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For the assessment of the Solvency Capital Requirement (SCR) using a partial internal model, is it permissible for a solo insurance entity and for an insurance group to model underwriting risks through the partial internal model, while simultaneously applying the standard formula equity shock of 22% for long-term equity investments, provided that all the conditions set out in Article 171a of the Commission Delegated Regulation (EU) 2015/35 of 10 October 2014 are fulfilled?

We were approached by representatives of the major ISPs in AT. They expressed concern about divulging their sub-contractors, as the information is currently not public and could be actionable by potential attackers. Should these sub-contractors indeed be disclosed by the ISPs to a large number of financial undertakings?

Does EIOPA have, and can it make available, an electronic version of the register of information, the content and template of which are set out in the draft commision implementing standard laying down implementing technical standards with regard to standard templates for the register of information according to Regulation (EU) 2022/2554 of the European Parliament and of the Council?

We understand that in Template 27.01.b. (Man made catastrophe risk - Liability) the “Earned premium last 12 months” should be considered, is this correct?

The first question is: Does the exception in Article 24(3), second subparagraph, apply to travel insurance sold together with a credit card? A credit card is not a payment account as defined in Article 2(3) of Directive 2014/92/EU, but a credit card typically is linked to an underlying payment account. Is the sale of travel insurance together with a credit card therefore covered by the ex-ception, or does the requirement to offer the insurance separately apply? The second question is: Depending on the answer to the first question, to what extent is a de-mand and needs assessment required under Article 20 of the IDD when travel insurance is sold as an inseparable part of a credit card package? We would appreciate EIOPA’s clarification on the application of these provisions in the context described.

What is the intended difference in information and insight for Direct Business for QRT S.04.04 vs S.04.05?

In relation to columns C0110 and C0120, you refer to claims that "have been settled with payment during the reporting year". Should the claims, on which the payment occured during the year, but they are for some reason still OPEN at the year-end (thus they are not fully settled) be also included or not?

Question 2433 clarifies that the non-life lapse risk shall be based on "policies for which discontinuance would result in an increase of technical provisions" (directive text) "before the payments caused by the discontinuance are made" (Q&A clarification). With this clarification, discontinuance of any profitable contract will result in a (short term) increase in the provisions and are thus within scope of the Lapse risk calculation.

We have a question regarding S.37.01 Cell C0320 – Exemptions (included in the Implementing Regulation 2023/894), where we seek clarification of what information is asked for specifically. The cell C0320 makes reference to Article 187 in the delegated regulation, and in its reporting events, EIOPA has also referred to the banking regulation (Article 400 in the Regulation (EU) No 575/2013); We understand this is because both articles/legislations are referred to in the FICOD reporting requirements (Implementing Regulation 2022/2454, template FC.06, cell FC0270).