Question ID: 920
Regulation Reference: (EU) No 2015/2452 - procedures, formats and templates of the solvency and financial condition report
Article: 51
Status: Final
Date of submission: 06 Dec 2016
Question
We have some doubts regarding public templates.
It seems that some of them contain additional information or have a slightly different structure in respect to the annual version to be reported to regulator (see some comments in field below). We would like do double check whether this was intended and if not how to behave in this case.
EIOPA answer
The templates to be disclosed in the SCFR are mostly based on the reporting templates but not completely.
The differences are intentional and aim to fulfil specific disclosure requirements (or constrains).
Specifically:
- S.19.01 is reported by LoB but should be disclosed for the entire Non-life business (with split only for accident/underwriting year)
- S.25.01 and S.25.02 have additional columns addressing USP and simplifications to comply with specific disclosure requirements (in reporting templates information is also requested but in a different approach, e.g. S.26.07 for simplifications)
The fact that "Gross SCR" has a different column in both templates might be seen as an inconsistency but as taxonomy does not cover the disclosure templates it is not seen as a problem that needs urgent solution. In a future revision this will be considered.