Filing to EIOPA and the PRA from one data set: a group with a UK subsidiary

A group with insurers on both sides of the Channel reports to two regimes. The EU entities, and the group return if the parent is in the EU, go to a national supervisor on EIOPA’s S templates and taxonomy. The UK entity files IR templates on the Bank of England Insurance Taxonomy through BEEDS. Two teams often run them from two extracts of the same ledger and reconcile in the last week of the quarter. This article is for the reporting lead who wants one data set behind both. It sets out what the two returns share, where they differ, which S template maps to which IR template, what a 30 September 2026 quarter end looks like in one calendar, and the design rules that let BOE Tool, our Bank of England XBRL reporting software, QRT Tool and SCR Tool produce both returns from one import. It builds on our comparison of Solvency UK and Solvency II, which covers the reforms themselves.

The situation

Take an EU group with a UK solo subsidiary. The subsidiary files its returns to the PRA on the IR templates and files no EIOPA solo return. The parent files the group return to its EU group supervisor on the S templates, consolidating the UK subsidiary. The UK balance sheet therefore appears twice each quarter: in IR.02.01 for the PRA and inside the group S.02.01 for EIOPA, on different codes, with different validations and, since the UK risk margin reform, with a different technical provisions figure.

A UK group with EU subsidiaries has the mirror image: the PRA receives the group return on IR templates, and each EU subsidiary files solo to its national supervisor on the EIOPA taxonomy for that reference date. Either way, one legal entity’s numbers appear in both packages and have to agree.

What the two returns share

More than the template codes suggest. Solvency UK kept the Solvency II valuation rules, so the market consistent value of the UK entity’s assets and liabilities is one number before the risk margin is added. The list of assets is one list: IR.06.02 keeps the CIC code table, the ISIN, the issuer LEI and the asset categories of S.06.02, so an asset master that is complete for EIOPA is complete for the PRA. The claims triangles in S.19.01 and IR.19.01 come from the same claims system with the same accident years. The actuarial models are shared as well: the best estimate cash flows behind IR.12.01 and IR.17.01 are the projections that feed S.12.01 and S.17.01, and the UK standard formula still uses the modules, shocks and correlation matrices in our article on the SCR standard formula calculation.

The pipeline from source to instance is the same too; our article on what XBRL means for insurance reporting walks through it, and only the taxonomy the instance points at changes.

What differs

A reporting system has to hold each of the following per entity, not per group.

The risk margin. The Insurance and Reinsurance Undertakings (Prudential Requirements) (Risk Margin) Regulations 2023 cut the UK cost of capital rate to 4 percent from 31 December 2023, with a tapering factor of 0.9 for life and 1.0 for non-life obligations and a floor of 0.25. The EU rate in Delegated Regulation (EU) 2015/35 stays at 6 percent until Directive (EU) 2025/2 applies on 30 January 2027 and lowers it to 4.75 percent with a time dependent element of its own; our article on Directive (EU) 2025/2 has the detail. The same UK liabilities carry two risk margins now, and two closer ones after that date.

The matching adjustment. PS10/24 reformed the UK matching adjustment from 30 June 2024: wider eligible assets, a senior manager attestation on the adjustment claimed, and the MALIR return due 130 business days after the year end. The EU matching adjustment is unchanged.

The curves. Since 31 December 2020 the PRA has published its own technical information every month, on or before the eighth working day: risk-free rate term structures, fundamental spreads, volatility adjustment portfolios and the symmetric adjustment to the equity capital charge, for GBP, USD, EUR and CAD from 1 January 2025. EIOPA publishes its own set each month. The UK entity discounts with the PRA curve in its solo return and with the EIOPA curve in the group consolidation.

The templates. PS3/24 removed a third of the package and renumbered the survivors from S and NS to IR, with IRR for ring-fenced funds. The mapping table below lists the pairs.

The portals and taxonomies. Every Solvency UK return goes through BEEDS on the Bank of England Insurance Taxonomy: 2.0.2 for reference dates from 31 December 2025, 2.1.0 for firms in scope of liquidity reporting from 30 September 2026, 2.2.0 from the 31 December 2026 reference date. Each EU entity files to its national supervisor’s portal, with that authority’s add-ons, on EIOPA taxonomy 2.8.2 through the annual 2026 submission and 2.10.0 from Q1 2027. Neither portal accepts the other’s taxonomy.

