Question ID: 740
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.02.01, S.06.02, S.08.01
Status: Final
Date of submission: 14 Jul 2016
Question
We kindly ask you to clarifiy the expectation with regard to the scope of issues to be presented under R0220 "Assets held for index-linked and unit-linked contracts" of S.02.01.
As of our interpretation this balance sheet item must match with the sum of ...
a) the SII Value as of C0170 in S.06.02 for those assets marked as "1 — Unit–linked or index–linked" in C0090
plus
b) the SII Value as of C0240 in S.08.01 for those assets marked as "1 — Unit–linked or index–linked" in C0080.
In a previous version of the QRTs (as of consultation started 12/2014) there was an accordant validation in place:
DB 37, S.02.01.b.C0010/R0220 = (sum(S.06.02.b.Table1.C0170/R....) IF S.06.02.b.Table1.C0090/R.... = 1) + (S.08.01.b.Table1.C0240/R....) IF S.08.01.b.Table1.C0080/R.... = 1)
Such a validation that clearly defines the scope of S.02.01 - R0220 is no longer defined in the XBRL taxonomy 2.0.1.
Some stakeholders (esp. local authorities) interpretes this as evidence that also other liabilities and other assets related to these products (other than investments, reinsurance recoverables and technical provisions) shall or might be presented in S.02.01 - R0220.
Thus we kindly ask for clarification to avoid differing opinion within the EEA.
EIOPA answer
In fact only the assets referred in the instructions of the template S.06.02 (template should reflect the list of all assets included in the Balance-sheet classifiable as asset categories 0 to 9 of Annex III – Assets Categories of this Regulation) should be reported in S.06.02 even if included in unit linked contracts. Therefore EIOPA does not expect a perfect match between the amount reported in S.02.01 as Assets held in unit linked and the assets listed in S.06.02 (and in S.08.01 if applicable) in relation to this contracts.
See Q&A 169 from file Answers to questions on Guidelines on submission of information to NCAs (Preparatory phase)