EIOPA Rejects Q&A 3616 on S.27.02 and S.27.03 Asset Type and Policy Reporting, Cites Q&A 3612

Key Takeaways

• EIOPA has rejected Q&A 3616, which asked for clearer asset type definitions (c0050) and for guidance on expired policies in the S.27.02 and S.27.03 templates, because Q&A 3612 already addresses the matter.
• The rejection introduces no new requirements.
• Compliance and reporting teams should review Q&A 3612 for the operative interpretation and confirm that their QRT reporting aligns with it.

Deep Dive

EIOPA has rejected Q&A 3616, which asked for clearer asset type definitions (c0050) and for guidance on expired policies in the S.27.02 and S.27.03 templates, because Q&A 3612 already addresses the matter. The rejection introduces no new requirements. Compliance and reporting teams should review Q&A 3612 for the operative interpretation and confirm that their QRT reporting aligns with it.

The submitter raised two issues. First, the distinctions between the asset type categories in column c0050 are unclear in the log file instructions, and the submitter asked for more detailed definitions of each individual type. Second, for S.27.03, the log file instruction says that when a policy is renewed during the year, only data for the policy active at the reporting date is reported. The instruction does not address policies that expired during the calendar year. The submitter argued that excluding them creates a mismatch between premium data ("as of" the reporting date) and claims data (calendar year), which could bias the results. If such policies were included, the submitter asked whether premiums should be pro-rated to the exposure period, for example 50% of premium for a policy expiring on 31 May. EIOPA did not confirm either approach in this answer.

No new deadlines or compliance dates arise from this update. The relevant dates are the submission date (15 July 2026) and the publication date (16 September 2026). Firms should keep to their existing QRT reporting calendar and national competent authority (NCA) expectations.

Recommended actions:
- Retrieve and review Q&A 3612 and confirm whether it resolves both the asset type and expired policy questions.
- Document the methodology the firm uses for c0050 asset type classification and for treating expired and renewed policies in S.27.03, with the rationale and its alignment to Q&A 3612 and the log file instructions.
- Where Q&A 3612 does not fully resolve an ambiguity, consult the NCA and record the outcome.
- Run a sensitivity check on the premium and claims basis mismatch to assess any data quality or bias impact.
- Update reporting procedures, data lineage documentation, and validation controls as needed.

The risk impact is moderate and mainly concerns regulatory reporting accuracy. Inconsistent interpretation of asset types or policy inclusion could cause misstatement in the catastrophe risk templates, supervisory queries, or resubmission requests. Because the rejection leaves the ambiguity to be settled through Q&A 3612, firms that rely on their own assumptions without documenting them face higher supervisory challenge risk.

Source: European Insurance and Occupational Pensions Authority