Question ID: 782
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 Sep 2016
Question
When the latest log files were released at the end of last year, the definition of the row R0040 "Commissions" in the QRT S.04.01 was changed to match the definition of the row R2210 "Acquisition expenses - Gross" in the QRT S.05.01. However the row R0040 in the QRT S.04.01 is still called "Commissions".
Will this description be updated to "Acquisition expenses" on the QRT S.04.01 to avoid any confusion?
In relation with the definition change of the row R0040 in the QRT S.04.01, the equivalent "Acquisition expenses" row R2210 for Life insurance entities in the QRT S.05.01 does not include the three words "including renewal expenses". Our interpretation from a life point of view is that we should follow the equivalent definition provided in the QRT S.05.01 for the Life insurance entities (row R2210 ).
Would you be able to confirm that our approach is correct?
EIOPA answer
Please see Q414 from file Answers to questions on the Final report on the ITS on the templates for the submission of information to the supervisory authorities (CP-14-052).
The intention is actually to have the same item reported even if in S.04.01 is called “Commissions” and in S.05.01 is called “Acquisition expenses”.
However, the templates and instructions were published in the Technical Standard and EIOPA will not amend the labels for the moment.
Regarding the difference between life and non-life it was not intentional, acquisition expenses should include renewal expenses in both cases, except in the following situation: if Member States requires a different treatment according to article 40 of that Directive 91/674. As both templates S.04.01 and S.05.01 follow the accounting valuation, for the undertakings from Member States where the option was used, the local GAAP should be followed.