EIOPA · 2613
Reporting Templates
- Regulation
- (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
- Topic
- Reporting Templates
- Submitted
- 2023-03-22
- Answered
- 2023-06-26
Question
Regards new template S.14.03 for 2.8 taxonomy, and the associated LOG guidance (in the draft business package supporting SII taxonomy 2.8.0). We are confused by a couple of things in this template DPM and the related draft LOG guidance. The General comment indicates how the grouping should be done of different products: "When more than one commercial product is provided for the same Product CategoryIdentification, for same set of LoB and the same set of Risk Coverage, products shall be reported using a single line" But we see a couple of problems with complying with this instruction with the way the S.14.03 is currently structured in 2.8 taxonomy: 1) Main issue being that LoB column (C0050) is an enumerable (not free text) and so a "set" of LoB cannot be declared there i.e. we can't report 1,3,6 with the current taxonomy; it must be 1 or 3 or 6. 2) How should C0040 be completed if different products within the product grouping differ in their "Cyber coverage"? We have one further comment on LOG guidance for columns C0080 through C0140 it mentions for each that they should be the sum of the XXX ""for the reported product Identification"", which I think readers would assume to be C0030. But this is a bit misleading to us because really the aggregation (i.e. what is included in the single line in question in S.14.03) is for the product identification (C0030), line of business (C0050) and Description of risks (C0060) columns. These together make the ""product group code"" (C0010) so we feel it would be clearer for the LOG guidance to refer to ""for the reported product group code"" in the guidance for columns C0080 through C0140 instead.
Answer
As mentioned in the general part of the instructions for this template: “[…]When more than one commercial product is provided for the same Product Identification, for same set of LoB and the same set of Risk Coverage, products shall be reported using a single line, providing a “Product Group Code" defined by the undertaking to identify the group of reported products. Products within the same Product Identification not sharing the mentioned characteristic cannot be aggregated and therefore shall be reported using individual lines.[…]". For these reasons, scenario mentioned in point 1 and 2 should never happen. In both cases, it is expected filer would split the information by the Line of Business and Cyber Risk Coverage and report it in separate rows. For example, Medical Expense insurance (s2c_LB:x135) should be reported in separate product group for Cyber as add-on coverage (main risk being covered) (s2c_PC:x32) and Cyber as add-on coverage (not as main risk being covered) (s2c_PC:x33).
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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