Question ID: 3639
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Status: Rejected
Date of submission: 08 Sep 2026
Question
With the application of taxonomy S2 2.10.0 from 01/01/2027 reference date, a common conception was shared across several actors that annual reports for 31/12/2026, still under S2 2.8.2 HotFix, would allow exemption of reporting for templates deleted under the updated requirements. Namely S.21*, S.29*, S.23.02, S.23.03... We can't find an official source confirming or denying this however, nor any practical or technical guideline on how to proceed in such cases.
Can you confirm the EIOPA stated approach on the matter? If some templates can actually be exempted from report with upcoming 31/12/2026 report, can you detail the list of applicable templates, and the practical approach for undertakings to remove those templates: - Do they need confirmation from their NCA supervisor upfront? - If a template if exempted from report, should we provide value 0 (not reported other reason) for it on Content of Submission, and provide justification? - Would the absence of specific templates alter the result of specific validation rules? If that'd be the case, should justification be provided as well?
EIOPA answer
The question has been rejected as this aspect has been clarified already in the EIOPA proposals on the revised ITS on Reporting.
EIOPA has included a specific provision in the draft legal act of the ITS on reporting, allowing the templates proposed for deletion not to be reported for the 2026 annual reporting exercise. In such cases, the option “Not reported” may be used.
The proposals are contingent upon the adoption by the European Commission.