Question ID: 68
Regulation Reference: Guidelines on submission of information to NCAs (Preparatory phase)
Article: 35
Template: S.06.02
Status: Final
Date of submission: 03 Jul 2014
Question
In the last version of the DPM published on the EIOPA website, it appears that the column "ID Code - A5/A4" is considered as the XBRL key for row dynamism of the Template S.06.02.02.02.
If my understanding is correct it means that each XBRL fact of this column must be unique in this template.
In the same time if you read the instruction published in the "Proposal for Guidelines on Submission of Information to National Competent Authorities (CP-13/010)" it seems that for group reporting a same Id code may have two distinct CIC CODE.
In those case, that means that may have two rows of the templates S.06.02.02 sharing the same ID CODE but displaying distinct CIC code. In those case the ID code won't be unique anymore, which can be for me quite troublesome.
=> Please tell me if my understanding is correct?
EIOPA answer
In fact EIOPA is revising the key for row dynamism both in the individual and in the group template. The situation where the key as described would not be unique is not only valid for CIC code but for other items as well. This was corrected in the next DPM/XBRL release (v1.4 release).
However, although this solution for the key for row dynamism, the groups should check and ensure that the CIC code used for the same security from different undertakings is the same in the group reporting.