Reporting ring-fenced funds: S.01.03, the RFF and MAP columns in S.25.01, and the validations that bite

A ring-fenced fund changes the shape of a Solvency II submission before it changes a number. The undertaking flags it in S.01.02, registers it in S.01.03, files a second set of templates for the fund and for the remaining part, and reports the lost diversification in S.25.01. This article goes through that filing cell by cell: the S.01.03 rows, how the fund number and the remaining part are coded, which templates get an SR variant, where the adjustment sits in S.25.01, and which EIOPA business validations reject the package when any of it disagrees. It uses the numbers from our explainer on ring-fenced funds under Solvency II: a fund with a notional SCR of 30, a remaining part of 70, an adjustment of 8 and an SCR of 100. RFF Tool populates these templates from the notional SCR calculation, and QRT Tool validates them before submission. Template codes follow Implementing Regulation (EU) 2023/894; rule codes come from the EIOPA list of validations for taxonomy 2.8.2.

Two flags start the chain

S.01.02 R0150 says whether the undertaking reports activity by ring-fenced funds (1 yes, 2 no) and R0170 whether it uses the matching adjustment. If either is 1, BV353 requires S.01.03 to be reported, so S.01.01 R0020 must show 1, and BV337 requires SR.01.01, the content template for the fund level, with every SR filing indicator row from R0790 to R0940 filled. TV0_2 then compares S.01.01 R0020 with the filing indicator actually present in the instance for S.01.03. All three are errors, so the package bounces rather than being queried.

S.01.03: the register

S.01.03 is annual and lists every ring-fenced fund and matching adjustment portfolio, material or not. The first table has one row per fund. C0040 is the fund or portfolio number: the undertaking chooses it, it stays the same from year to year, and every other template uses it to point at the fund. C0050 is the name, unique and stable. C0060 is the type: 1 ring-fenced fund, 2 matching portfolio, 3 remaining part of a fund. C0070 says whether other funds are embedded in it (1 yes, 2 no; only the mother fund gets 1), C0080 is materiality (1 or 2) and C0090 the Article 304 status: 1 under Article 304 with the equity risk option, 2 without it, 3 not under Article 304.

The second table is for nested funds: C0100 repeats the mother fund’s number, C0110 gives the embedded fund’s number and C0120 its nature (1 ring-fenced fund, 2 matching portfolio). The general comments say when this arises. Where a matching adjustment portfolio does not cover the whole ring-fenced fund, three funds are registered, the ring-fenced fund, the matching portfolio inside it and the remaining part of the fund with type 3, and the second table records the relation. BV1735 requires C0050 to C0090 on every row, BV1280 rejects a fund that appears in the second table without a row in the first, and BV1436 warns when C0070 is 1 with no row in the second table.

Which templates are filed per fund

Each material fund and the remaining part file their own versions of the balance sheet, the technical provisions and the SCR templates. They carry an SR prefix in the full list of Solvency II QRTs, and their filing indicators sit in S.01.01 rows R0790 to R0940.

The S.25.01 and S.26.01 instructions add that a fund with another fund embedded is treated as separate funds, one SR template per sub-fund from the second table of S.01.03. An immaterial fund files none of this. It still sits in S.01.03 with C0080 set to 2, and its restricted own funds are deducted in full under Article 81(2) of Delegated Regulation (EU) 2015/35.

How the fund number and the remaining part are coded

Every SR template opens with two Z cells. Z0020 says whether the figures belong to a fund or to the remaining part: 1 is RFF/MAP (plain RFF in SR.02.01, since the balance sheet is not split by matching portfolio) and 2 is the remaining part. Z0030 is the fund number, attributed by the undertaking, consistent over time and equal to C0040 in S.01.03. SR.02.01 adds one rule the others leave implicit: when Z0020 is 2, the fund number is reported as 0.

In the XBRL instance these Z cells are dimensions on the context, not part of the filing indicator. SR.25.01 gets one filing indicator for the whole template; the facts for fund 1, fund 2 and the remaining part are told apart by the fund number dimension behind Z0030. A fund typed as 01 in one system and 1 in another therefore becomes two funds in the instance, which is why the validator has a rule per SR template that the fund number must be present. The number also appears in the list of assets: S.06.02 C0060 carries it for every asset held in a ring-fenced or other internal fund. A stricter rule, BV1193, required every fund number in S.06.02 to exist in S.01.03; EIOPA deactivated it on 26 March 2025, though the instruction to keep the numbers consistent still stands.

S.25.01: the rows and columns that carry the adjustment

The whole-undertaking S.25.01 is where the lost diversification is reported. Where the undertaking has funds or matching portfolios outside Article 304, the module charges are not the sums of the notional SCRs. They are calculated as if no diversification was lost (full recalculation) or by direct summation at sub-module or module level (the two simplifications), and the gap between the true SCR and that figure goes into one row.