The deadlines. The EU counts weeks under Article 312 of the delegated regulation: five and fourteen for solo entities, eleven and twenty for groups. The PRA counts business days: 30 and 70 for solo firms and branches, 55 and 100 for groups.

Mapping the core S templates to the IR templates

The table pairs each EU solo template in the routine return with the closest PRA template. The EIOPA links go to our pages on the annexes of Implementing Regulation (EU) 2023/894, the PRA links to our pages on the PS15/24 instructions.

A matching code does not guarantee a matching cell. PS18/26 adds rows and columns to IR.05.04 and renames own funds items in IR.23.01 to IR.23.04 from the 31 December 2026 reference date, while EIOPA’s taxonomy 2.10.0 deletes S.21, S.23.02, S.23.03, S.29, S.30.01 and S.30.02 at solo level from Q1 2027. Group templates follow the same logic: an EU group files the group variant of S.02.01 and S.32.01 for the scope of the group, a PRA group files IR.02.01 and IR.32.01. Our Solvency II QRT list has the full EU set with frequencies.

One quarter end in one calendar

Take the 30 September 2026 reference date for an EU group with one UK subsidiary, all on a calendar year. The EU dates come from Article 312 of Delegated Regulation (EU) 2015/35 and the six extra weeks for groups in Article 373. The PRA dates follow the 30 and 55 business day rules in the PRA’s reporting schedule for a 31 December year end. That schedule runs to the 30 June 2026 reference date at the time of writing, so the two Q3 dates below are counted on its rule; there is no bank holiday in England and Wales in the window.

Read the table as a sequence. The asset master and the claims extract close once, in early October. Both sets of curves arrive within two weeks, so the two SCR runs and the two risk margins for the UK entity are produced in the same week. The EU solo entities file on 4 November, the UK subsidiary on 11 November, and its IR.02.01, IR.12.01, IR.17.01 and IR.25.04 are the figures the group team traces into the group S.02.01 and S.25.01 by 16 December. The reconciliation has a five week window and starts from a return that has already passed BEEDS validation.

The annual return follows the same order with longer gaps. For the 31 December 2025 reference date the EU solo return was due on 8 April 2026 and the PRA solo return on 13 April 2026; the EU group return on 20 May 2026 and a PRA group return on 27 May 2026.

Design principles for one data set

Four rules make that calendar workable.

One asset master. Every position is loaded once, with ISIN, CIC, LEI, issuer group, currency and country, and S.06.02 and IR.06.02 are two views of it. Where the instruction sets diverge, as they do on NACE 2.1 from 2027, the master carries both codes and each template picks its own. Claims work the same way: one triangle per line of business, two output templates.

Entity specific parameters. The UK entity carries the PRA curve, the PRA symmetric adjustment, the UK risk margin parameters and, if it has one, its matching adjustment portfolio under PS10/24. The EU entities carry EIOPA’s. The group consolidation of the UK entity carries EIOPA’s again, because the group return is an EU return. Parameters belong to the entity and the regime, never to the installation, so one calculation engine produces IR.25.04 for the PRA and the UK contribution to S.25.01 for the group supervisor from the same inputs.

Two taxonomy packages. The software holds the current EIOPA and Bank of England taxonomies side by side, plus the previous version of each for resubmissions, and picks the entry point from the entity and the reference date. From January 2027 that means four live versions.

One validation log. Both regulators run taxonomy assertions plus their own business rules, and BEEDS returns errors 100 lines at a time. Running the EIOPA rules, the Bank’s rules and any national add-ons locally, before upload, and keeping the results in one log per entity and reference date means the group team sees which UK cells were corrected and why before it consolidates them.

Where this lands in the software

QRT Tool, BOE Tool and SCR Tool share the data layer. Groups define all their legal entities under one account and choose the entity at logon, one username with multiple access. Data comes in from databases, Excel files and CSV files through import definitions whose transformations are set up once and used quarter after quarter, year after year, and several sources can feed several templates. QRT Tool builds the EIOPA package and BOE Tool the Bank of England package, each with the regulator’s validation rules, national specific validations where an authority has defined them, and resolvers that correct the common errors. SCR Tool imports the asset list from QRT Tool and lets a UK entity use the risk-free term structures and symmetric adjustment published by the PRA instead of EIOPA’s. SmartData fills missing asset fields in S.06.02 and IR.06.02 from more than 13 million securities and the GLEIF data.