Question ID: 956
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: 13 Feb 2017
Question
Please could you provide some guidance regarding presentation of non-EEA business in template S.04.01 Activity by country (old K1)?
According to the Log file non-EEA business is only considered in the template when underwritten through non-EEA branches (C0070: “Amount of the business underwritten by all non–EEA branches.” and C0110: “Amount of business underwritten by material non–EEA country branches in the country where it is established.”). Is our understanding correct that business in non-EEA countries underwritten by EEA branches and directly by the undertaking is not included in this QRT?
Based on the above assumption, is it correct to apply the materiality threshold for non-EEA branches (“Material non-EEA shall be reported when needed to report at least 90% of the gross written premiums or if gross written premiums of a non–EEA country are higher than 5% of the total gross written premiums”) to the total gross written premium excluding business in non-EEA countries underwritten by EEA branches and the undertaking?
EIOPA answer
Freedom of Services as defined in the Solvency II Directive can only be performed in a Member State (Article 13 (9)).
Assuming that by "non-EEA business" the stakeholder is referring to business which risks are located in a non-EEA area but were issued by the undertaking or any EEA branch, these amounts should be reported under the columns referring to business issued in the country where the branch or the undertaking are established.