Solvency II taxonomy 2.10.0: the templates that go, the ones that arrive, and what to test before Q1 2027
EIOPA intends taxonomy 2.10.0 for Q1 2027. Which templates are deleted, which change frequency, the new S.22.07, S.27.02 and S.27.03, and what to test.
In this article
EIOPA intends taxonomy 2.10.0 for Q1 2027 reporting. Published on 3 July 2026, it reflects EIOPA’s proposed amendments to the reporting ITS. The taxonomy and final report do not themselves enact those changes. The proposed changes have legal effect only to the extent included in an adopted and published ITS. This article lists what the release contains, which templates go, change or arrive, how the transition from 2.8.2 is intended to work, and what a reporting team should test. It is written from the release notes and EIOPA’s final report, and is the checklist we work through when preparing QRT Tool, our XBRL reporting software for a new taxonomy.
What a taxonomy release contains
A taxonomy release is a package. The Data Point Model, or DPM, is the business layer: the dictionary and the annotated templates map every cell of every template to a data point with dimensions, so a row and column in S.02.01.02 means the same thing to every filer and every supervisor. The XBRL taxonomy is the technical form of that model, the schema and linkbase files a filing must reference, split into entry points such as annual solo or quarterly group. The list of validations holds the business and technical rules, numbered BV and TV, that a supervisor’s portal runs against the instance. The filing rules constrain the instance file itself, and the release notes and change log tell you what moved.
The 2.10.0 package
The release notes, document EIOPA-26-488, state that 2.10.0 “is to be used from Q1 2027 reference date” and that the model correlates with the final report EIOPA submitted to the European Commission on 30 March 2026. One detail matters if you have already loaded the public working draft: the package went online on 3 July 2026, but EIOPA kept the date of 30 June 2026 in the taxonomy links and documents so that the final release stays consistent with the draft.
Besides the usual dictionary, annotated templates, validations, taxonomy zip, filing rules and documentation, the package carries two change logs, one against the 2.8.2 hotfix and one against the second public working draft, sample instance documents for every entry point, the final report, and technical instructions for S.30.01 and S.30.02, the facultative reinsurance templates that leave the ITS but stay in the taxonomy for ad hoc requests. The entry points keep their codes: ars with the .01 suffix for annual solo, qrs with .02 for quarterly solo, arg with .04 and qrg with .05 for groups, and the release notes count 89 templates in the annual solo entry point and 11 in the quarterly one.
Two changes affect tooling. EIOPA discontinued support for canonical files with the optional NACE 2.1 hotfix releases and future releases, asking remaining users to switch to zip packages by 31 December 2025. Taxonomy 2.10.0 continues the zip-package approach and completes the move to NACE 2.1 codes introduced as an option in the 2.8.2 hotfix of 30 June 2025.
The templates that disappear
EIOPA’s final report EIOPA-BoS-26/081 deletes eleven solo annual templates and two group ones. The instruction text for each is still in our reporting explanations library, which helps when you have to explain to an auditor why the annual 2026 and annual 2027 packages differ.
| Template | What it reported | Level |
|---|---|---|
| S.21.01 | Loss distribution risk profile | Solo |
| S.21.02 | Underwriting risks non-life | Solo |
| S.21.03 | Non-life distribution of underwriting risks by sum insured | Solo |
| S.23.02 | Detailed information by tiers on own funds | Solo |
| S.23.03 | Annual movements on own funds | Solo and group |
| S.29.01 | Excess of assets over liabilities | Solo |
| S.29.02 | Excess of assets over liabilities explained by investments and financial liabilities | Solo |
| S.29.03 | Excess of assets over liabilities explained by technical provisions | Solo |
| S.29.04 | Detailed analysis per period, technical flows versus technical provisions | Solo |
| S.30.01 | Facultative covers, basic data | Solo |
| S.30.02 | Facultative covers, shares data | Solo |
| S.37.03 | Risk concentration by asset class and rating | Group |
The last reference date for all of them is annual 2026 at the latest. The transition section below explains why it may be earlier. The S.29 family is the one industry asked EIOPA to remove: the final report records the stakeholder estimate that variation analysis can take up to half the effort of preparing the templates in individual cases, and EIOPA added S.29.03 after public consultation. S.30.01 and S.30.02 leave the ITS and the S.01.01 content template, but remain in the taxonomy for justified ad hoc supervisory requests.
