EIOPA Consultation in Focus: What’s Changing in Solvency II Reporting & Disclosure

EIOPA has launched a public consultation on amendments to the Implementing Technical Standards (ITS) for supervisory reporting and public disclosure under Solvency II. The Level 3 amendments target four areas to improve: 

• Changes of the reporting obligations stemming from the Level 1 amendments – DIRECTIVE (EU) 2025/2 
• Correction of inconsistencies identified in the first year of the application of the latest ITS on supervisory reporting and ITS on public disclosure (applicable since December 2023),  
• Targeted requests for new supervisory data and  
• Proposals for streamlining frequency and template scope. 

As Level 2 changes are expected to undergo public consultation later in summer 2025, EIOPA has chosen to focus this current consultation solely on Level 1 amendments. This approach provides the industry with sufficient time to prepare for the upcoming ITS and taxonomy implementation.

Key Takeaways: 

1. Template Changes Triggered by the Solvency II Review

The Solvency II review introduces new or revised templates aligned with Level 1 changes: 

• S.01.02 – Basic information (Solo and Group) 
• S.22.01 – Long-term guarantees and transitional measures (Solo and Group) 
• S.22.06 replaced by S.22.07 – Calculated volatility adjustment and corresponding best estimates by country and currency.  

2. Clarifications and Fixes to Reporting Instructions 

Several errors and inconsistencies identified in 2023 ITS are corrected. In addition, the instructions are clarified for several templates and updated to reflect NACE 2.1 codes as of 2025. 

3. New Supervisory Data Requests 

• Natural Catastrophe Data Collection – Two new templates will collect insured NatCat losses and exposures at CRESTA and country levels. This supports EIOPA’s climate resilience strategy and disaster risk monitoring.
• Pension Products Supervision – Template S.14.01 is enhanced to distinguish occupational pension products from other life insurance products, addressing identified supervisory blind spots. 

4. Reducing the Reporting Burden: EIOPA’s Simplification Package 

To address concerns around reporting complexity, EIOPA proposes a package of simplifications focused on frequency, scope, and relevance:

    4.1. Reduced Reporting Frequency

• S.28.01 / S.28.02 (MCR) – Annual reporting only 
• S.06.03 (CIU Look-through) – No longer required in Q1 and Q3 
• Small Non-Complex Undertakings (SNCUs) – Only three templates (S.01.01, S.01.02, S.23.01) to be reported in Q1 and Q3 

    4.2. Deleted Annual Templates

EIOPA proposes to remove several annual templates due to limited supervisory value and high reporting burden. The following templates are proposed for deletion: 

Solo undertakings: 

• S.21.01 – Loss distribution risk profile 
• S.21.02 – Underwriting risks non-life 
• S.21.03 – Non-life distribution of underwriting risks – by sum insured 
• S.23.02 – Detailed information by tiers on own funds 
• S.23.03 – Annual movements on own funds 
• S.29.01 – Excess of Assets over Liabilities 
• S.29.02 – Excess of Assets over Liabilities – explained by investments and financial liabilities 
• S.29.04 – Detailed analysis per period – Technical flows versus Technical provisions 
• S.30.01 – Facultative covers for non-life and life business basic data 
• S.30.02 – Facultative covers for non-life and life business shares data 

Group undertakings: 

• S.37.03 – Risk Concentration – Exposure by asset class and rating 

    4.3. Further Simplifications and Clarifications

• S.06.02 – Removal of columns related to custodians — C0120 (Custodian), C0121 (Custodian code and type), and C0122 (Type of code of custodian) 
• S.14.01 – Elimination of fields C0055 (Fiscal treatment), C0142 (Remaining contractual maturity), and C0270 (Exit conditions at reporting date) 
• S.14.02 – Deletion of the “Country” field 
• S.16.01 – Reporting by currency removed 
• S.19.01 – Reinsurance recoverables triangles removed; template now focuses on direct claims expenses (ALAE) and limited additional data 
• S.36 templates – Profit and loss information removed due to redundancy 
• S.04 templates – Clarified guidance, particularly for cross-border reporting 
• S.06.04 – Reduced reporting scope to total exposures only; instructions clarified based on industry Q&A 

If S.06.02, S.06.03, and S.08.01 are reported in Q4, no separate annual submission is required (unless there is an exemption under Article 35a) 

    4.4. Proportionality Measures

• Threshold for S.03.01 (Off-Balance Sheet Items) increased from 2% to 3.5% 
• SNCUs are exempt from reporting S.06.04 (Climate Risk) and the two new NatCat templates 

More Information

The full consultation paper and supporting documents are available on EIOPA’s website: EIOPA Consultation on Supervisory Reporting and Public Disclosure 

What’s Next?

EIOPA invites comments via EU Survey until 10 October 2025. A revised proposal and consultation feedback report will follow. 

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