Intra-group transactions (IGTs) to be reported regularly in S.36.01, S.36.02, S.36.04, in accordance with Article 245 of the Solvency II Directive, should be those as defined in Article 13 point 19 of Directive 2009/138/EC, according to which IGT means "a transaction by which (re) insurance undertaking relies, either directly or indirectly on other undertakings….” and that are performed by insurance and reinsurance undertakings within a group. Therefore, only IGTs in which at least one insurance or reinsurance undertaking is involved, either directly or indirectly, are subject of reporting obligations under Article 245 of the Solvency II Directive.

Please note that as clarified in the Instructions of the templates, “when there is a chain of related IGTs (say A invests in B and B invests in C), each link of the chain needs to be reported as a separate IGT”. This is applicable when the insurance and reinsurance undertaking involved relies, either directly or indirectly, on other undertakings, e.g. if A is an insurance undertaking, B is an insurance holding company (IHC) and C is a mixed activity holding company (MAIHC).
Information about the transactions which do not fall under the scope of the above mentioned definition may be systematically requested in addition by the relevant supervisory authority on the basis of Article 254 of the Solvency II Directive, according to which supervisory authorities shall have access to any information relevant for the purpose of group supervision, regardless of the nature of the undertaking concerned. In particular, considering recital 109 of the Solvency II Directive, by which supervisory authorities should be able to exercise supervision over risk concentrations and intra-group transactions, taking into account the nature of relationships between regulated entities as well as non-regulated entities, including insurance holding companies and mixed activity insurance holding companies, and take appropriate measures at the level of the insurance or reinsurance undertaking where its solvency is being or may be jeopardised, the IGTs between an IHC, MAIHC or mixed financial holding company (MFHC) may be requested to be reported systematically together with the other IGTs.