Disclosure Templates

The delegated act (article 317) states that “Aggregated annual statistical data concerning the supervised undertakings and groups in accordance with Article 316 shall be disclosed in respect of each calendar year within three months after the date by which the undertakings having a financial year ending 31 December are required by Article 312(1)(c) to submit annual quantitative templates.” A strict reading of article 317 can imply that NSA have to publish the aggregated data on insurers and on groups at the same time. However, as NSA receive annual quantitative template of groups 6 weeks later than the solo, it would be difficult to disclose aggregated group data at the same date. Can we then consider that the extension of the deadlines established by article 373  (“deadlines referred to in Article 312 shall be extended by 6 weeks” ) for the group is also applicable to NSA disclosures ?