EIOPA Confirms Q&A 2753 Will Be Amended to Align CIC 86-88 Reporting with ITS 2.10.0

Key Takeaways

• EIOPA has agreed that the 2023 ITS amendments (taxonomy 2.10.0) conflict with its earlier Q&A 2753 on mapping loan CIC codes 86, 87 and 88 to Solvency II balance sheet lines R0240 and R0250.
• Q&A 2753 will be amended, but the revised wording has not yet been published.
• Insurers should treat the ITS as the governing text and review their S.02.01 and S.06.02 mappings for consistency.

Deep Dive

EIOPA has agreed that the 2023 ITS amendments (taxonomy 2.10.0) conflict with its earlier Q&A 2753 on mapping loan CIC codes 86, 87 and 88 to Solvency II balance sheet lines R0240 and R0250. Q&A 2753 will be amended, but the revised wording has not yet been published. Insurers should treat the ITS as the governing text and review their S.02.01 and S.06.02 mappings for consistency.

The question, submitted on 06 Jul 2026 and now marked Final, concerns Regulation (EU) 2023/894 and templates S.02.01 (balance sheet) and S.06.02 (list of assets). Since Q4 2023, loans have been classified as CIC 86 (loans on policies), CIC 87 (loans to AMSB members) and CIC 88 (loans to other natural persons). CIC 87 and 88 take precedence over the other CIC 8* categories. Q&A 2753 had directed that R0240 (Loans on policies) include all policy loans regardless of CIC 86, 87 or 88, and that R0250 (Loans to individuals) hold only the remaining loans under CIC 87 and 88. The submitter argued that the ITS in taxonomy 2.10.0 appears to require the opposite treatment.

EIOPA's answer is brief. It agrees that the latest ITS amendments require changes to Q&A 2753, which will therefore be amended. It does not set out the corrected mapping, give a timeline for the revision, or address the submitter's query on why only AMSB loans (CIC 87) are named in the R0250 instructions. Until revised guidance appears, the ITS text is the authoritative source. That text defines R0240 as loans to policyholders collateralized on policies, and R0250 as loans to individuals, with or without collateral, and including AMSB natural-person loans of any type. Q&A 2753 is therefore likely to be superseded wherever it conflicts with the ITS.

For compliance and reporting teams, the main risk is misclassification between R0240 and R0250 in the Solvency II balance sheet. This could produce inconsistencies between S.02.01 and S.06.02, validation failures, or supervisory queries. Although the amounts may be modest for many undertakings, quality of submitted data is a focus area for national supervisors. Firms that built their mapping logic on Q&A 2753 are most exposed.

Recommended actions:
- Compare current CIC-to-balance-sheet mapping for CIC 86, 87 and 88 against the ITS instructions for R0240 and R0250.
- Quantify the effect of any difference on reported figures for recent reporting periods.
- Document the interpretation adopted and the rationale, in case of supervisory challenge.
- Monitor EIOPA's Q&A publications for the revised Q&A 2753 and be ready to adjust systems and controls quickly.
- Consider consulting the national competent authority if the impact is material or if resubmission could be required.

Source: European Insurance and Occupational Pensions Authority