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Stand:updated on 01.01.2016 | Topic Reporting obligations Submission of data

Technical aspects of Solvency II reporting procedures

I. Submission via BaFin's MVP Portal

Solvency II notifications and reports are submitted electronically to BaFin via its MVP Portal (specialised procedure "Insurance Supervision – Solvency II"). Along with up-to-date information and announcements, the portal also provides detailed instructions on how to use the procedure.

The technical aspects of the Solvency II reporting procedures described below were given binding effect by the Regulation on Reporting (see section 39 (1) no. 7 of the Insurance Supervision Act (Versicherungsaufsichtsgesetz - VAG). They are relevant for all primary insurers, reinsurers and insurance groups within the scope of Solvency II.

II. XBRL notifications (quantitative reporting)

XBRL data format

Quantitative templates (so-called reporting templates) are to be submitted to BaFin in XBRL format. General information on the XBRL standard can be obtained at http://xbrl.org/, http://www.xbrl.de/, http://www.eurofiling.info/.

EIOPA XBRL taxonomy

Based on quantitative reporting requirements harmonised at European level, the European Insurance and Occupational Pensions Authority (EIOPA) provides an XBRL taxonomy which, in addition to the obligatory dataset description, also includes validation rules against which the data reported are checked. During its period of applicability, the EIOPA XBRL taxonomy covers all versions required for Solvency II quantitative reporting (reporting of primary insurers, reinsurers and insurance groups, quarterly and annual reporting, etc.). The taxonomy defines specific entry points for access to the individual report versions. In addition to entry points for the original Solvency II report versions (including reporting on third country branches and SPVs), the EIOPA XBRL taxonomy provides entry points for reporting for financial stability purposes and ECB insurance statistics purposes. The rationale for pooling these technical data is that the reporting obligations for financial stability purposes and ECB insurance statistics purposes overlap to a high degree with the Solvency II reporting requirements. To avoid having different standards, formats, reporting channels, etc. for partially identical information needs, the above-mentioned reporting obligations were included in the Solvency II taxonomy (for further information, please refer to "Further notes", points 1 and 2 ). The currently applicable version of the XBRL taxonomy and further information on this matter can be fond at https://eiopa.europa.eu/regulation-supervision/insurance/reporting-format.

The following entry points should be selected for reporting to BaFin:

Table "Entry points for XBRL notifications"
FrequencyType of reporting requirementEntry point acronymEntry point code
NonrecurrentDay 1 Solvency II reporting Solo d1s.03
Day 1 Solvency II reporting Groupd1g.06
Day 1 Solvency II reporting Third country branches
d1b.09
QuarterlyQuarterly Solvency II reporting Solo*
qes.17
Quarterly Solvency II reporting Group*qrg.05
Quarterly Solvency II reporting Third country branches*qeb.19
Quarterly Financial Stability reporting Soloqfs.11
Quarterly Financial Stability reporting Groupqfg.13
Quarterly Financial Stability reporting Third country branchesqfb.15
AnnualAnnual Solvency II reporting Solo*
aes.16
Annual Solvency II reporting Grouparg.04
Annual Solvency II reporting Third country branches*aeb.18
Annual Financial Stability reporting Soloafs.10
Annual Financial Stability reporting Groupafg.12
Annual Financial Stability reporting Third country branchesafb.14
Annual reporting Special Purpose Vehiclesspv.20

All data sets for report versions marked with an "*" also contain content reported on the ECB insurance statistics, since they are based on the "extended" ECB entry point (see entry point acronym "...e..."). This ensures that when submitting a notification, both the reporting requirements under Solvency II and the ECB insurance statistics are met.

Validation of XBRL notifications

A notification must fulfil the following conditions in order to be regarded as submitted - and the reporting requirement thus considered met:

1. Compliance with naming conventions. The notification file must comply the following naming convention:

<"SII">_<4-digit registration number>_<reporting period JJJJ(QQ)>_<sequential number>.zip

<"SII">_<4-digit registration number>_<reporting period JJJJ(QQ)>_<sequential number>.zip

<Registration number> is the four-digit numerical registration number of the insurance undertaking subject to the notification requirement (see "Further notes" point 3).

<Reporting period> is the four-digit numerical year of annual notifications or the six-digit numerical combination of year and quarter of the quarterly notification.

For the so-called Day 1 reporting, the reporting period is "0000".

<Sequential number> is a four-digit number that shows whether the notification is the initial notification ("..._0001.zip") or a correcting notification (e.g. "..._0002.zip") of the respective reporting period. If there is need for correction, the correcting notification will replace the previous notification and the sequential number will be increased by 1. In most cases, i.e. without a correcting notification, the sequential number is "0001".

Example:
SII_4711_2017_0001.zip (Annual notification of insurance undertaking 4711 for 2017)
SII_4711_201703_0001.zip (Quarterly notification of insurance undertaking 4711 for Q3 2017)

The XBRL file contained in the zip archive must end in .xbrl and comply with the general naming conventions of the MVP Portal.

