EIOPA · 2547
Reporting Templates
- Regulation
- (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
- Article
- 35 of SII Directive
- Topic
- Reporting Templates
- Submitted
- 2022-12-20
- Answered
- 2023-04-27
Question
I have a question regarding the new Logfiles Solvency II reporting (2.8.0.) that come into force Q4 2023. The threshold in template S.30 doesn't seem to be right. It doesn't make sense to have a threshold on the reinsurance program for year (t+1), especially because the threshold is linked to the percentage recoverable of the past programs. The result will be that almost no insurer will report their Cat-program, as there is seldom a recoverable.
The intention of this threshold was, in our opinion, to limit the reporting of existing recoverables that are relatively small for the insurer. Therefore this threshold should be addressed to S.31 in stead of S.30.
Do you agree with this analysis and can this be changed / corrected?
Background
We received a question from an insurer about this threshold and discovered the possible mistake.
Answer
EIOPA understands the concerns raised in the comment, but unfortunately the comment arrived after the end of the public consultation, and at this stage no changes are possible. Nevertheless, this will be discussed in the next 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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