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We would like to follow up on the EIOPA response provided on 26/3/24 for Question ID 2953 where EIOPA stated that: "Please note that there seems to be a mistake and the BE triangles are to be reported including (and not excluding) any expenses. This will be clarified in the next ITS amendments. (The instructions should actually read “net of salvage and subrogation and including any expenses")." We have looked at the latest ITS amendments - ITS (EU) 2023/894 issued 4/4/23 - which still refers to "excluding expenses". Can we please clarify whether the BE triangles should be reported including/excluding 1) any expenses; 2) future premiums for FY25?

We would like to raise a concern regarding the header of table S.27.01.01.19, which currently reads: "Man-made catastrophe risk – Other non-life catastrophe risk." Upon review, we believe this wording is not aligned with Article 119 of the Commission Delegated Regulation (EU) 2015/35. According to the regulation, "Other non-life catastrophe risk" is a sub-module of "Non-life catastrophe risk", not of "Man-made catastrophe risk". In light of this, we kindly request that you review both the header of table S.27.01.01.19 and its corresponding description in the Implementing Technical Standards (ITS) to ensure consistency with the regulatory framework.

In QRT S.08.01, swap inflow and outflow amounts have to be reported in C0200 and S0210. It is stated: "Amount received/delivered under the swap contract (other than premiums), during the reporting period." What exactly is meant with reporting period? For example: We report Q2 figures; are these amounts meant to be "year-to-date" (01.01. until 30.06.) or only for Q2 (01.04 until 30.06.)?

Assume a life insurance undertaking holds a bank overdraft of 1m (in reporting currency), which is solely attributable to unit-linked contracts. Following EIOPA Q&A ID 183, the overdraft should contribute negatively to Assets held for index-linked and unit-linked contracts (R0220) in the Solvency II balance sheet (template S.02.01). Is it correct that this same overdraft must also be reported in the List of assets (template S.06.02) with a total Solvency II amount (C0170) of –1m, even though this treatment appears to breach the automated validation rules starting with BV733 under Taxonomy 2.8.2, which do not accept negative asset values? Could you please clarify whether: 1. Negative Solvency II amounts are permissible in S.06.02 for bank overdrafts linked to index-linked or unit-linked business; or 2. An alternative reporting approach should be applied to satisfy both Q&A 183 and the validation rules?

a)The ESMA Guidelines has brought a general change in the rules to calculate performance fees. On the subject of performance fee calculation, PRIIPS RTS prescribes that where a full performance fees history is not available because the fund/share class is new or the fund's terms have changed due...

Regarding the performance scenarios shown in an investment product's KID for a product with SRI 1: - Can the performance scenarios somewhat be considered commensurate with the "reality"? That a given scenario is in reasonable proportion to the resulting amount? - For example, is the actual outcome of SEK 0 after one month realistic or possible when the stress scenario that can be said to have occurred states that an investment of SEK 100,000, according to the information in KID, yields SEK 2.5 million after one month? - Finally, is it at all possible that a the stress scenario for a procuct with SRI 1 as in my example shows such a high positive result? 

On template S.17.01 specifying information on non-life technical provisions for each line of business, instruction in ITS 2023/894 doesn't stated the sign expected on the flows submitted for lines R0370 to R0440 related to Cash-flows of the Best estimate of Premium or claims Provisions (Gross). What is the correct approach ?

Please can you advise how P&L generated from (1) Repo and (2) Reverse Repo should be reported in S.09.01, assuming the Repo and Reverse Repo both counterpart is ECB.

Point 16 of Annex IV contains a comprehensive catalogue of criteria for the appropriateness of benchmarks or proxies when they are used to calculate the performance scenarios. There is no corresponding catalogue for the appropriateness of benchmarks or proxies used to calculate the MRM (see point 7 of Annex II, Part 1). Does this mean that benchmarks and proxies used to calculate the MRM are subject to different (lower) appropriateness requirements?