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General comments Insurance Europe welcomes the opportunity to comment on the EIOPA consultation on corrections and amendments of the implementing technical standards on reporting and disclosure. However, Insurance Europe highlights that due to the timing of the consultation - several reporting deadlines have to be met in this period, eg annual reports are due 7 May 2018, Q1 reports are due 14 May - many undertakings will not have the resources to analyse the proposed amendments in detail.
Further, Insurance Europe notes that the introduction of more than 300 new validations is seen critical. Especially for complex groups it would not be feasible to implement these - mainly blocking - validations in time for Q4 reporting, as the final taxonomy will only be published around mid-July. To avoid problems stemming from the new validations, Insurance Europe proposes to implement these validations as ‘non-blocking’ for the first year of application, and transform them into blocking validations for the second annual submission. Insurance Europe suggests applying a similar approach for quarterly validations, eg new validations could be ‘non-blocking’ for the first two quarters of application and be transformed into blocking validations as from the third quarter. This would avoid that the submission of a full report is hindered because a single new validation is failing.
Insurance Europe welcomes the introduction of some of the Q&As into the ITS, however, the aim should be to cover all necessary information in the ITS. Therefore, Insurance Europe proposes to include all relevant Q&As in the ITS, and to indicate in the Q&A files the Q&As that have been included.