852

I am not sure I fully understand your question. Templates published in ITS should be used as templates for undertakings to include in the SFCR. Undertakings do not need to use the excel files published by EIOPA although we can understand they are used as a basis.   On the changes allowed in the templates for disclosure, the answer is not straightforward. We do expect undertakings to perform formatting arrangements to fit their own purposes, e.g. the number of countries to be reported and size of columns and also we believe that not publishing the columns of LoB for which the undertaking is not authorised e.g. in S.05 or S.17 for example should be possible. However, we believe that Balance sheet should be used exactly as published in the ITS, even if some rows are zero, the same would apply for instance to Own Funds template. It is important to facilitate comparability between companies but adaptations for visual purposes should be allowed.