In relation to QRT S.01.01.b, the definition of cells A6 and A7 where the reporting entity should indicate if it is reporting QRT S.12.01.b and QRT S.17.01.b, indicates the following close list:
- Not reported o/a no life and health SLT/non-life business;
- Not reported o/a materiality threshold;
- Not reported other reason (in this case special justification is needed).
The third option (Not reported o/a materiality threshold) can be interpreted as if the reporting entity mighty be exempt on reporting the QRT for materiality threshold reasons. We suppose that the threshold relates to the additional information reported (BE by Country). Nevertheless, neither the Technical Annex I nor Technical Annex II on these QRT indicates possible exemption of reporting the entire QRT. Could you clarify if an entity can be exempt on reporting these two QRT?
A second question would be, if the last option is chosen, where should be reported this special justification? In the same cell (that would mean that the close list is not actually closed). Or elsewhere?
A third question would be, the language of the close list. Can, for example, a Spanish company report the close list in Spanish, or should always use English?
The close list of cells A6 and A7 of S.01.01.b are wrong. In fact the option referring to materiality threshold should not be considered.
In the cases where a justification is needed, the justification should not be given in the template itself but be part of the dialogue between undertakings and NSA.
In future all close lists, as part of the LOGs, will be translated into all languages. For this reason, in the future package the options will also be identified with numbers to facilitate any comparison needed between different languages.