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New 2.8.0 guidance states: "For assets where there is no custodian or when this item is not applicable, “No custodian” shall be reported." However, validation rule BV1213 says that for CIC 71, 75, 8, 9, isNull({t: S.06.02.01.01, c: C0120, z: Z0001}) is expected. Is the validation rule incorrect?

Two questions:

1. The guidance for the new rows R0120 and R0130 is marked as being applicable for all columns (ie C0010-C0100) but we believe there should be a different approach for the "Impact" columns, being columns C0030, C0050,C0070,C0090 and C0100. In fact there are Blocking validations for the C0030, C0050 and C0100 which state that the value for R0120 and R0130 is not based on other rows but is based on other column ins the same row. eg for C0030 R0120 BV60-1 is: S.22.01.01!_C0030_R0120= (S.22.01.01!_C0020_R0120 - S.22.01.01!_C0010_R0120) And this result will not necessarily be the same as "(R0050) divided by the total amount of SCR (R0090) of each column." which the LOG guidance for R0120 indicates.

Is validation rule BV2-1 applicable to all assets? Rule BV2-1 simply says "matches({t: S.06.02.01.02, c: C0390, z: Z0001}, "ISO 8601 'yyyy-mm-dd' pattern ")". There is no "where" or "filter" indicating which asset types are expected to have a maturity date. Therefore assets with no maturity date cause this rule to fail.

In Q&A 2931 EIOPA answers: The implementation of new NACE code requires amendments in the ITS (e.g. whenever there is a reference to specific letter). Therefore, EIOPA will consider in the future ITS amendments. The question is: for NACE rev2.1, when the implementation date and reporting reference data it should be for QRTs. If this is subject to ITS amendment, can you advise (1) when will you amend the ITS (2) does it mean NACE rev2.1 is not required if ITS is not amended?

It was found that the changes in NACE codes (Rev 2.1) which is said to take effect from 1st January 2025, was not adopted in Solvency II taxonomy 2.8.2. When is it planned to be adopted by EIOPA?

Further clarification is needed on the business validation 1597, introduced with Taxonomy 2.8.0. BV1597 expresses the following: In S.23.02, R0100/C0010 (Total ordinary share capital) = R0010/C0010 (Paid in ordinary share capital) + R0020/C0010 (Called up but not yet paid in ordinary share capital)+ R0030/C0010 (Own shares held) However, according to the instruction, in S.23.02 R0010 should be represented gross of own shares. This validation rule would therefore imply a double count of own shares in R0100. Further, EIOPA indicated in Q&A 777 that “The information on own shares is not considered in the Total as it is already included in the amount of paid in share capital.

Regarding Control TV1002_1: New mandatory validation. The control compares fields C0131 (nominal) with field C0370 (currency). As the check is made between an amount and a text string, we do not understand what causes the validation error The validation at Eiopa looks as follows: localName(unit({t: S.08.01.01.01, c: C0131, z: Z0001})) = localName({t: S.08.01.01.02, c: C0370, z: Z0001})

S.04.04.01.01 is reported by underwriting entity as specified in S.04.03. Validation rules between S.04.04.01.01 and S.05.01.01.01 is not able to capture the input reported for other underwriting entities than the head office in validation. Example BV1875; “Fire and other damage to property insurance"" reported in template S.04.04 - Activity by country - location of underwriting should be equal to the total GWP written in the S.05.01 - Premiums, claims and expenses by line of business for

The assertion s2md_BV1015-5 seems incorrect, it checks The item "Maturity date" in S.06.02 - List of assets should not be reported for assets with CIC codes different from CIC '##1#', '##2#', '##5#', '##6#', '##74', '##79' or '##8#'.but in the rule we have filter : <gFilter test="matches(.,&quot;^..((1.)|(2.)|(5.)|(6.)|(74)|(79)|(8.))$&quot;)" cover="true" complement="true" />it should be not match as in 2.7 as this : <gFilter test="not(matches(. ,&quot;^..((1.)|(2.)|(5.)|(6.)|(74)|(79)|(8.))$&quot;))" />