Technical Provisions (TPs), Solvency Capital Requirement (SCR)

The updated official Journal of the European Union (log reference C0010–C0020 / R0360) in 2023 states instructions for Insurance and intermediaries receivables amounts for payment by policyholders, insurers and other linked to insurance business that are not included in technical provisions. We note that the wording has changed from previous where a distinction between past-due and not past due is no longer made. We have received professional advice from another party suggesting that this should be interpreted as change to the classification of future premiums within the best estimate where due premium should relate to the date an invoice was issued rather than when the premium is due to be paid or received. This suggestion would mean that a much higher proportion of future premiums would sit in the premium receivables on the balance sheet relative to the previous wording. With the above in mind, can you confirm whether the latest wording should be interpreted as a change in the classification of future premium within the best estimate. As an example, in an instance where a premium invoice had been issued prior to the valuation date but where the premium payment was due to be received after the valuation date, should this now be classified as a premium receivable on the balance sheet or remain as a future premium cashflow in the best estimate?

We have received professional advice from another party suggesting that this should be interpreted as change to the classification of future premiums within the best estimate where due premium should relate to the date an invoice was issued rather than when the premium is due to be paid or received. This is broadly a repeat of question 3365 with clarification that it was the challenge from the external provider was due to updates of the official Journal of the European Union (log reference C0010–C0020 / R0360) in 2023 rather than Guideline 68.