Technical Provisions (TPs), Reporting Templates

Should future benefits of unit-linked products be reported as Future guaranteed benefits (C0051) or Future discretionary benefits (C0055) in S.13.01.01.01?

In SII taxonomy 2.8.0 future benefits were divided into two groups - guaranteed and discretionary. We have noticed different praxis in reporting these cash-flows for unit-linked products. On one hand, the benefits of the unit-linked products are usually not guaranteed and depend on the market development. Then it would be natural to report them as non-guaranteed, which means in the column for future discretionary benefits. On the other hand, according to the whereas (17) in SII delegated regulation, "the definition of future discretionary benefits should capture the benefits of insurance and reinsurance contracts that are paid in addition to guaranteed benefits and that result from profit participation by the policy holder. It should not capture index-linked or unit-linked benefits." Unit-linked benefits are defined in number of units, they don't have the same nature as discretionary bonuses in products with guarantees. Besides, unit-linked benefits shouldn't be included in calculation of Net future discretionary benefits (R0460) in S.25.01.01.02.