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We would like to have some clarification regarding the following templates:

Question 1:

S.14.03: Regards the new S.14.03 QRT, for the expected scope, does the QRT concerns all contracts that were in the portfolio for at least one day during the year under review or just the contracts in force at the end of the year?

In the ITS 2023/894 the CIC code no. 87 („Loans to AMSB members“) was added in Annex VI. The definition says: „Loans made to AMSB members. This class shall prevail over the ones above“. Does the definition refer only to the current members of the AMSB or does it refer to the former members of the AMSB as well?

We have a discussion about the realized (C0100) and unrealized (C0110) results for QRT S.09.01 in case of assets acquired during the reporting period. We normally calculate the acquisition value by multiplying the quantity by the price. We do not take into account any purchasing or selling costs. When determining the value at the end of the previous reporting year, you also multiply the quantity by the price. In our opinion this gives you a consistent line of conduct. However, an alternative opinion is that any purchase and selling costs should also be included in the acquisition value and the realized or unrealized result.

For C0060/R0010 Without volatility adjustment and without other transitional measures - Technical Provisions total amount of gross technical provisions without the adjustments should be reported. This suggest that only the amount of the adjustment on the gross technical provisions should be included. However there is also an impact on the amount recoverable from reinsurance. Should this impact amount not also be included since the QRT eventually states the impact on Own funds which will be impacted by both the impact om gross technical provisions and amount recoverable from reinsurance?

There is a mismatch between the risk zone numbers listed in Annex IX of Commission Delegated Regulation (EU) 2015/35 (DR) and the ones used in Annex XXIII DR.
In Annex IX, the risk zones for Romania (RO) are numbered from 1 to 41, while in Annex XXIII the correlation coefficients are provided for risk zones numbered from 01 to 45 but without the numbers 2, 11, 15 and 16. Although the total number of zones is the same for the two annexes (41), the zone numbers are different.

Could you please confirm that the Solvency Capital Requirement (SCR) for investments in (un-listed) loan-financed property shall be calculated as property-risk based on the market-value of the property, rather than the market value of the investment.

“According to DIRECTIVE (EU) 2016/97 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 20 January 2016 on insurance distribution (recast)
Article 2
Definitions

2. For the purposes of paragraph 1, points 1) and 2), none of the following activities shall be considered as insurance or reinsurance distribution:

(b) the management, on a professional basis, of the claims of an insurance or reinsurance undertaking as well as the activities of assessment and settlement of claims;

I have a query regarding the risk classification of medical device software. Is the risk classification for medical device software the same as for other medical devices, or are they considered separate? Your clarification on this matter would be greatly appreciated.

Could you please provide guidance on the Solvency II treatment of the following scenario: An insurance or reinsurance company, possibly a captive, provides a loan to a non-regulated entity within the same group. The loan has a limited term, and its interest rate is determined not only by the duration and credit quality of the borrower but also includes a feature that provides coverage for a defined insurance risk up to a certain limit during the loan term. This is called an Insurance Linked Loan (ILL).The loan's remuneration is variable and consists of three components: 1.The traditional interest components, based on credit quality and duration, 2.