EIOPA Rejects Q&A 3463 on CIC Classification of French NEU CP and NEU MTN Instruments

Key Takeaways

• EIOPA rejected Question 3463 because it sought an interpretation of French national legislation, which is outside the scope of the Q&A process.
• No new guidance on CIC codes for NEU CP or NEU MTN was issued.
• Insurers must therefore rely on existing Solvency II reporting rules and their own documented classification judgment.

Deep Dive

EIOPA rejected Question 3463 because it sought an interpretation of French national legislation, which is outside the scope of the Q&A process. No new guidance on CIC codes for NEU CP or NEU MTN was issued. Insurers must therefore rely on existing Solvency II reporting rules and their own documented classification judgment.

The rejection means EIOPA has not clarified how the 2016 Banque de France reform of the negotiable debt securities (TCN) market maps to Complementary Identification Code (CIC) categories. The submitter asked how EIOPA interprets the reform, which CIC codes apply to NEU CP (which now covers former Commercial Paper and Certificates of Deposit) and NEU MTN, and whether these instruments could be aligned under a single code. EIOPA treated these questions as dependent on interpreting national law, so it did not address them. The rejection is a procedural outcome, not a substantive position on the classification.

The question referenced Delegated Regulation (EU) 2015/35 and Implementing Regulation (EU) 2023/894 (reporting templates). The submitter noted that ISINs with the same instrument type (NEUCP) carry different CICs (FR24 and FR23). This shows the practical difficulty: the CIC is assigned under the reporting framework's classification logic (which depends on the instrument's economic and legal characteristics, such as the issuer type and the nature of the instrument), whereas the national NEU CP label covers a broader grouping. No deadlines were set, and the rejection creates no new obligations. The submission date was 14 Nov 2025, and the publication date is 2026-09-11.

Compliance teams should not treat the rejection as endorsement of any current approach. Recommended actions:
- Review existing CIC mappings for French TCN instruments, particularly NEU CP and NEU MTN.
- Confirm that classification is driven by instrument characteristics (for example, whether an instrument is a certificate of deposit or commercial paper by nature) and not solely by the NEUCP instrument type field.
- Document the rationale and mapping logic in data governance and reporting policies.
- Consider consulting the national competent authority (ACPR in France) on classification expectations, since EIOPA pointed to the national-law dimension.
- Check existing EIOPA CIC guidance and prior Q&As for related precedents.

Risk implications are moderate. Inconsistent CIC assignment between similar instruments can cause errors in quarterly and annual quantitative reporting templates (such as asset templates S.06.02 and S.08), data quality findings, and queries from supervisors. Impact on solvency calculations is likely limited, but misclassification can distort asset category reporting and risk-module inputs. Firms with large French short-term paper holdings or third-party data vendors supplying CICs should prioritize validation and keep a clear audit trail of decisions.

Source: European Insurance and Occupational Pensions Authority