Reporting Templates, Intra-group transaction

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Because Article 36 explicitly says that it concerns Annual submission of IGT and RC, my assumption would be that Article 38 concerns Ad-hoc submissions of the same (this could be written out explicitly to clear any doubts). In this article, you explicitly list all 5 of the new S.36 IGT QRTs: '... using, as appropriate, ...'. This would indicate that S.36.05 should be included in an Ad-hoc reporting. For instance when a large IGT has taken place. However, in the general comments for 36.04 and 36.05, the first line reads only: 'This template relates to the information groups shall provide annually.' This is opposed to 36.01-03 which also include 'at least annually'. Could you please clarify whether the two latter IGT QRTs should be included in the case of an Ad-hoc reporting?

European Insurance and Occupational Pensions Authority · Accepted Answer

Article 245 (paragraphs 2 and 3) of Directive 2009/138/EC require insurance and reinsurance undertakings or insurance holding companies to report on a regular basis and at least annually intragroup transactions to the group supervisor. In addition, Member States shall require reporting of very significant intra-group transactions as soon as practicable (ad hoc).In accordance with Article 245(6), EIOPA has developed the following intragroup transactions templates: templates S.36.01.01, S.36.02.01, S.36.03.01, S.36.04.01 and S.36.05.01 of Annex I to Regulation (EU) 2023/894. Article 245 does not distinguish between different types of intragroup transactions, therefore all templates shall be reported on a yearly basis, as well as on an ad hoc basis, namely in case of very significant intra-group transactions and for the intragroup transaction that must be reported in all circumstances.

Reporting Templates, Intra-group transaction

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