EIOPA Q&A Updates
Please see below for EIOPA’s response to recent queries which have been raised by the public for further clarification on the Solvency II requirements. The Solvency II requirements may change or become more prescriptive over time.
07 March: S.06.02
EIOPA clarified in Q&A (#2719) that with regards to contract that cover risks in several member states, the European Commission declared that: “In the event that a single insurance contract covers risks/commitments belonging to a policy-holder's subsidiaries or branches, the location of the various risks/commitments covered by this contract must be determined on an individual basis for each risk/commitment”
07 March: Articles 76, 77 and 77e of SII Directive; 37, 38 of DR
EIOPA clarified in Q&A (#2899) that when calculating technical provisions insurance undertakings shall use that technical information which was adopted by the Commission in accordance with Article 77e (2).
07 March: Articles 13(14) and 147
EIOPA clarified in Q&A (#2939) that in the case of a policyholder moving residence to another member state after the insurance contract has concluded, Solvency II does not define the date on which the habitual residence of the policyholder must be determined.
13 March: Article 55
EIOPA clarified in Q&A (#3180) that non-life inwards reinsurance should be classified under LoBs 13-24. Outward reinsurance should not lead to Technical Provisions and instead should be recognised as reinsurance recoverables.
13 March: S.06.02, S.11.01
EIOPA clarified in Q&A (#3235) that NACE ‘Other’ should not be assigned for QRT S.06.02, S.11.01 and S.37.01.
13 March: S.06.03
EIOPA clarified in Q&A (#3224) that in the instructions of S.06.03 the reference to CIC 8 and 9 should also include CIC 7.
13 March: S.04.04, S.04.05:
EIOPA provided in Q&A (#3164) two examples to clarify the expected reporting in S.04.04 and S.04.05:
13 March: Reinsurance
EIOPA clarified in Q&A (#3162) that outwards reinsurance should be classified according to the nature of the risk transferred from the underlying contracts being reinsured. Therefore, an outward reinsurance policy providing coverage for an inward life reinsurance policy should be considered as a life reinsurance policy.
13 March: S.06.02
EIOPA clarified in Q&A (#3196) that the external rating scale used for short-term deposits in local currency should reflect the long-term rating of the counterpart.
13 March: Article 227
EIOPA clarified in Q&A (#3071) that the provisional equivalence of the Japanese supervisory system will expire on 31 December 2025 unless the European Commission will consider to take a decision on the renewal of provisional equivalence under Article 227 of Solvency II before end 2025.
21 March: Articles 3(22) - DORA
EIOPA clarified in Q&A (#2959) that DORA does not define ‘function’ to enable flexibility for the financial entities (FEs) to identify their functions in accordance with their operational and organisational framework.
21 March: Articles 6(1) - DORA
EIOPA clarified in Q&A (#2990) that if a parent undertaking is not a financial entity, the obligation to keep registers of information does not apply to the parent undertaking at individual level.
21 March: DORA
EIOPA clarified in Q&A (#3076) the following with regard the meaning of ‘linked’ in field B_06.01.0020 of DORA: “Each function reported in B_06.01.0010 shall be ‘linked’ to a ‘licenced activity’ listed in annex II. In case the function could not be linked to a licenced activity ‘support function’ shall be reported in B_06.01.0020 instead of the ‘licenced activity’.”
21 March: Articles 2(1)
EIOPA clarified in Q&A (#3168) the extent to which insurance comparison websites fall under ‘insurance distribution’ (IDD).
24 March: S.14.02 & S.17.03
EIOPA clarified in Q&A (#2670) the following with regard to the template:
- For scenarios where the Line of Business consists entirely of one Product category, only the row of the specific product category should be reported in S.14.02.
- If the Home Country represents a small part (i.e. less than 10%) of the written premiums for a given LoB, the premium should be reported together with other non-material countries.
- If product category encompasses an entire Line of Business, only one row should be reported for this LoB.