The templates that change frequency
| Template | Until annual 2026 | From Q1 2027 |
|---|---|---|
| S.28.01 and S.28.02 (MCR) | Quarterly and annual | Annual only; the quarterly MCR figure comes from S.23.01 |
| S.06.03 (look-through of collective investments) | Every quarter above the 30% threshold | Q2 and Q4 only, same threshold |
| Quarterly set for small and non-complex undertakings and groups | Full quarterly set | Q1 and Q3: only S.01.01, S.01.02 and S.23.01 |
| S.06.02, S.06.03 and S.08.01 | Q4 and annual | Reported in Q4 are not reported again annually, unless the undertaking is exempted from Q4 under Article 35a |
These are proposed frequency changes reflected in taxonomy 2.10.0, subject to adoption of the amended ITS. Less frequent S.06.03 filing may not reduce the underlying workload where look-through data are already refreshed quarterly for SCR recalculation.
The MCR change has a detail that catches people. The proposal retains the quarterly MCR result in the own funds template, S.23.01. An undertaking otherwise exempt from quarterly S.23.01 would still report cell C0010/R0600, the MCR, every quarter. Detailed S.28 calculation inputs would be reported annually, but the MCR itself must still be calculated and reported at least quarterly.
New and amended templates
The release notes describe the DPM changes as “mainly aimed at reducing the reporting burden”, and the new tables are few.
| Template | Change | Who files it |
|---|---|---|
| S.22.07, calculated volatility adjustment and best estimates by country and currency | New; replaces S.22.06 in reporting and in public disclosure, following Articles 51(1c)(b) and 77d of the amended Directive | Solo |
| S.27.02, catastrophe data, loss data | New annual template on natural catastrophe insured losses | Solo, except small and non-complex undertakings and life insurers; reinsurers file it |
| S.27.03, exposure and premium data | New annual template on natural catastrophe exposure | Solo, except small and non-complex undertakings, life insurers and reinsurers |
| S.01.02 | New columns for the risk-corrected spread adjustment, the phasing-in of the extrapolation, long-term use and a long-term equity breach of the SCR | Solo and group |
| S.22.01 | Amended for the phasing-in of the extrapolation under Articles 51(8) and 308f | Solo and group |
| S.23.01, S.23.04, S.25.01, S.25.05 | Matching adjustment changes | Solo and group |
| S.26.01 | Equity under legislative programmes and the securitisation spread risk changes in Articles 173 and 178 of the Delegated Regulation | Solo and group |
| S.27.01 | New countries for flood, hail and subsidence; vehicle policy limit raised from EUR 24 million to EUR 32.4 million; vessel exemption raised from EUR 250,000 to EUR 337,500 | Solo and group |
The simplifications are longer than the additions. S.06.02 loses custodian columns C0120, C0121 and C0122. S.06.04 keeps two of its four cells. S.14.01 loses C0055, C0142 and C0270, S.14.02 loses its country cell, and S.16.01 loses its currency split. S.19.01 loses the reinsurance recoverables triangles, changes Claims Paid/UDBE expense treatment to include only direct claims management expenses (ALAE), adds total other expenses, and reports discounted best estimates by line of business. The S.36 family loses duplicate profit-and-loss data, and S.37.02 changes to specific exposures over total exposures reported in that template. Two thresholds move: S.03.01 is due above 3.5% instead of 2%, and S.04.05 is not reported when the location of risk equals the location of underwriting.
What changes for small and non-complex undertakings
Directive (EU) 2025/2 defines small and non-complex undertakings in Article 13, sets eligibility criteria in Article 29a and provides for supervisory classification in Article 29b; our article on the Directive (EU) 2025/2 explains the process. Under EIOPA’s proposed ITS, classified undertakings and groups would report only S.01.01, S.01.02 and S.23.01 in Q1 and Q3, and would be exempt from S.06.04 and S.27.02/.03. The 2.10.0 DPM implements these proposed exemptions inside the existing entry points. There is no separate module. Until classified by the supervisor, plan for the full quarterly set.
