SE.01.01
Status: Final
Date of submission: 10 Jul 2026
Question
Will the closed list options in SE.01.01 for S.36.05 be adjusted to include "Not due in accordance with instructions of the template"?
Background of the question
Under Taxonomy v2.10.0 it is now stated that the QRT S.36.05 is no longer due in case the reported elements are already included in other S.36 templates. However, in the QRT SE.01.01, according to the ITS, you cannot use the option Not due in accordance with instructions of the template, which seems to be the more logical option. With the current drop down, one would have to use option Not reported other reason and provide a special justification. This seems a bit strange as there is no special justification to not report, as it simply follows the rules as laid out in the technical standards.
EIOPA answer
As the taxonomy 2.10.0 has been published and the ITS amendments have been submitted to the European Commission for adoption, EIOPA will further look at this topic in the next ITS amendments.