Having been contacted by a German market participant, we submit the following question to the Q&A process:

“Template S.39.01 requires semi-annual reporting of profit or loss after taxes as in Directive 91/674/EEC, Article 34, III., Item 16. As consolidation requirements under Solvency II differ from consolidation requirements under statutory accounting rules we wonder, which consolidation scope is relevant for this template at group level. As Solvency II does not require the calculation of profit or loss as in Directive 91/674/EEC, Article 34, III., Item 16, it would be unduly burdensome to require the calculation of profit or loss for the group under Solvency II solely for this template. Are we therefore correct in assuming that profit or loss as reported in the financial statement has to be reported? We assume this as the position is called “Statutory Accounting: Profit & Loss”.”