Validation rules v2815_m to v2823_m between FINREP and AE

Are validation rules v2815_m to v2823_m between FinRep and AssetEncumbrance plausible if an institution has to report significant portfolios as 'held for sale' in accordance with IFRS 5, in particular taking into account the intention of AssetEncumbrance?

The intention of AssetEncumbrance, as defined in the ITS and according to the structure of the templates, is the survey of encumbered assets with a focus on financial instruments and ‘other’ assets (whereas not the balance sheet categorization according to IFRS 9) as well as the underlying types of contracts. The information from FinRep balance sheet is referenced only for the purpose of verifying completeness. However, this constitutes a break with the intention of AssetEncumbrance if the volume of the financial instruments is generally equated with the volume under the respective IFRS 9 categories, but the reporting entity has to separate financial instruments in balance sheet item ‘held for sale’ (F01.01; col 010; row 370) due to IFRS 5 regulations. This circumstance affects the product-specific validations v2815_m to v2823_m between FinRep F01.01 and the template 'AE-Assets'. Our opinion is that financial instruments, even if they have to be shown under 'held for sale' for FinRep, still have to be assigned to their original product type in AssetEncumbrance. This results, due to the different presentation, in shifts between the mentioned validation rules. Of course, this does not affect the validation with regard to the total sum of all assets according to FinRep with the total sum of all products according to template 'AE-Assets' (v2814_m).