Question ID: 2774
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: Template: S.36.05
Template: S.36.01
Status: Final
Date of submission: 29 Aug 2023
Question
Could you please specify the usage of S.36.05 (IGT - P&L)? (1) We are wondering if any entry within S.36.01 and S.36.02 requires also an entry within S.36.05, even if the interest or dividends are below the reporting threshold for significant transactions. Example: internal loan 100, interest 5, reporting threshold 75 --> entry within S.36.01 and also an entry within S.36.05? (2) If so, could you please explain why such an additional entry is necessary within S.36.05? For our understanding, interest or dividends are already covered with S.36.01 (cell NC0190) and therefore the reporting is duplicated. (3) We are wondering if any entry within S.36.06 (IGT - Off-balance sheet and contingent liabilities) and S.36.07 (IGT - Insurance and Reinsurance) requires also an entry within S.36.05. S.36.06 and S.36.07 are not explicitly mentioned at the instructions for S.36.05.
EIOPA answer
There is indeed an overlap as indicated in the general comments of the template “Although interest, dividends are reported in S.36.01, S.36.02 they have to be reported additionally in S.36.05 P&L.". Note however that S.36.05 does not cover the off-balance sheet items & contingent liabilities nor the insurance/Reinsurance P&L hence there is no duplication on this.