EIOPA Confirms CIC 47 Classification for Listed Private Equity Funds in S.06.02 Reporting

Key Takeaways

• EIOPA has confirmed that a fund investing predominantly in listed securities of issuers that primarily make or manage private equity or private debt should be classified under CIC 47 (Private Equity Funds) in Solvency II template S.06.02.
• Because the fund is listed, the CIC country prefix must reflect the listing venue, or be XV if the fund is listed in multiple countries.
• Insurers and asset managers should review their investment fund classifications to ensure consistent and accurate regulatory reporting.

Deep Dive

EIOPA has confirmed that a fund investing predominantly in listed securities of issuers that primarily make or manage private equity or private debt should be classified under CIC 47 (Private Equity Funds) in Solvency II template S.06.02. Because the fund is listed, the CIC country prefix must reflect the listing venue, or be XV if the fund is listed in multiple countries. Insurers and asset managers should review their investment fund classifications to ensure consistent and accurate regulatory reporting.

The answer also sets a requirement on the CIC prefix. Because the fund is itself listed, the two-letter country code should be the country of listing. Where the fund is listed in more than one country, the prefix should be XV. This differs from the prefix convention applied to unlisted funds, so teams should confirm that the logic in their reporting systems distinguishes between listed and unlisted vehicles.

The Q&A is final, and the question was submitted on 23 Apr 2025. No new deadline is introduced. As Q&As reflect EIOPA's supervisory expectations on applying existing rules, firms should align their classification practices at the next reporting cycle and consider whether prior submissions need correction. Materially misclassified items may warrant dialogue with the national competent authority.

Recommended actions: (1) screen the investment fund portfolio for listed funds focused on private equity or private debt issuers; (2) review current CIC assignments and correct any that differ from CIC 47; (3) verify the country prefix logic, including XV for multi-listed funds; (4) update data vendor mappings, reporting procedures, and look-through documentation; and (5) document the rationale for classification decisions for audit and supervisory review.

Risk implications are mainly regulatory reporting quality and data integrity. Misclassification can distort asset-class aggregation, supervisory analysis of private equity exposure, and potentially the consistency between reported assets and the associated capital charge treatment under the standard formula. The overall impact is low to moderate, but it may be more significant for firms with large holdings of listed private equity vehicles.

Source: European Insurance and Occupational Pensions Authority