The answer provided below is based on the definition of intra-group transaction under Directive 2002/87/EC and therefore only applies for reporting under Commission Implementing Regulation (EU) 2022/2454 and not for reporting under Commission Implementing Regulation (EU) 2023/894 . 

Article 2(18) of Directive 2002/87/EC defines intra-group transactions as “all transactions by which regulated entities within a financial conglomerate rely directly or indirectly on other undertakings within the same group or on any natural or legal person linked to the undertakings within that group by close links, for the fulfilment of an obligation, whether or not contractual, and whether or not for payment”. Any transaction shifting either directly or indirectly risk from a regulated entity to another entity of the FICO shall therefore be considered as an intragroup transaction and be reported if significant. The ESAs already clarified through 2 Q&A both the definition of intragroup transactions and their expectation on how indirect intragroup transactions shall be reported depending on the nature of the intermediated undertaking: 

• EIOPA Q&A 3065 clarified that intragroup transactions to be reported are the transactions between two entities comprised in the scope of the supplementary supervision pursuant to article 5 of Directive 2002/87/EC where at least one of those entities is a regulated entity as defined under article 2(4) of Directive 2002/87/EC being however specified that in case where a regulated entity of the financial conglomerate is involved in a chain of transactions between two non-regulated entities, each transaction of that chain involving a regulated entity shall be considered as an intragroup transaction
• EIOPA Q&A 3064 clarified expectation for the reporting of indirect intragroup transactions and the intermediary steps that shall be reported or inversely indicated in comments.

The below table summarizes the different cases of intragroup transactions (“IGT”):

For avoidance of any doubts, the concept of “single economic operation” (SEO) is distinct from “indirect transaction” concept and such SEO concept is not expected to be used for identifying several transactions that are “connected” to form an “indirect transaction”. The concept of SEO applies in addition to identify all intra-group transactions transactions, direct and indirect, “which, from an economic perspective (i) contribute to the same risk, (ii) serve the same purpose or (iii) are temporally connected in a plan, shall be considered a single economic operation”.