The European financial services sector continues to refine its regulatory data-sharing processes to improve transparency and efficiency. On 23 January 2025, FinDatEx (Financial Data Exchange) hosted a comprehensive webinar outlining the transition to the Tripartite Template (TPT) V7. This latest iteration is designed to support evolving Solvency II requirements while minimising operational disruption for the industry.

The Role of the TPT Standard

FinDatEx was established by representatives of the European financial services sector in 2019 to support the development and use of standardised technical templates for data exchange. The TPT standard itself was originally created by asset managers to facilitate fund "look-through" capabilities for their insurance clients.

The template plays a critical role in supporting Solvency Capital Requirement (SCR) calculations through the standard formula and the production of Quantitative Reporting Templates (QRT), specifically S.06.03. Maintained by the Solvency 2 Technical Working Group (Solvency II TWG)—a collective of specialists across Europe—the template is provided entirely free of charge, is not compulsory, and carries no intellectual property rights.

Key Upgrades in TPT V7

Published in December 2024, TPT V7 was developed with a "Costs of change / Benefit approach," resulting in a minimum of changes between V6 and V7. Implementation is recommended for the second quarter of 2025, specifically for the 31 March to 30 June reporting period. The update introduces nine new data points at the end of the template and several crucial modifications:

  • Regulatory Alignment: The addition of a Bail-in-Rules indicator in accordance with Solvency II regulation.
  • Enhanced SCR Calculation: The inclusion of Expected Maturity and related modified/credit durations to improve SCR calculation for debt instruments with multiple possible redemption dates.
  • Administrative Enhancements: New requirements for Custodian LEIs for funds, integration of NACE 2.1 codification, and PIK (Payment-in-Kind) modelling rules.

Navigating Data Quality Challenges

A Q1 2024 survey launched by the Solvency II TWG, which gathered 50 detailed responses representing approximately 120,000 annual templates, shed light on the current state of TPT data quality. While 56.5% of users rated the data as "good/fit for purpose" (needing some minor adjustments) and 30.4% considered it "very good" (providing necessary granularity), the industry still faces significant operational friction. The top three reported issues are:

  • Reporting Delays: Cited by 71.4% of respondents as a major issue.
  • Missing Information: 59.5% of users struggle with missing files or TPT reports.
  • Technical Complexity: 47.6% face difficulties specifically with derivatives instrument modelling.

Real-World Applications and Friction Points

The webinar highlighted real-world insights from both sides of the data exchange equation:

The Investor Use Case: A well-known Austrian Insurance company presented the perspective of an insurance company consuming these reports. Insurers rely heavily on the TPT standard for regulatory reporting (Solvency II, SFDR, EU Taxonomy) and internal asset risk management, as their internal limits operate on a look-through basis. 

Portfolio Context: To understand their data needs, their portfolio consists heavily of Bonds (34.2%) and Real Estate (32.1%), followed by Listed Equity (9.6%), Unit-linked products (8.0%), and alternative investments like Private Equity and Private Debt.

Data Processing & Usage:

  1. Volume: They process about 30 TPT files each month for bond, equity, and multi-asset funds, utilising a tree structure to map fund-of-funds accurately. They process quarterly TPT files for private debt and private equity.
  2. System Integration: Their internal "Portfolio Tool" ingests TPT data alongside asset data from accounting, Bloomberg ratings, and ESG data. They preprocess this daily overnight to calculate yields, durations, and derivative metrics.
  3. Key Takeaways: Even "TPT-light" versions are often sufficient for their needs, mainly requiring investment identifiers and amounts. They note that data and formatting issues occur during the generation phase, not because of inherent flaws in the template itself. Because timing is critical, the insurance company explicitly demands all TPT files by the 10th working day of the month.

The Asset Manager Use Case (Union Investment & SolvencyAnalytics): Operational Frictions

SolvencyAnalytics and Union Investment jointly presented the intense operational pressures faced by producers of TPT files, drawing on real-world implementation experience. Asset managers dealing with complex structures—such as Real Estate AIFs, Securities Funds, and Master Funds—face cascading challenges across three phases of ongoing TPT production:

  1. Data Collection: Asset managers frequently struggle with a dynamically changing fund scope and late or incomplete input data. Furthermore, data formats from sources are often unstable due to manual processing. Compiling fund-of-funds look-through reporting is particularly difficult when third-party TPTs are missing, late, or of insufficient quality.
  2. Report Generation: During production, false or missing data attributes frequently force manual intervention. Producers must also navigate inconsistent data handling regarding FX rates, NACE codes, and LEIs, while incorporating new instruments like crypto into the existing universe. Due to late scope changes, multiple production runs are often required, compounding the pressure of stringent reporting deadlines.
  3. Report Delivery: Dissemination introduces its own hurdles, as one generalised report must often fit hundreds of different recipients. Asset managers frequently encounter formatting issues on the recipient's side, such as localised CSV delimiters or Excel country settings, and must balance conflicting preferences—such as recipients desiring aggregated reports versus a single report per fund.

Looking Ahead

As the industry adopts TPT V7, the Solvency II TWG of FinDatEx will continue monitoring prudential regulation, including the January 2025 amendment of the Solvency II Directive and subsequent delegated acts. The group's future agenda focuses on integrating new sustainability and proportionality frameworks, SCR revisions, and identifying simplifications to address market participants' concerns.