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European Insurance and Occupational Pensions Authority

2457

Q&A

Question ID: 2457

Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities

Topic: Reporting Templates

Article: Article 35 of SII Directive

Template: S.02.01

Status: Final

Date of submission: 07 Jul 2022

Question

We are an insurance company that will adopt IFRS 17 next year, and we have some questions regarding the implementation. With some reinsurance contracts, parties agree on depositing cash or assets. This generates deposits retained on assumed reinsurance or deposits retained on ceded business. According to IFRS 17.32, 33 and 63, an entity should measure a group of (re)insurance contracts based on the fulfilment cash flows, which comprise inter alia all the future cash flows within the boundary of each contract (listed in IFRS 17.B65). Taking into consideration abovementioned, as part of the respective insurance contracts, cash flows from deposit agreements and changes in cash flows triggered by deposit agreements are within the scope of IFRS 17 and they are related directly to the fulfilment of the contract. As a result, in the statement of financial position, they are in one position, the (re)insurance contract asset or liability. Could you please confirm that for the purposes of S.02.01 (MVBS), column C0020 (statutory accounts): • row R0830 (Deposits from reinsurers) and row R0350 (Deposits to cedants) should be nil as deposits will be a part of assets or liabilities for (re)insurance contracts, i.e. they will be presented in row R0270 (Reinsurance recoverables) or row R0510 (Technical provisions - non-life)/ R0600 (Technical provisions - life (excluding index-linked and unit-linked)) / R0610 (Technical provisions - index-linked and unit-linked), respectively?

Background of the question

IFRS 17.32. On initial recognition, an entity shall measure a group of insurance contracts at the total of: (a) the fulfilment cash flows, which comprise: (i) estimates of future cash flows (paragraphs 33–35); (ii) an adjustment to reflect the time value of money and the financial risks related to the future cash flows, to the extent that the financial risks are not included in the estimates of the future cash flows (paragraph 36); and (iii) a risk adjustment for non-financial risk (paragraph 37). (b) the contractual service margin, measured applying paragraphs 38–39. IFRS 17.33. An entity shall include in the measurement of a group of insurance contracts all the future cash flows within the boundary of each contract in the group (see paragraph 34). Applying paragraph 24, an entity may estimate the future cash flows at a higher level of aggregation and then allocate the resulting fulfilment cash flows to individual groups of contracts. […] IFRS 17.B65 Cash flows within the boundary of an insurance contract are those that relate directly to the fulfilment of the contract, including cash flows for which the entity has discretion over the amount or timing. The cash flows within the boundary include: (a) premiums (including premium adjustments and instalment premiums) from a policyholder and any additional cash flows that result from those premiums. (b) payments to (or on behalf of) a policyholder, including claims that have already been reported but have not yet been paid (ie reported claims), incurred claims for events that have occurred but for which claims have not been reported and all future claims for which the entity has a substantive obligation (see paragraph 34). (c) payments to (or on behalf of) a policyholder that vary depending on returns on underlying items. (d) payments to (or on behalf of) a policyholder resulting from derivatives, for example, options and guarantees embedded in the contract, to the extent that those options and guarantees are not separated from the insurance contract (see paragraph 11(a)). (e) an allocation of insurance acquisition cash flows attributable to the portfolio to which the contract belongs. (f) claim handling costs (ie the costs the entity will incur in investigating, processing and resolving claims under existing insurance contracts, including legal and loss-adjusters’ fees and internal costs of investigating claims and processing claim payments). (g) costs the entity will incur in providing contractual benefits paid in kind. (h) policy administration and maintenance costs, such as costs of premium billing and handling policy changes (for example, conversions and reinstatements). Such costs also include recurring commissions that are expected to be paid to intermediaries if a particular policyholder continues to pay the premiums within the boundary of the insurance contract. (i) transaction-based taxes (such as premium taxes, value added taxes and goods and services taxes) and levies (such as fire service levies and guarantee fund assessments) that arise directly from existing insurance contracts, or that can be attributed to them on a reasonable and consistent basis. (j) payments by the insurer in a fiduciary capacity to meet tax obligations incurred by the policyholder, and related receipts. (k) potential cash inflows from recoveries (such as salvage and subrogation) on future claims covered by existing insurance contracts and, to the extent that they do not qualify for recognition as separate assets, potential cash inflows from recoveries on past claims. (ka) costs the entity will incur: (i) performing investment activity, to the extent the entity performs that activity to enhance benefits from insurance coverage for policyholders. Investment activities enhance benefits from insurance coverage if the entity performs those activities expecting to generate an investment return from which policyholders will benefit if an insured event occurs. (ii) providing investment-return service to policyholders of insurance contracts without direct participation features (see paragraph B119B). (iii) providing investment-related service to policyholders of insurance contracts with direct participation features. (l) an allocation of fixed and variable overheads (such as the costs of accounting, human resources, information technology and support, building depreciation, rent, and maintenance and utilities) directly attributable to fulfilling insurance contracts. Such overheads are allocated to groups of contracts using methods that are systematic and rational, and are consistently applied to all costs that have similar characteristics. (m) any other costs specifically chargeable to the policyholder under the terms of the contract.

EIOPA answer

Deposits whose cash flows are within the fulfilment cash flows are to be included in reinsurance recoverables (R0270 / C0020 in S.02.01) in case of ceded business and in technical provisions (R0510, R0600 or R0690 / C0020 in S.02.01) in case of accepted reinsurance​.