Question ID: 3648
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision, (EU) No 2009/138 - Solvency II Directive (Insurance and Reinsurance)
Topic: Reporting Templates
Article: N/A
Template: S.06.02, S.06.03
Status: Final
Date of submission: 17 Sep 2026
Question
We have a question concerning the CIC classification of loans/advances on assets.
Should they be classified according to the nature of the underlying asset?
Or should they fall under a different category?
For example, in the case of deposits with Collective Investment Undertakings, the CIC code to be used should be 4* or 7* since the deposits made with the funds are already with CIU but not totally invested yet?
Because from our understanding of QRT S.06.03, the total amount of the investment is : " Total amount invested by asset category, country and currency through collective investment undertakings.".
Could you confirm the correct approach or direct us to the applicable regulatory reference?
EIOPA answer
In general, reporting entities are expected to apply a consistent, well-reasoned, own assessment when assigning CIC codes, considering the risks and characteristics of the respective asset (see also: Q&A 1548 and 3406 - European Insurance and Occupational Pensions Authority).
The CIC reflects the instrument held by the undertaking, not the underlying asset. Loans and advances granted by the undertaking are therefore reported under CIC category 8 with the subcategory determined by the type of collateral or by the loan being on a policy (86).
Moreover, reporting in S.06.03 requires a look through until the underlying asset category is identified (see also 2043 - European Insurance and Occupational Pensions Authority).
Any direct holding of shares or units in an investment fund or Collective Investment Undertaking (CIU) must be reported under CIC category 4 in template S.06.02, irrespective of whether the CIU has already invested the amounts received.
Amounts not yet invested by the CIU are reported in the look-through under CIC category 7 in template S.06.03.
Amounts paid to a CIU for which shares or units have not yet been issued do not constitute a holding in the CIU and should not be reported under CIC category 4.
As the CIC classification needs to reflect the most representative risk and individual features of an asset, an investment's assigned CIC code may change over its lifecycle if there are changes to its underlying risk profile, structural features, or listing status.