Validations

We have a question regarding the new business validation rule BV 1181-1 introduced with taxonomy 2.6.0. From our point of view this validation rule contradicts EIOPA Q&A 712 and 776. According to the above EIOPA Q&A, in S.23.02 in R0610 the change in technical provisions should be presented excluding the surplus Fund. However, in the new validation rule, the different valuation of technical provisions between Solvency II and statutory accounts from the balance sheet is used for validation. But the statutory accounts/HGB provisions include the surplus funds. For this reason, this validation rule incorrectly strikes. In our view, the new validation rule would therefore have to be reduced by the value of the surplus fund when checking the difference in the technical provisions in the balance sheet: abs({S.02.01, r0510, c0010} + {S.02.01, r0600,c0010} + {S.02.01, r0690,c0010} - {S.02.01, r0510,c0020} - {S.02.01, r0600,c0020} - {S.02.01, r0690,c0020} - {S.02.01, r0730,c0020}) = abs({S.23.02, r0610,c0110})-abs({S.23.02, r0660,c0110}) Can you please confirm this assumption with regard to the current annual reporting?