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While traversing through the templates for the RSR/SFCR-reporting I found a strange template.The S.25.01.21 is the SFCR/RSR reporting template. The counterpart can be considered to be the S.25.01.04 which is used for the regular reporting using XBRL.
Question:•         Is it really right that the C0100 isn’t located below the upper column C0100?•         The rows R0010 – R0100 in C0100 can’t be found on the other reporting templates. This poses the question which data has to be put in.

European Insurance and Occupational Pensions Authority · Accepted Answer

Template S.25.01.21 is the template to be disclosed (not reported) by solo undertakings and template S.25.01.22 is the template to be disclosed (not reported) by groups, as defined in Commission Implementing Regulation (EU) 2015/2452of 2 December 2015 laying down implementing technical standards with regard to the procedures, formats and templates of the solvency and financial condition report in accordance with Directive 2009/138/EC of the European Parliament and of the Council.  
The basis for this templates are in fact the ones to be reported (S.25.01 and S.25.04) but adapted to fulfil disclosure requirements.
In fact the R0130 to R0440/C0100 are to be seen bellow C0110. Please note that the columns codes are only relevant for the link with Annexes II and III with the Instructions of the template. It is not envisaged that the codes of the columns have to be disclosed.
R0010-R0100/C0100 are specific of disclosure. The data to be disclosed is the data as described in Annexes II and III of the ITS.http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R2452…

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