Validations

In C0340 of S.06.02, the credit quality step assigned to the asset according to Article 109a (1) of Directive 2009/138/EC, is allocated. If the asset does not have an external issue rating, the issuer rating is used here for the calculation of the CQS (i.e. it is derived from Pillar I). Conversely, this means according to our current interpretation that even if no rating is reported in field C0320 (i.e. field C0320 remains empty for all CIC 1,2,5,6 and 8) a CQS is reported in field C0340, applying the Implementing Regulation EU 2016/1800 of 11.10.2016. This is because, in our view, the CQS in field C0340 has to be reported independently of a disclosure of an external rating in field C0320, as the derivation is from Pillar I and therefore the issuer rating may be relied upon. Here, we refer to Q&A 2154 and to the log files. EIOPA response to Q&A 2154: C0340 should include the CQS attributed to the asset, regardless whether it was derived from the rating of the asset or from the rating of the issuer. When deriving the CQS from an external rating, Art. 5(2) of the Commission Delegated Regulation (EU) 2015/35 has to be considered. BV1196 from the new taxonomy 2.6.0 now requires as a blocking validation that C0340 is only to be reported if C0320 Empty. Thereafter, if C0320 is empty, the value “9-no rating available” must always be used in field C0340. This means that the field content C0340 is now dependent on C0320 and from our point of view would no longer comply with the specifications from Q&A 2154 and the log file for S.06.02. We therefore kindly ask you to review the validation BV1196 of the taxonomy 2.6.0 or to clarify our concern.

Our national supervisory authority has so far confirmed our point of view.