EIOPA Defers Fix to SE.01.01 Closed List for Non-Due S.36.05 Template to Future ITS Amendments

Key Takeaways

• EIOPA has confirmed that the SE.01.01 closed list will not yet include "Not due in accordance with instructions of the template" for S.36.05, even though Taxonomy v2.10.0 now treats S.36.05 as not due when its content is already reported in other S.36 templates.
• Any change is deferred to the next ITS amendments.
• Insurers must therefore use a workaround for now, and should plan for how it will be perceived by supervisors.

Deep Dive

EIOPA has confirmed that the SE.01.01 closed list will not yet include "Not due in accordance with instructions of the template" for S.36.05, even though Taxonomy v2.10.0 now treats S.36.05 as not due when its content is already reported in other S.36 templates. Any change is deferred to the next ITS amendments. Insurers must therefore use a workaround for now, and should plan for how it will be perceived by supervisors.

The question (ID 3615, final status, submitted 10 Jul 2026) concerns a mismatch between Taxonomy v2.10.0 and the ITS on supervisory reporting templates (Implementing Regulation (EU) 2023/894). Under the taxonomy, QRT S.36.05 is no longer due when the reported elements already appear in other S.36 templates. However, the SE.01.01 closed list does not offer the option "Not due in accordance with instructions of the template" for S.36.05. The only available choice is "Not reported other reason," which would normally call for a specific justification.

EIOPA's answer does not change the current requirements. It notes that Taxonomy 2.10.0 has been published and that the ITS amendments have already been submitted to the European Commission for adoption. EIOPA says it will examine the issue in the next round of ITS amendments. No timeline is given, and no interim guidance is provided on which option to select or what justification to supply. The response should be read as acknowledgment of the inconsistency, not a resolution.

For compliance and regulatory reporting teams, the main impact is operational. Where S.36.05 content is already covered in other S.36 templates, firms will likely need to select "Not reported other reason" in SE.01.01. They will also need to decide how to word the justification, for example by referencing the Taxonomy 2.10.0 instructions and the duplication with other S.36 templates. Because EIOPA has not prescribed an approach, the practice is not harmonized across firms, and national supervisors may react differently.

Recommended actions: (1) document the chosen approach and rationale in reporting procedures; (2) confirm with the national competent authority how it expects such cases to be flagged, and whether data quality checks might query the "other reason" selection; (3) make sure the S.36.05 due-logic in reporting systems matches Taxonomy 2.10.0; (4) monitor the Commission's adoption of the ITS amendments and subsequent EIOPA consultations so the closed list change can be implemented once made; and (5) keep an audit trail for any supervisory follow-up.

Risk impact is low to moderate. The exposure is mainly reporting inconsistency, possible supervisory queries, and extra manual effort, not a substantive compliance breach. The risk is highest for groups reporting across several jurisdictions, where authorities may interpret the workaround differently.

Source: European Insurance and Occupational Pensions Authority