In the QRT S.06.02 List of Assets for field "C0230 Issuer sector" we have to fill in the NACE code. Log EIOPA states: "for NACE sections A to N full four-digit reporting of the NACE codes is required, i.e. the letter identifying the Section followed by the 4 digits code for the class shall be used (e.g. ‘K6411’). For the remaining sections the letter reference of the NACE code identifying the Section shall be used as a minimum for identifying sectors (e.g. ‘P’ or ‘P8501’ would be acceptable)". Unfortunately, we note that for some positions NACE sections A to N have the letter + 2 digits and not 4 digits as required. We use an official provider (Bloomberg) for this data. We would like to know if these codes are correct for Eiopa, otherwise how can we properly populate this field?

The current regulation is requesting KID document to be written in the official language of the country where investment product is being offered. Is there a way for customer to overcome this rule by proving in any way that he is able to understand KID language?

Should a financial conglomerate decide the reporting unit (R03)?

How to report public sector and financial sector concentration in template (template FC07-00)?

Considering the definition of intragroup transactions provided in article 2(18) of Directive 2002/87/EC, we would like to confirm whether transactions between non-regulated entities of the financial conglomerate shall be reported.

Annex II to the Final Draft Report briefly mentions the “waterfall” example: A invests in B (e.g. purchases shares), B in C and C in D, where B and C are unregulated units of the conglomerate. This transaction shall be taken into account as specified. => In my view, A would not have to report a transaction (since investment does not meet a liability, see above), B and C would not have to act as they are not supervised, only D would have to report, as a supervised entity and through the sale of shares, funds flow, namely transaction A => D. Is this view correct?

In the draft ITS on the reporting of intra-group transactions and risk concentration, in the section “Current requirements as regards the reporting of information on risk concentration” (starting on page 9) it is proposed to report also the indirect exposures of a credit institution or investment firm belonging to a financial conglomerate (page 11). Here, indirect exposures are defined by the application of the substitution approach in Article 403 of Regulation (EU) No 575/2013, i.e. under the regulation for credit institutions and investment firms. Question: Do exposures of insurance companies belonging to a financial conglomerate therefore not fall under this new reporting requirement?

For the purpose of completing the reporting of significant risk concentration under Commission Implementing Regulation (EU) 2022/2454:

Question A: for the completion of templates FC.07 and FC.08 related to concentration, how should non-significant concentration be considered?

For the completion of template “FC.06 Risk Concentration - Exposure by counterparties”, could you clarify which methodology shall be used for determining the value of exposure to be reported, in particular for repo / reverse repo and derivatives?