We ask a confirmation about the financial guarantee that shall be reported either in:
•    S.03.01 related to Off-balance sheet items; or
•    S.36.04 related to IGT.

S.03.01 is asking not to report ‘internal guarantees within the scope of the group’.
In our interpretation, internal guarantees are those where both guaranteed and guarantor are companies within the same Group regardless the beneficiary.
With the same logic as above, we would populate S.36.04.
Can you confirm the abovementioned interpretation?

In addition, within S.03.01, how the guarantees where the reporting entity is the beneficiary are to be reported?
a. as financial guarantee received
b. as collateral
c. other

EIOPA answer

We confirm that off balance sheet guarantees being an intra-group transaction falling under reporting obligation should be reported in S.36.04. We also confirm that the parties to the transaction are an entity receiving the guarantee and an entity providing a guarantee. Information regarding the entity receiving guarantee should be provided in C0020, C0030 and C0040. Information regarding the entity providing guarantee should be reported in C0050, C0060 and C0070.

In S.03.01, where the reporting entity is the beneficiary of the guarantee, the guarantee should be reported in R0030 as “Guarantees received by the undertaking, including letters of credit.