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Are commission claw-backs part of C0071 (Total amount of commissions paid during year) or not?

We are struggling with a clear assignment of some assets to CIC codes, in particular 22/25/28/51. Could you please confirm that our understanding of the following instruments is correct?

One of our insurance entities was contacted by their local authority regarding Q4_2024 reporting. They asked them to fill column “C0145 Long-term equity investment” in the list of assets (S.06.02) also for assets without CIC 3 or 4. They demand that for all other CIC the element “9 – not applicable” must be filled in. Together with our system provider we analyzed this topic and found the following instructions. From the LOG File, we think it is clear that the column only has to be filled for CIC 3 and 4. But the EIOPA Q&A lead to some confusions. Reading the Q&A 2651, EIOPA confirms that there are 4 available options.

In Q&A 2553 and 2729 you confirm the S.06.04 is RECOMMENDED to look through,e.g. based on the S.06.03. But this are only assets classes and doesn't mean anything about climate risk. The same for the NACE-codes in the S.06.02. You also answer that "for this, undertakings are allowed to make their own estimates". By doing so their is no force for the sector for one (comparable) standard.

Can an insurance broker (including a captive broker) who has a legal authorization only for an insurance broker (the distribution of insurance) or reinsurance, carry out the activity of claims management, as well as the activities of instruction and assessment of claims otherwise carried out by the insurer, given that these claims fall under the Professional Civil Liability guarantee of the clients of said broker (and the broker and his clients are in "close ties" in the case of a captive broker)?

When calculating group SCR, some of the solo-level exposures are removed from group level diversification according to articles DA 336(d) and 336(e). Their capital requirement calculated on an individual exposure level is added to the final group SCR. Should these exposures be included within appropriate risk modules in group SCRs when calculating group LAC of TP and DT?

Considering that insurance and reinsurance intermediaries and ancillary insurance intermediaries are not obliged by law to setup a dedicated legal entity to carry out insurance distribution and therefore some of them may have a principal professional activity other than insurance distribution, how should the calculation of the thresholds defined in DORA Article 2(3) point (e) for exclusion of those intermediaries which are micro, small or medium enterprises be interpreted?

Proposal - Recognising Handstand Teaching as a Distinct Insurance Category

I note that your monthly RFF file for March "EIOPA_RFR_20250331_Term_Structures" does not include any term data for South Korea and India. Will you provide these, and if not, can I ask why they are not provided?