Question ID: 3656
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.06.02, S.06.03
Status: Rejected
Date of submission: 24 Sep 2026
Question
We would appreciate clarification regarding the correct population of currency-related fields in the Solvency II Tripartite Template (TPT). For a fund with a base currency of NOK and a share class denominated in DKK, how should fields 4, 5 and 24 of the FinDatEx TPT be populated? More specifically:
1. Should 4_Portfolio_currency_(B) be NOK, reflecting the base currency of the underlying fund, or DKK, reflecting the currency of the share class? 2. If field 4 is DKK because the TPT is produced for a DKK share class, should 24_Market_valuation_in_portfolio_currency_(B) contain the underlying fund's instrument values converted into DKK, or should the look-through positions remain valued in the fund's base currency (NOK)?
3. How should 5_Net_asset_valuation_of_the_portfolio_or_the_share_class_in_portfolio_currency be populated when the share class currency differs from the fund's base currency? Our main concern is the consistent interpretation of currency (B).
If field 4 contains DKK and field 5 contains the share class NAV in DKK, while field 24 contains the underlying fund's market values in NOK, currency (B) would effectively represent two different currencies within the same TPT. We would therefore appreciate your guidance on the intended treatment when the share class currency differs from the fund's base currency, particularly regarding fields 4, 5 and 24.
Background of the question
Investment funds may offer several share classes denominated in currencies that differ from the base currency of the underlying fund. In such cases, the NAV and share price of a specific share class may be expressed in the share class currency, while the underlying portfolio holdings represent the assets of the fund as a whole and are valued in the fund's base currency. This creates uncertainty in Solvency II look-through reporting as to whether the underlying instrument-level market values should remain in the fund's base currency or be converted into the currency of the relevant share class. Clarification is needed to ensure consistent treatment of NAV, portfolio currency and underlying market values, particularly where the data is subsequently used by insurance undertakings for Solvency II reporting.
EIOPA answer
The question has been rejected as the template referred to in the question is not part of the Solvency II prudential reporting and was not developed by EIOPA. Due to this fact, EIOPA can’t provide clarifications on the purpose and reporting of the template.
EIOPA would like to remind that financial institutions are required to consider whether to address the question in the first place to their competent authority before submitting it to EIOPA.