Question ID: 1120
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.36.01
Status: Final
Date of submission: 02 Jul 2018
Question
Do we include corporate members (where participation is held either 100% or less) in the scope of Intra-group transactions reporting for the S.36.01 - S.36.04 annual QRTs?
EIOPA answer
The QRTs reporting templates for Intragroup Transactions (IGTs) have their own reporting objective which is different from that Premiums, Claims and Expenses QRTs.
As indicated in the Group QRT log files on IGTs (S.36.01- S.36.04), the transactions with a related undertaking within the Group should be reported (e.g. as long as a Solvency II insurance entity is part of the transaction chain, these IGTs should be reported). Consequently, if a managing agent (100% or less) enters into an IGT with a Solvency II entity that is part of the group – then this should be reported. If the managing agent enters into an IGT with the holding company or another entity that is not a Solvency II entity, and this is not part of a recognisable chain that ultimately impacts on the insurer, then this should not be reported.
Please also note that National Competent Authorities can ask for IGTs for other entities in the insurance group to be reported systematically together with the other IGTs. For instance, if the group supervisor requires the managing agent to be included in the IGT reporting, it can do so. In that regard, we advise you to contact your National Competent Authority if any queries about any additional reporting requirements on IGTs.
Finally, please refer to the detailed answer on this subject previously published by EIOPA (see Q&A 490 on the Commission Implementing Regulation (EU) 2015/2450 of 2 December 2015) which provides you with more granular information on this subject.