The transition from 2.8.2 to 2.10.0
The final report states EIOPA’s view that the proposed reporting requirements should begin on 30 January 2027, the Solvency II review’s application date. Under current rules, Q4 2026 and annual 2026 QRTs use the current ITS and taxonomy 2.8.2. EIOPA intends Q1 2027 to be the first reporting period for 2.10.0. For solo calendar-year filers, annual 2026 reporting is due in April 2027 and Q1 2027 follows about a month later. Group deadlines are longer, so the two submissions are due around the same time.
EIOPA’s final report proposes exempting the deleted templates from annual 2026 reporting. Check the Official Journal for the adopted text before removing them from that return; the proposal alone does not create the exemption.
On hotfixes, EIOPA’s governance document EIOPA-BoS-24/411 allows one adaptive release a year, final by 30 June, then at most one hotfix, decided by 15 September and published by 25 October. A hotfix keeps the release number and replaces the original before it is used for reporting, so a 2.10.0 hotfix would still be 2.10.0. No 2.10.0 hotfix had been published when this article was written; if one appears in October 2026, it becomes the master version for Q1 2027.
Validations: what to expect on the first run
The release notes report more than 400 XBRL assertions removed with the deleted and amended tables and more than 1,000 added, around three quarters of them checking the probabilities in the cumulative distribution functions of the S.26 templates. The cross-checks between S.04.04 and S.05.01, rules BV1871 to BV1899, are not implemented in the taxonomy, but EIOPA says filers should still respect them. 2.10.0 also adds a custom margin approach to tolerances, in a relative and an absolute variant. Expect a different pattern of failures on the first run, not fewer of them.
Migration checklist for a reporting team
- Load the 2.10.0 package from the zip and keep 2.8.2 installed for the annual 2026 package.
- Work from the change log against the 2.8.2 hotfix. The release notes summarise and the change log lists every moved cell.
- Update the mappings for the deleted templates, the new S.22.07, the amended S.01.02 columns, the S.06.02 custodian columns and the S.14.01 and S.19.01 cells, and confirm every NACE code is a NACE 2.1 code.
- Rebuild the quarterly set: drop S.28.01 and S.28.02, add S.06.03 only to Q2 and Q4, and confirm S.23.01 carries C0010/R0600 every quarter.
- Rerun the full validation list on a 2.10.0 instance built from real Q2 or Q3 2026 data and compare the failures with the same data under 2.8.2.
- Check S.01.01 against the templates present; the deleted templates must be absent and S.30.01 and S.30.02 must not be declared.
- Ask your supervisor when its 2.10.0 test environment opens and make a test submission through the national portal before the Q1 2027 deadline.
- Confirm the taxonomy version in the filing: the entry point reference must point at 2.10.0 for Q1 2027 and at 2.8.2 for annual 2026. A mismatch is rejected before any business rule runs.
Where this lands in the software
QRT Tool can reuse database, Excel and CSV source connections quarter after quarter, but taxonomy changes may still require mapping and validation updates. It applies EIOPA rules and configured national add-ons; resolvers can help address common failures, subject to review. Selected static asset or issuer reference fields in S.06.02 can be enriched from SmartData and GLEIF; users should verify matches and reported values against their records. The planning view holds a deadline per template, and a finished template can be locked and sent to a second person for review. Our XBRL tools page describes the regular updates that follow each taxonomy change, and groups can run every legal entity from one login.
Sources
- Supervisory reporting - DPM and XBRLEIOPA
- Solvency II taxonomy 2.10.0 release notesEIOPA
- Final report on supervisory reporting and public disclosure requirements under Solvency II (EIOPA-26-081)EIOPA
- Governance of taxonomy releases (EIOPA-BoS-24-411)EIOPA
- Commission Implementing Regulation (EU) 2023/894EUR-Lex
- Directive (EU) 2025/2EUR-Lex
- Commission Delegated Regulation (EU) 2026/269EUR-Lex
- Acts & Regulation - Reporting ExplanationsSolvencyTool regulation library