While the naming conventions are compulsory and must be observed, the name of the notification file may be individually extended by adding a suffix, separated by an underscore, of up to eight alphanumerical characters. The file name may contain any characters, including underscores and dashes, except umlauts, blank spaces or special characters.

Examples:

  • SII_4711_2017_0001_G.zip
    (Annual notification of a group for 2017)
  • SII_4711_2017_0001_G-FS.zip
    (Annual notification of a group for 2017 for financial stability purposes)
  • SII_4711_2017_0001_20180615.zip
    (Annual notification for 2017, submitted on 15 June 2018)

This optional extension of notification file names allows the submitting undertaking or institution to better manage the storage of their internal files. Only the notification content and the entry point selected are relevant for processing and interpretation of the notification by BaFin (see table above "Entry points for XBRL notifications").

2. Taxonomic validity. Each notification must be processed on the basis of the taxonomy version applicable during the selected reporting period. Notifications must in particular comply with the validation rules of the selected entry point integrated in the taxonomy (see table above "Entry points for XBRL notifications"), if such rules are applicable. Validation rules are applicable unless they have been deactivated by EIOPA. Deactivated validations will be published on EIOPA's website.

3. Compliance with applicable filing rules. Notifications must comply with any EIOPA filing rules identified as "MUST". These MUST rules are also listed on the EIOPA website.

Use of the LEI in XBRL notifications

Quantitative reporting requires undertakings to identify themselves by using an identification code for legal entities, the Legal Entity Identifier (LEI Code). For this reason, the LEI Code (NOT the four-digit registration number) must be entered in all data fields of XBRL notifications that serve to identify the undertaking. The 4-digit registration number is required for registration at the BaFin MVP Portal and for naming the notification file (see above "Compliance with naming conventions".

EIOPA reporting tool (Tool for Undertakings)

During the start-up phase of Solvency II reporting, EIOPA offers a reporting tool for undertakings called "T4U". This software solution helps undertakings to generate XRBL instances in line with the taxonomy. Up-to-date information on EIOPA's reporting tool can be obtained at EIOPA's website under https://eiopa.europa.eu/Pages/Supervision/Insurance/Tool-for-Undertakings.aspx.

EIOPA bears the sole responsibility for this tool. BaFin cannot provide support services.

III. PDF reports (narrative reporting)

Narrative Solvency II reports are to be submitted to BaFin in PDF format. The document has to meet the specifications of, for instance, PDF/A-1a, PDF/A-2a or PDF/A-3a to ensure that the text contained in the document can be searched. The conformance of the report with one of the aforementioned specifications must also be shown in the document properties (so-called meta data). Unlike the quantitative templates, the narrative report files are submitted uncompressed to the MVP Portal of BaFin.

In order for report files to be successfully received, i.e. for reporting requirements to be met, the reports of primary insurers and reinsurers must fulfill the following naming conventions:

BerichtNamenskonventionDateinamen-Beispiel
SFCRSFCR" & "_" & registration number & "_" & reporting period & ".pdf"SFCR_1234_2016.pdf
RSRRSR" & "_" & registration number & "_" & reporting period & ".pdfRSR_1234_2016.pdf
ORSA"ORSA" & "_" & registration number & "_" & reporting period & ".pdf"ORSA_1234_2016.pdf

For the narrative part of the Day 1 reporting, the naming convention is "Day 1" & "_" & registration number & "_2016.pdf".

If a group level notification is submitted, the suffix "_G" must be added to the file name. In this case, the suffix is mandatory.

Example: RSR_1234_2016_G.pdf

The suffix "_ADHOC" should be appended to file names of reports that are submitted ad hoc, i.e. at an unscheduled time and/or for non-standard reporting periods.

Example (report of a primary insurer and reinsurer):

RSR_1234_2016_ADHOC.pdf

Example (group report):

RSR_1234_2016_G_ADHOC.pdf

If the reporting requirements of a primary insurer and reinsurer are met by submitting a group-level report (which is always due at a later date), and the solo level report is consequently not submitted by the relevant reference date, a statement of "nil" is required at the level of the primary insurer or reinsurer. The submission of such a statement requires submission of a file in the same format (PDF), but adding the suffix "_FA" to the file name.

Example:

ORSA_1234_2016_FA.pdf

The statement of "nil" is to be worded such that the only assertion conveyed by the document is that it is a statement of "nil".

Reports that do not comply with the above naming conventions cannot be received, with the result that reporting requirements are not fulfilled.

General remarks

1. EIOPA XBRL taxonomy: in order to submit XBRL notifications to the MVP Portal of BaFin, it is necessary to store the notification file in a ZIP file ("outer notification file"). More detailed information on how to submit notifications to the MVP Portal can be obtained here.

2. EIOPA XBRL taxonomy: regulation on statistical reporting requirements for insurance corporations (ECB/2014/50). For further information please refer to the Bundesbank's website.

3. Validation of incoming XBRL notifications: the registration number of the leading entity should be stated as registration number for notifications at group level.

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