Question ID: 820
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 19 Oct 2016
Question
It is given as part of Notes that "For non-EEA undertakings and non-regulated undertakings within the group, the identification code will be provided by the group according to one of the two predefined patterns".
We understand that the two patters provided here apply only to non-EEA and non-regulated undertakings which do not have LEI codes. In case these undertakings have LEI code then these need to be reported with the pattern "LEI/Code". Can you please clarify our understanding?
EIOPA answer
Yes, LEI code should be a priority and actually according to EIOPA Guidelines on the use of the Legal Entity Identifier (LEI) we do expect all entities in the scope of the group as defined under article 212 (1) (c) of Solvency II Directive, on which information is required under their reporting obligations to have a LEI code.
However, if that is not the case, the alternative pattern should be used.