Reporting Templates, Validations

Why is Issuer Group (C0240) and Issuer Code and Type of Code (C0250) required for (among others) CIC 21 – corporate bonds, even if the issuer has no majority owner (and thus is the ultimate parent)? These rules were introduced in 2.7.0 (BV1219-6 requiring C0250) and 2.8.2 (BV1218-6 requiring C0240) taxonomy for (among others) CIC 21. However this goes against the original understanding and position of EIOPA (Q&A 1411), where the answer to the part e) of the question: "In which specific cases should the issuer group be left blank? e) bond issued by the group itself/entity, which has some subsidiaries but no majority owner" was to leave C0240 empty: "The issuer group to be reported in C0240 is: e) bond issued by the group itself/entity, which has some subsidiaries but no majority owner: C0240: default approach, i.e. should be reported but ultimate parent does not exist as the bond is issued by the ultimate parent, therefore empty" This is confusing. Please advise on how to properly fill in C0240 and C0250 for issuers that are already the ultimate parent/that are not part of a group.