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Some legal provisions are already in place, both for statistical insurance data under the ECB statistical framework and for supervisory insurance data under the Solvency II framework.
For the purpose of statistical data, the IC Regulation (Annex III) refers in general terms to minimum standards for revisions, stating that “The revisions policy and procedures set by the ECB and the relevant NCB must be followed”. Annex III also defines minimum standards for transmission, accuracy and compliance with concepts, implying that incorrect data should be corrected. As regards the national aggregated data reported by the NCBs to the ECB, the Monetary and Financial Statistics Guideline includes a short section on revision policy, providing that between the initial transmission of new data and their dissemination only the latest data should be revised, although any reference periods can be revised outside this period. It also specifies that NCBs should submit explanatory notes giving the reasons for significant revisions and for historical revisions.
The Solvency II framework refers to re-submission of data by insurance and reinsurance undertakings and groups in Commission Implementing Regulation (EU) 2015/2450, Article 4, which states that financial institutions “shall re-submit as soon as practicable the information reported using the templates referred to in this Regulation when the information originally reported has materially changed in relation to the same reporting period after the last submission […]”.
Article 9 of the EIOPA Decision of the Board of Supervisors on Collection of Information by EIOPA under Solvency II specifies that EIOPA may, after performing quality checks, conclude that additional information or explanations are required and as a result send a request for comments to an NCA.
By agreeing on common minimum standards, all authorities have aligned their expectations for the minimum acceptable level of data quality for the purposes of the different uses of data. The common understanding established in this document should be considered for the reporting reference dates after its date of publication. However, these common minimum standards should not prevent stricter practices from being applied at national level. The NCAs/NCBs have the responsibility and the power to request that financial institutions revise data when necessary.
Given the extent and complexity of data submitted to EIOPA and the ECB, the XBRL validations, which perform a significant set of controls, cannot cover all data quality issues. Additional analyses undertaken by active users of the data are needed and occasionally reveal quality issues which require revised data to be submitted to EIOPA and the ECB.
While information reported should be of good quality at the time of its first submission (reporting), revisions may nonetheless be needed at a later stage. Revisions may be on financial institutions’ own initiative or requested by EIOPA, the ECB, NCAs or NCBs.
It is important to keep consistency between EIOPA’s Central Repository, the ECB’s statistical databases and NCA/NCB databases. Any revision of data should be carried out at all levels of the transmission chain so that all parties involved5 have the same data.
Revisions should be sent by NCAs and NCBs to EIOPA and the ECB in a timely manner, thus reducing time pressure for business users who need high-quality and stable data on specific dates