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While reviewing the EIOPA Q&A responses, we observed a specific clarification in Q&A 2748. The response explicitly confirm the older answer for the Q&A 1074, which allows for the addition of more than one row for each Product ID code in the Portfolio table, referring to the possibility to report a product with different country codes (C0080). This practice was accurate up to Taxonomy 2.7.0,

We are seeing classification by Bloomberg CIC Code Identifiers of Development Finance Institutions (DFI) to be 21. We are working with a European-based Development Finance Institution (DFI) fully owned and regulated by a European government and acting on behalf of this government. We would like to know your approach to such CIC code classification for Development Finance Institution. Would you classify it be as 1 (Government ) or 2(Corporate)?

Regards the changes to S.29 guidance for 2.8 and the associated LOG guidance (in the draft business package supporting SII taxonomy 2.8.0). Two questions/observations that we seek clarity on:
1) Captives can have an exemption from S.29.01 but the S.01.01 R0600 options are not updated to reflect this (in LOGs or hierarchy CN_15).

Concerning Information on Derivatives PF0801.24 C0440 Swap Delivered & C0450 Swap Received. Should C0440 & C0450 be filled for total return swaps, credit default swaps and swaptions? And if yes, how should these be reported? Especially when the fixed rate can be an index return. Can you please provide us with some examples.

What is the meaning of double reporting using NACE 2.0 and NACE 2.1? Is it related to Solvency II Reporting? Will we have a new version of the templates with one column for issuer code using NACE 2.0 and one using NACE 2.1?

In the Q&A ID 2590, EIOPA states that "the captives' exemption holds only for S.29.01." Please clarify then why the heading of Article 22 of the Commission Implementing Regulation 2023/894 includines only "individual undertakings" and does not include "captive insurance undertakings"? This seems very misleading as I would expect a captive insurance undertaking to only submit those templates which are listed under Articles which include "captive insurance undertaking" in the heading?

We receive many questions from insurance intermediaries on how to determine for group structures whether they are in scope of DORA.
It is not defined in DORA how to calculate whether you meet the 250FTE criterium. We found guidance from the EC in 2003/361/EC on how to calculate whether a firm is small/medium/large and how to consider linked entities and parent entities, but we are not sure if this is the guidance to follow. Can you please provide clarity on these matters?

Can EIOPA please clarify the situation regards reporting exemptions for captives:

1. Firstly, there appears to be errors in the Articles listed in both Article 4(4) and (5). For example, both refer to Article 7, but Article 7 doesn't reference any templates. It looks like it might be that the true set of Articles that should have been listed is one less than that given eg Article 6 instead of 7, Article 8 instead of 9 etc.

Article 19 of the Implementing Regulation 2023-894 specifies required QRTs on SCR information for individual undertakings and captive insurance undertakings, including forms 26 and 27. Article 20 specifies the required QRTs on SCR information for captive reinsurance undertakings and does not include forms 26 and 27. However, Article 24, which applies to individual undertakings, captive insurance undertakings and captive reinsurance undertakings,