Technical problem due to validation

The current validation logic effectively forces the submission of an incomplete and therefore factually incorrect report, as only one participation can be reported per investor. We kindly ask you to review this issue and inform us promptly how institutions should proceed in this case. Please confirm whether an adjustment of the validation rule is planned or whether there is an alternative approach to correctly reflect our group structure.

According to the reporting requirements, template Z_01.02 is intended to reflect the full ownership structure of the group. This includes all participation relationships. A key aspect of our group structure is that a single legal entity (e.g. the parent company) may act as an investor in multiple subsidiaries.   Template Z_01.02 is structured such that each row represents a single ownership relationship (investor → investee). To correctly reflect the situation described above, it is essential to list the parent company as the investor (columns 0010/0020) in multiple rows, each time in combination with the respective participation (investee, columns 0040/0050). However, we observe that an explicit validation rule enforces the uniqueness of column 0020 (Investor Code) across all rows of the template. This validation rule directly contradicts the requirement to report a complete group structure. It makes it technically impossible to report an entity that holds more than a single participation.