Rows R0010 to R0050 hold market, counterparty default, life, health and non-life underwriting risk. C0030 is the net charge, C0040 the gross charge before future discretionary benefits, and C0050 the allocation of the RFF adjustment to that module, which must be positive. R0060 is diversification, negative, and R0100 the basic SCR. R0120/C0100 is the adjustment due to RFF/MAP nSCR aggregation, positive. R0130 to R0160 carry operational risk, the two loss-absorbing capacities and the Article 4 pension charge; R0200 is the SCR excluding add-ons and R0220 the SCR. The lower block summarises the funds: R0410 the notional SCR of the remaining part, R0420 the sum over ring-fenced funds, R0430 the sum over matching portfolios, R0440 the diversification credit for Article 304 funds and R0450 the method: 1 full recalculation, 2 simplification at sub-module level, 3 at module level, 4 no adjustment.

The C0050 allocation follows a formula in the instructions: a factor q equals the adjustment divided by the basic SCR at C0040/R0100 less the intangible assets charge at C0040/R0070, and each module gets q times its own charge. Our worked example on the notional SCR and the diversification adjustment runs it to three decimals; here the figures are rounded so a reader can check them by hand.

A worked filing example

The explainer’s undertaking has one material with-profits fund and a remaining part, two risk modules correlated at 0.25, and no operational risk or loss-absorbing adjustments. The fund carries market risk 27 and life underwriting risk 8, a notional SCR of 30. The remaining part carries 12 and 66, a notional SCR of 70. Summed at module level the undertaking shows market 39 and life 74, which aggregate to 92. The adjustment is 100 less 92, so 8, and q is 8 divided by 92, about 0.087. Restricted own funds in the fund are 50, so 20 exceeds the notional SCR and is deducted.

Two cells deserve a second look. The C0050 allocations add up to 9.8, not 8, because q multiplies each module’s undiversified charge; the instruction defines it that way, and no rule in the current list adds C0050 back to R0120. And BV134 holds only because R0100 is the as-if-one figure of 92. Writing the sum of notional SCRs, 100, into R0100 and 8 into R0120 gives 108 at R0200 and an error. On the own funds side, S.23.01 R0740 holds the adjustment for restricted own fund items, 20 here, and BV2027 warns when the excess of assets over liabilities in R0700 differs from R0730 plus R0740 plus R0760.

The validations that bite

These rules come up in RFF packages more than any others. Every code is taken from the EIOPA list of validations for taxonomy 2.8.2, hotfix edition, last updated on 3 June 2026, and none of them is deactivated.

Almost none of these rules test the calculation. They test whether the fund exists consistently across the package. The register is typed into one system, the SR templates come out of another and the list of assets from the custodian, so C0040 drifts from Z0030 and from S.06.02 C0060. The S.01.01 is copied from a year before the fund existed and the SR rows stay empty. The fund’s balance sheet is loaded with the fund name as its key and Z0030 is never set. Our post on EIOPA validation errors and how to read them covers the filing indicator and decimals rules that apply to every package.

Two checks have no code. The instructions say R0120 and every C0050 cell shall be positive, and that R0450 may only show 4 when the undertaking has no ring-fenced fund or only Article 304 funds. A negative adjustment, or a switch from method 1 to method 3 between quarters with no change in the funds, reads as a data quality problem whether or not a rule fires.

Do groups report differently?

Groups file the same two tables in S.01.03.04, and BV687 requires the template when the group reports by ring-fenced fund or uses the matching adjustment and consolidates with method 1 or a combination of methods 1 and 2. BV1281 and BV1584 are the group versions of the second-table and all-columns checks, and the group S.25.01 carries the same R0120, R0410 to R0430 and R0450. The group taxonomy lacks a full set of SR templates: the tables referenced by the 2.8.2 validations show group variants only for SR.01.01, SR.25.01, SR.25.05, SR.26.01 and SR.26.08, so the fund’s balance sheet and technical provisions are reported by the solo entity that holds it.

Where this lands in the software

RFF Tool runs the standard formula for every ring-fenced fund, every matching adjustment portfolio and the remaining part in one pass, fixes the scenario direction at undertaking level and produces the notional SCRs, the as-if-one figure and the adjustment together. Assets prepared for the list of assets and the look-through are split into risk buckets per fund, and the liability importer takes structured data on liabilities, funds and exposures for each balance sheet. The results are mapped to the templates and transferred to QRT Tool with one click, which fills S.01.03, the SR templates with the fund number in Z0030 and the S.25.01 adjustment rows from the same data. QRT Tool then runs the EIOPA and national specific validations, and its resolvers correct the common errors automatically. A finished template can be locked and sent for review, and multi-entity support keeps each fund-holding entity in a group separate.