Question ID: 3090
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates, Intra-group transaction
Template: S.36.05
Status: Final
Date of submission: 15 May 2024
Question
We have read EIOPA’s answer in relation to question #2774, and would like to clarify our understanding in regards to the instructions provided to the template S.36.05 in EU/2023/894. In terms of the overlap mentioned between S.36.01/S.36.02 and S.36.05, is it correctly understood then that the instructions in the “General comments” to QRT S.36.05.01 (“This template shall report the P&L associated to all (significant, very significant and transactions required to be reported in all circumstances) intra-group transactions between entities in the scope of the group supervision or P&L transaction considered as significant or very significant intragroup transactions or transactions required to be reported in all circumstances”) should be read in the following manner: This template shall report • the P&L associated to all (significant, very significant and transactions required to be reported in all circumstances) intra-group transactions between entities in the scope of the group supervision; or • P&L transaction considered as significant or very significant intragroup transactions or transactions required to be reported in all circumstances. Reading the instructions this way, the example given in #2774 becomes applicable as a reportable IGT in S.36.05 as it meets with the criteria set in point 1 above – i.e. the P&L is associated to a IGT transaction reported in either S.36.01/S.36.02. While it is still possible that other IGT transactions may also need to be reported in S.36.05 in addition to those under point 1, i.e. transactions that meet with the definitions set under point 2 above. We appreciate if EIOPA can confirm whether this reading is correctly understood.
EIOPA answer
In terms of the overlap mentioned between S.36.01/S.36.02 and S.36.05, EIOPA confirms that the reading is correctly understood, i.e. the templates shall report:
• the P&L associated to all (significant, very significant and transactions required to be reported in all circumstances) intra-group transactions between entities in the scope of the group supervision in S.36.01 or S.36.02;
or
• P&L transaction considered as significant or very significant intragroup transactions or transactions required to be reported in all circumstances in S.36.05, possibly in addition to the ones reported in in S.36.01 or S.36.02.