As stated in Guideline 22 of EIOPA Guidelines on reporting and public disclosure, “insurance and reinsurance undertakings, excluding participating insurance and reinsurance undertakings, insurance holdings companies and mixed financial holding companies, should provide information on technical provisions”.

Therefore we confirm that Guideline 22 (paragraph 1.36) does not apply to group RSR in any case, also when an insurance or reinsurance undertaking is a participating undertaking. This means that we do not envisage that details of the calculations of technical provisions at group level should be reported.

However, considering that GL22 refers in letter l) to the assessment performed under Article 44 of the Solvency II Directive, we would like to highlight that the requirements under Article 44 (2a) of Solvency II Directive and Article 308 (3)(f) of the Commission Delegated Regulation 2015/35 are applicable at a group level. In fact the ITS on Reporting and Disclosure also includes a template (S.22.01) that is expected to be reported and disclosed at group level.

The information should in our view be limited to the impact of long term guarantees and transitional as requested in Directive and not focus on details of the calculation. GL 29, para. 1.43 b), describes the additional information EIOPA expects to be reported in addition to the template S.22.01.