Annex II of Implementing Regulation 2015/2450 states that "gross premiums written shall comprise all amounts due during the financial year in respect of insurance contracts" (cell R0020 S.04.01; C0210 to C0280/R1410 S.05.01; C0220 to C0280/R1410 S.05.02). We would be grateful if you could confirm that only premium written in respect of "insurance contracts" as defined by accounting standards must be reported in S.04.01, S.05.01, and S.05.02. That is, premium received in respect of insurance products classified as investment contracts must not be reported in those templates.
When the instructions of the template refer to "insurance contracts" it should be considered as insurance contracts under Solvency II, i.e. all insurance contracts issued by the undertakings.
This means that regardless of the use of IFRS, if accepted as local GAAP, or local GAAP under which some contracts may be classified as investment contracts, the premiums, claims, and expenses requested in templates S.04.01, S.05.01 and S.05.02 should consider all insurance business.
As this might not be clear from the instructions of the templates, undertakings might have implemented it differently; applying accounting standards that recognise some insurance contracts as investment contracts, and therefore currently not includes these amounts in the referred templates. EIOPA will put forward a corresponding amendment in the next revision of the ITS. In the meantime, undertakings can choose to comply with this interpretation in time for the Q4 and annual 2016 Solvency II submissions., as well as for the subsequent quarterly and annual submissions. Where they are unable to do so, ad-hoc reporting for supervisory purposes can be requested by NSAs where information is required for supervisory purposes.