Question ID: 6435
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.04.01
Status: Final
Date of submission: 01 Dec 2016
Question
Can you please advise where we should include the Reinsurance accepted business in the QRT – S.04.01. The log file states that the information should include direct business and accepted reinsurance business (presented gross). However the form only includes categories for business underwritten by the undertaking and the EEA and non- EEA branches. Our reinsurance business is fronted business (majority of fronters situated outside the EEA) and is a significant portion of our business. If you can share some advise on the matter as to which column ref i.e. C0010- C0110) this should be included in ,we would be very grateful.
EIOPA answer
If the reinsurance business is performed by any material non-EEA country branches please reported the amounts in S.04.01.C0110. If the reinsurance business is issued by subsidiaries, please note that the template is only applicable at individual level and should not be reported at group level.
EIOPA clarifies, that business underwritten (direct business and accepted reinsurance) by the undertaking, by any of its EEA branches or by a non-EEA branch from outside EEA is considered cross-border business and has to be included in S.04.01. “Activity by country":
- Business underwritten (direct and accepted reinsurance) by non-EEA branches is to be reported in C0070 and, where country is material, in C0110 by country.
- Business underwritten (direct business and accepted reinsurance) from outside the EEA by the undertaking (and not by a branch) is to be reported in C0010.
- Business underwritten (direct business and accepted reinsurance) outside the EEA by an EEA branch, is to be reported in C0040 and, for the country where the branch is established, in C0080.
This approach is based on the understanding that business from a non-EEA country should be considered as cross-border however when performed by the undertaking or any of the EEA branch it is not considered as Freedom of Services and as such should be reported as business from the undertaking/EEA branch.