The public consultation on the European Insurance and Occupational Pensions Authority’s (EIOPA) Discussion Paper for its upcoming report on integrated data collection formally concluded on June 10, 2026. This initiative represents an important step toward modernising the supervisory reporting landscape across the European Union.

This Discussion Paper is part of a broader, coordinated European Commission mandate aimed at streamlining data collection and reducing compliance duplication across the financial services sector. As part of this initiative, the European Securities and Markets Authority (ESMA) was similarly mandated to optimise its data collection frameworks. Following its own public consultation performed in 2025, ESMA has already advanced further in this process, releasing its Final Report on the integrated collection of funds' data on May 4, 2026. This milestone establishes the regulatory direction for the fund management industry, though the specific operational details remain to be seen.

The intersection between the EIOPA and ESMA reporting frameworks is of high macroeconomic significance. According to the official EIOPA statistics as of Q4 2025, European insurers manage a total investment universe of €9.70 trillion. Within this total, Collective Investment Undertakings (CIUs) represent a substantial 36% of total assets, translating to more than €3.5 trillion allocated into funds. These figures clearly indicate that the operational efficiency of the cross-sectoral data exchange between the fund and insurance industries is essential to ensure transparency for both risk management and regulatory reporting.

At SolvencyAnalytics, we believe that the harmonisation of these two frameworks is fundamental for driving operational efficiency, elevating data quality, and ensuring long-term transparency across both the insurance and fund industries. To help shape a future architecture for European regulatory data that reflects real-world workflows and known challenges, we actively participated in this EIOPA consultation. Our formal submission draws upon the practical insights we have gathered over more than ten years as a regulatory reporting service provider for fund managers and insurers across Europe.

Relevance for Fund Look-Through Reporting

Based on our day-to-day data management and regulatory reporting for insurers and collective investments, our response to the consultation focused on the specific challenges related to data exchange between the asset management and insurance sectors, as well as related data ownership considerations. We highlighted several persistent issues that we believe are important to be addressed within an integrated data collection model.

1. Validation at Source and Data Ownership

Insurers currently face the disproportionate burden of validating look-through data over which they lack direct operational control. This stems from a fundamental mismatch in data ownership and regulatory accountability: while the data ownership for fund look-through rests with the fund managers, the legal reporting obligation resides with the insurance investors. Consequently, when data errors are discovered during the insurers' regulatory filing process, the actual data owners (the fund managers) are rarely notified. As a result, these issues are often addressed only through temporary, one-off patches by the insurer, leaving the root errors unfixed in future data deliveries.

Under current market practices, insurers receive look-through data from fund managers, often in the FinDatEx Tripartite Template (TPT) format. While the TPT is the established market standard, it operates as a voluntary client service performed by fund managers and their service providers. This means data quality, completeness, and delivery timelines remain subject to bilateral commercial goodwill, forcing insurers to assume regulatory risks for data they do not own and cannot independently verify.

To ensure long-term reliability, any future data exchange model - regardless of its specific format - should incorporate formal supervisory validation and enforcement mechanisms directly at the level of the originating fund manager. Enforcing standardised validation rules directly at the point of origin before dissemination would eliminate the systemic reconciliation loops that currently strain insurers’ operations and risk departments.

2. Cross-Sectoral Alignment of Data Dictionaries

Material inefficiencies arise from mapping similar economic concepts across different regulatory regimes. In our view, cross-sectoral integration requires a harmonisation of the underlying data dictionaries used by EIOPA and ESMA. Greater alignment of core reference data across both frameworks would represent a major step forward in eliminating reporting redundancies and mapping uncertainties.

Significant operational friction currently stems from conflicting asset classifications and misaligned data attributes across the two regulatory frameworks. In practice, reconciling EIOPA’s Complementary Identification Codes (CIC) with ESMA’s Classification of Financial Instruments (CFI) codes would require complex, error-prone translation tables. This friction is particularly pronounced for over-the-counter (OTC) derivatives and structured products, where technical variations in how mandatory attributes are reported under differing standards can have a significant impact on risk calculations. Aligning these underlying dictionaries and data attributes is a prerequisite for automated, frictionless cross-sectoral reporting and robust risk management.

3. The Fund-of-Funds Dependency and Timeline Compression

Look-through challenges are strongly amplified within fund-of-funds structures. Target funds are often not in a direct client relationship with the ultimate insurer and do not receive these data requests directly, leading to unclear responsibilities across market participants, data fragmentation and often resulting in incomplete or delayed data delivery.

Because data requests must pass sequentially through multiple layers of intermediaries, the reporting chain suffers from various operational bottlenecks:

  • Timeline Compression: Each layer of intermediation introduces delays, frequently leaving service providers and insurers with only a very short time window to aggregate, validate, and produce the final Solvency II output before strict regulatory deadlines.
  • Lagged Valuations: If look-through data is not available at the date of the regulatory report production, insurers are frequently forced to rely on stale, lagged valuations or proxies compromising the accuracy of Solvency Capital Requirement (SCR) calculations and transparency reporting.
  • Broken Audit Trails: Without a standardised regulatory framework, the data transmission chain frequently breaks as information passes through multiple fund-of-funds’ service and data providers.

4. Data Licensing Frameworks and Intellectual Property

Third-party proprietary data, including credit ratings and index reference data, represents a substantial cost and legal barrier. To complete comprehensive risk reporting (such as interest rate risk, spread risk, and market risk concentrations), look-through data must be enriched with external reference data, including official credit ratings, benchmark index constituents, and specialised asset identifiers.

Currently, global data vendors often enforce rigid intellectual property licenses that prohibit the redistribution or secondary processing of this data. This forces insurers, fund managers, and service providers into redundant, highly expensive licensing overlaps and introduces legal uncertainty regarding data ownership. Clearer regulatory guidance or exemptions regarding the permissible redistribution of data for regulatory compliance will be key to reducing legal uncertainty and eliminating commercial barriers to transparency.

Looking Ahead: Managing a Staggered Timeline

While the conclusion of EIOPA’s public consultation marks an important milestone, the implementation of a fully integrated cross-sectoral framework remains a long-term prospect. Under the European Commission’s broader mandate, ESMA’s own timeline for implementing its newly proposed integrated fund reporting framework is not expected to take effect before 2029.

Given the deep operational dependencies between the two sectors, EIOPA’s integrated data collection model is likely to follow a similarly extended trajectory, with formal implementation expected even later.

However, market participants cannot afford to remain passive. The structural changes being debated today regarding validation at source, standardised data dictionaries, and data licensing may fundamentally alter reporting workflows. For insurers and fund managers alike, tracking this regulatory evolution now provides the foresight needed to evaluate existing operating models and plan for these changing requirements over a longer time horizon.

If you would like to discuss how these shifting regulatory frameworks and look-through challenges might impact your reporting workflows and future regulatory reporting requirements, please contact our team at info@solvencyanalytics.com.