EIOPA · 2468
Reporting Templates
- Regulation
- (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
- Article
- Article 35 of SII Directive
- Topic
- Reporting Templates
- Submitted
- 2022-07-29
- Answered
- 2023-04-27
Question
We have a an issue with regard to the SCR calculation approach. Currently EIOPA defines this field as being an investment related field. However, this leads to the issue that, in order to have the correct SCR treatment for the same asset that is held in different portfolios (for example, unit linked and non-unit linked), we have to artificially create split ID codes for the same investment that can then each be treated correctly for the SCR calculation. We believe that it makes more sense to make the SCR field position related. This would enable us to avoid having split ID codes for the same investment. Can this definition please be adjusted from being investment related to being position related?
Answer
EIOPA would like to clarify that the proposal for S.06.02 C0292 is not possible under the current legal framework. In addition, it will not help in the example provided (UL – non-UL) as C0090 already requires two different lines with different IDs to be reported. However, EIOPA understands the rationale behind the proposal and will further analyse it in the future ITS amendments.
This Q&A is published by European Insurance and Occupational Pensions Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.
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