Regulation 2022/2454 states that for Single economic operation (FC0090) “Where the reported IGT is part of a single economic operation (see point 2.1 ‘general remarks’ above) [groups shall] report the ‘ID of intra-group transaction’ (FC0010) of the related transaction in this cell”. Thus, the reporting instructions do not allow transactions that are part of the same SEO to be reported with a specific ID common to all transactions part of this SEO as the instructions for the column FC0900 mentions that the ID to be reported is the one of the intra-group transaction itself.

The purpose of column FC0090 is to enable the coordinator and relevant competent authorities to identify the transactions that belong to a given SEO. In accordance with the instruction and where several transactions are part of SEO that is identified as a significant intragroup transaction, financial conglomerate shall therefore in principle fulfil column FC0090 for each transaction that is part of that SEO with the ID of all transactions that are related to the corresponding SEO. Considering that in practice, a significant number of transactions could be related to a given SEO, it is also possible in accordance with instruction provided under regulation (EU) 2022/2454 to simply use a unique identifier for each SEO which may be different than the list of the ID of the transactions that are associated with this SEO.