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It seems that the rules EV75-2 and EV52- are incompatible:EV75-2: Issuer sector according to ESA 2010 should be reported for non-ISIN securities only.--> BUSINESS(en) - [EV75-2];[isNull((t: SE.06.02.16.02, c: EC0231, z: Z0001, filter: matches([s2c_dim:UI], "^((ISIN/.*)|(CAU/ISIN/.*))")) reported as {$v1})]|This states that the Issuer sector is not required if the asset identification is an official ISIN (no mention of CIC).EV52-2: The item Issuer sector according ESA 2010 must be reported.--> BUSINESS(en) - [EV52-2];[(not(matches(dim((t: SE.06.02.16.02, c: C0290, z: Z0001) reported as {$v2},[s2c_dim:UI]), "^(ISIN/.*)|(CAU/ISIN/.*)")) and matches((t: SE.06.02.16.02, c: C0290, z: Z0001) reported as {$v2}, "^..((1)|(2)|(3)|(5)|(6)).$")) or matches((t: SE.06.02.16.02, c: C0290, z: Z0001) reported as {$v2}, "^..8.$")];[not(isNull((t: SE.06.02.16.02, c: EC0231, z: Z0001) reported as {$v1}))]|According to the above, the Issuer sector must always be provided if the CIC is ##8#, independent on whether it is an official ISIN or not.You cannot fulfil both rules in case the CIC is of type ##8# and the identification of the CIC is an official ISIN.

European Insurance and Occupational Pensions Authority · Accepted Answer

The EV52 (implemented with error severity) expects column C0231 to be reported for non-ISIN assets assigned to categories (CIC) 1, 2, 3, 5, or 6. For assets with CIC 8, column C0231 is expected to be reported regardless of whether an ISIN is assigned, as mortgages and loans are not typically expected to have ISIN codes. On the other hand, EV75 (warning severity) checks that column C0231 is not reported for assets with an ISIN provided. Therefore, it is a correct assumption that this validation will fail for rows with CIC 8 and a reported ISIN.According to the instructions provided by the ECB on SE.06.02, the issuer sector: “shall be reported for CIC category 8 and for categories 1, 2, 3, 5, and 6 if the instrument does not have an international securities identification number (ISIN).” Therefore, it is correct to follow EV52, as this validation directly reflects the ECB’s intention (which is also the reason for its higher severity level). EV75 will be monitored for further feedback, although no deactivation of this rule is planned at this stage.

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