The classificator of template S.14.01 shows the following 5 elements with the instruction above.

C0100    Product classification    The following close list shall be used:
  1 - single life
  2 - joint life
  3 - collective  
  4 - pension entitlements
  5 - other

If more than one characteristic is applicable use “5 – other”.
For annuities stemming from non-life use “5 – other”.

The Austrian Insurance Association (VVO) had asked EIOPA on this issue whether “pension entitlement” is meant to be the actual status of the contract or the original one at signature. The EIOPA answer said the actual one should be used.

In the meanwhile EIOPA changed the instruction in the “July-Version” of the LOG-Files adding the line “If more than one characteristic is applicable use “5 – other””. This instruction creates the problem, that all “pension entitlements” will be empty (0). The reason for this is, you classify a contract as 1,2 or 3 without “pension entitlement” or as 1,2 or 3 with “pensions entitlement”. In the latter case the instruction bites and you have more than one characteristic and the contract is classified as “5 – other”. In our view, this goes against the intention of gathering information of “pension entitlements”.

Our National Bank and the Statistical Office from Austria are sharing our concern.

We think there should be an instruction which is unambiguous and clear how to be used. A contract is either 1 or 2 or 3. Number 4 is not an “or” anymore but an “and”.

We would be very much interested to get as a result the “pensions entitlements” hold by the Austrian insurers.