We think that validation BV401 which states that the values of own shares reported on template S.23.02 and S.02.01 should be the same is incorrect. We think own shares reported on S.23.02 should be at nominal value. This is supported by validation BV504 which suggests the value of own shares reported on S.23.02 may be less than the value reported in cell R7010/C0060 in S.23.01.

Furthermore, own shares reported on S.23.02 forms part of paid in ordinary share capital reported in cell R0010/C0010 of S.23.02, which we think should be consistent with ordinary share capital reported in cell R0010/C0010 of  S.23.01.

Ordinary share capital reported in cell R0010/C0010 should be at nominal value in order for the share premium to be meaningful. Own shares have been reported using a solvency II value on the balance sheet template S.02.01, applying the principles of Article 75 of Directive2009/138/EC, in accordance with the S.02.01 general comments section of the Annex III to the implementing Technical Standard on group reporting. The validation will therefore fail.