The implementation guidance and EIOPA Q&A appear to categorise gross outstanding claims and the subsequent reinsurance reimbursement differently on template S.02.01. EIOPA Q&A 2582 states that claims past their due date should be recognised as insurance payables while the implementation guidance states that claims not yet paid, but expected to be reimbursed, should be recognised in reinsurance recoverable. The means that the gross outstanding claim sits outside of technical provisions but the expected reimbursement sits within the SII equivalent of reinsurers share of technical provisions. Can EIOPA confirm whether this interpretation of the rules is correct and intended.

The instructions (“implementation guidance") set out in Commission Implementing Regulation (EU) 2023/894 in relation to the completion of cells C0010– C0020/R0270 in template S.02.01 says in the second sentence that the total amount of reinsurance recoverables corresponds to the amount of the reinsurer's share of technical provisions (including Finite reinsurance and SPV).

As claim payments to policyholders that are past due should not be included in technical provisions (see Q&A 2582), this implies that reinsurance recoverables should not include payments from reinsurers to the undertaking that correspond to payments to policy holders past their due date, as those payments to policyholders are no longer within the technical provisions.

Please note that this carries over to the split of the recoverables in the business types in rows R0280 – R0340.