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.
31 January: QRT S.37.02
EIOPA clarified in Q&A (#3003) the following:
- Template S37.02.04.03 should capture the exposure by country and should therefore be reported irrespectively of S.06.
- 37.02 should include all type of exposures and is therefore not limited to information provided in S.06.02.
- Look-through for collective investment schemes is applicable on a best effort basis.
31 January: QRT S.23.01
EIOPA clarified in Q&A (#2903) the following with regard to new rows in the QRT:
- R0800 should equal sum of R0560 and R0440, for columns C0010 through C0050 respectively
- R0810 should equal sum of R0560 and R0460, for columns C0010 through C0050 respectively
- Quantitative tiering limits don’t apply to R0440.
31 January: QRT S.09.01 & S.20.02
EIOPA provided in Q&A (#3198) context on the Validation Rules between QRTs S.09.01.01 and S.29.02.01.
31 January: QRT S.05.01
EIOPA clarified in Q&A (#3151) that instructions for written/earned premiums in ITS 2023/894 applies to those from proportional reinsurance accepted. These should be reported in a separate line.
31 January: Article 9 and 192(6) of DR (EU) 2015/35
EIOPA clarified in Q&A (#2537) reporting requirements for a reinsurance contract that includes a pay as paid clause.
31 January: S.03.01
EIOPA clarified in Q&A (#2896) that S.03.01 should only include off-balance sheet items, with the only exception of material contingent liabilities, which in Solvency II shall be recognised in the Balance Sheet according to Article 11 of the Delegated Regulation 2015/35 and should also be reported in S.03.01.
31 January: S.12.01 & S.13.01
EIOPA clarified in Q&A (#3128) the following:
- Future Guaranteed Benefits (FGB) in S.12.01 (and S.13.01) should include all future benefits that do not meet the definition of Future Discretionary Benefits (FDB) in article 1(35) of the Delegated Regulation 2015/35. Therefore, benefits from pure Index-linked and unit-linked (UL/IL) should be reported as FGB.
- FDB has the same meaning across all reporting templates, including S.12.01 and S.13.01, and it is the definition in Article 1(35) of the Delegated Regulation 2015/35.
- In S.12.01, “Future guaranteed and discretionary benefits" should include all future benefits.
31 January: QRT S.23.01 & S.23.04
EIOPA clarified in Q&A (#3143) that the new field ‘Non-available own funds in the reconciliation reserve’ should be considered as own funds such as those of related undertakings according to Article 335 (1)(d) and (f) of Delegated Regulation (EU) 2015/35 as indicated in S.23.01. There could also be other non-available own funds items, for example national specific own fund items identified by an NCA within the Reconciliation reserve.
22 January: Article 3(21)
EIOPA clarified in Q&A (#2999) based on the definition of DORA Article 3(21), what types of services should be considered ICT services.
22 January: Article 2(1)(o)
EIOPA clarified in Q&A (#3074) that ancillary insurance intermediaries are within the scope of DORA.
22 January: Article 3(60-64)
EIOPA clarified in Q&A (#3100) that guidance on the calculation of meeting 250FTE criterium can be found in the EC Recommendation 2003/361/EC, with regards to being in scope of DORA.
17 January: QRT S.14.02
EIOPA clarified in Q&A (#3001) that within the QRT, rows 12.1 and 12.2 together make up the total of Line of Business (“LoB”) 12, therefore the row total of LoB 12 should not be reported.
17 January: QRT S.14.02
EIOPA clarified in Q&A (#2952) that in LOB 4 and 5, what should be reported in C0140 are the insured properties, which also include vehicles.
17 January: QRT S.14.02
EIOPA clarified in Q&A (#2974) that where a contract covers fully or partially natural catastrophe, it should fully be reported in LoB 7.1, and not repeated in LoB 7.
17 January: QRT S.05.01 & S.26.06
EIOPA clarified in Q&A (#3192) that any reconciliation between S.05.01 and S.26.06 will not be straightforward. This is due to S.05.01 is provided from a local GAAP accounting perspective (usually IFRS). On the other hand, the S.26.06 is Solvency II valuation based.
17 January: QRT S.05.01
EIOPA clarified in Q&A (#3183) that in S.05.01, C0300/R2600 shall be reported all expenses considered within the technical result.
17 January: QRT S.14.01
EIOPA clarified in Q&A (#2658) that when a contract has a guaranteed rate C0260, C0261 and C0280 should be populated. Conversely, when a contract does not have any guaranteed rate, these fields should remain empty. EIOPA also outlined that if a contract includes applicable surrender options at the reporting date, C0200 and C0270 should be populated. Otherwise, these fields should remain empty.
17 January: QRT S.14.02 & S.14.03
EIOPA clarified in Q&A (#2913) that with regard to template S.14.03, the template should be subject to the application of a threshold based on the following:
- The sum of premiums earned for standalone cyber policies and policies with cyber as add-on coverage (where only the (estimated) premiums earned for cyber risk should be taken into account) is greater than 5 % of the overall non-life business pursued by the undertaking or greater than 5 million EUR.
OR
- Number of policies that include cyber coverage (i.e., standalone cyber and/or cyber ad add-on policy) represent more than 3 % of the total number of policies of the non-life business). Provided that those conditions are met, all contracts underwritten during the year should be reported.
EIOPA also stated within S.14.03, field C0090, C0120 and C0140 should be gross amounts. C0110 and C0130 should be reported on an actual claim count basis and not as a proportion after reinsurance.
With regards to S.14.02, EIOPA clarified that the gross written stemming from contracts sold via brokers should be included in C0090.
17 January: Annex VI
EIOPA clarified in Q&A (#3194) that the CIC code no. 87 (“Loans to AMSB members“) refers only to the current members of the AMSB, and not former members.
17 January: QRT S.09.01
EIOPA clarified in Q&A (#3049) that C0100 (Realised gains/losses from the sale or maturity of an asset) is calculated as the difference between the selling/maturity value and the value according to Article 75 of Directive 2009/138/EC at the end of the prior reporting year (or, in case of assets acquired during the reporting period, the acquisition value).
EIOPA also clarified that for C0110 (Unrealised gains from an asset not being sold or maturing) is the difference between the value at the current reporting date and the prior reporting date (or the acquisition value if the asset was acquired during the reporting year). Values at these reporting dates should be calculated according to Article 75 of Directive 2009/138/EC.
17 January: QRT S.22.01
EIOPA clarified in Q&A (#3007) that this template requires reporting in gross amounts. Requirements to report in gross amounts can be found in Annex II of the ITS 894/2023.
