Reporting Templates

In case the undertaking neither holds "subordinated mutual members accounts", "preference shares", "subordinated liabilities", "Other items approved by supervisory authority", "Own funds from the financial statements ... ", "ancillary own funds", "RFFs" or "MAPs" we believe it should be possible to be excepted from reporting S.23.04 without a special justification. This is currently not the case. We would suggest to add a new option in S.01.01 R0440 for this, named something like "Not reported, as no such items are part of the own funds".

It is not very uncommon for small companies not to have anything in this template, and it seems unnecessary to require reporting an empty template or require the small companies to apply for a formal exception. Validations could be added, to check if this template is reported in case any of the items in S.23.01 are non-zero, to avoid incorrect use of this exception.