Our insurance group currently reports intragroup equity-type transactions (e.g., capital contributions, dividends) in template S.36.01 according to the instructions in Commission Delegated Regulation (EU) 2023/894. The instructions for field NC0140 – Maturity date state: For intragroup transaction with no maturity date use '9999-12-31'. For perpetual securities use '9999-12-31'. Based on this, our group has applied the convention of reporting 9999-12-31 for equity transactions without a contractual end date. This means that such transactions remain “in-force” and are included in S.36.01 for multiple reporting periods, even though no new transaction has occurred. As a result: • The same transactions are reported year after year in the S.36.01 annual reporting templates, which increases administrative burden. • Materiality thresholds for “significant” or “very significant” transactions are assessed on an accumulated basis for transactions that are deemed to be of the same kind (e.g., capital contributions, dividends), which can trigger additional reporting obligations even when only minor new transactions occur in a given year, as these are assessed collectively/in aggregation with earlier/historic transactions, which have maturity date “9999-12-31”. We wonder however if this is correct? In these capital transactions (which are conventional/unconditional capital contributions and dividends) we would normally deem the transaction to lack a maturity date, as: • Capital contributions represent permanent funding provided by shareholders to the entity. They are not repayable unless there is a formal reduction of capital or liquidation. Therefore, these transactions do not have a contractual maturity. • Dividends are distributions of profits to shareholders. Once declared, they become payable, but they are not considered a financial instrument with a maturity date. They are obligations to pay, but not subject to conditions like repayment schedules. We would deem these transactions to be unconditional and non-repayable under normal circumstances – and lack any “expiry date”. We note that EIOPA Q&A #864 (related to S.36.03 and S.30.03) states: This cell should be left blank in the cases where there is no expiry date (for example, contract is continuous and ends by one of the parties giving notice). Current validations allow this cell to be reported blank. Furthermore, the instructions for S.36.04 (Insurance and Reinsurance) also indicate that the expiry date should not be reported if the contract is continuous and has no end date. This creates an inconsistency between templates: • S.36.01 requires 9999-12-31 for transactions without maturity date. • S.36.04 and Q&A 864 allow the field to be left blank in similar situations. Our insurance group would like to clarify whether the same logic (blank maturity date) can be applied to equity-type transactions in S.36.01, in order to harmonize reporting and reduce unnecessary complexity.

The field can be left empty and there is no validation rule included in the Taxonomy which would prevent it.​