The fact that the property is in own use is not determinative. What matters is that the ancillary services undertaking is intended to assist the insurance or reinsurance undertakings. Owning and/or managing property means in most of the countries, to manage for the purpose of the insurance or reinsurance undertakings only (excluding for the benefits of third parties). In S.32.01 (G01) a real estate holding company or an insurance intermediary can be classified as “an ancillary services undertaking” if the definition in Article 1 (53) of the Delegated Regulation is met (#10) or otherwise as “other” (#16 for preparatory phase and #99 in the final instructions). In case of doubt, any specific classification has to be discussed between each group and the group supervisor.