EIOPA Clarifies Policy Treatment and Asset Type Guidance for New QRT S.27.03 Reporting

Key Takeaways

• EIOPA has issued a final Q&A (ID 3612) clarifying how undertakings should treat renewed and expired policies in the new QRT S.27.03 and where to find guidance on commercial versus industrial asset types.
• Expired policies must follow the approach used for comparable datapoints in QRT S.05.01, and asset classification guidance sits in Annex IV of S.06.02.
• Compliance teams should align data logic and classification rules now to avoid inconsistent submissions.

Deep Dive

EIOPA has issued a final Q&A (ID 3612) clarifying how undertakings should treat renewed and expired policies in the new QRT S.27.03 and where to find guidance on commercial versus industrial asset types. Expired policies must follow the approach used for comparable datapoints in QRT S.05.01, and asset classification guidance sits in Annex IV of S.06.02. Compliance teams should align data logic and classification rules now to avoid inconsistent submissions.

The Q&A addresses two issues raised by an undertaking preparing for the new QRT S.27.03 under Commission Implementing Regulation (EU) 2023/894 (Taxonomy 2.10). The submitter argued that the LogFile instruction, which limits reporting to the policy active at the reporting date, leaves a gap for policies that expire during the calendar year. In that case, premium data would be "as of" the reporting date while claims data would cover the calendar year, which could bias results. The submitter also asked whether premiums for expired policies should be pro-rated to the period of exposure, for example 50% for a policy expiring on May 31.

EIOPA confirmed that the renewal rule stands: where a policy is renewed during the year, only data for the policy active at the reporting date is reported, even if amounts relate wholly or partly to a later period. For policies expiring during the calendar year, undertakings must report insurance premiums and expenses consistently with the approach used for similar datapoints in QRT S.05.01. EIOPA did not prescribe explicit pro-rating. The practical effect is that S.27.03 premium and expense figures should be derived with the same logic as the S.05.01 equivalents, which supports reconciliation between the two templates.

On asset types, EIOPA declined to issue new market definitions for commercial versus industrial assets. It referred undertakings to Annex IV of S.06.02 (List of Assets) in Regulation (EU) 2023/894. Teams should not create proprietary definitions, as these could cause mismatches with S.06.02 and with peer entities.

The Q&A is final and was submitted on July 7, 2026. No new deadlines are stated, but the guidance is relevant to the build and testing of S.27.03 under Taxonomy 2.10 ahead of the first reporting cycle. Recommended actions:
- Document the S.27.03 premium and expense methodology for expired and renewed policies, with an explicit cross-reference to S.05.01 logic.
- Build reconciliation checks between S.27.03 and S.05.01.
- Map asset classification to the S.06.02 Annex IV instructions and record any judgment calls.
- Confirm that data lineage and controls cover the mismatch between "as of" premium data and calendar-year claims data.
- Brief actuarial, finance, and data teams, and monitor for further EIOPA Q&As or national supervisory expectations.

Risk implications center on regulatory reporting quality. Inconsistent treatment of expired policies could cause misstatement, internal data mismatches, and supervisory queries. Misclassifying assets could reduce comparability and draw scrutiny. The ambiguity on pro-rating is a residual interpretation risk, so firms should keep documented rationale and consider engaging their national competent authority where uncertainty remains.

Source: European Insurance and Occupational Pensions Authority