According to the instructions on columns 010-070 (counterparty identification) of template C 27.00 of Annex VIII to Regulation (EU) No 680/2014 as amended by Regulation (EU) 2015/1278 (ITS on Supervisory Reporting) which are provided in Annex IX of the ITS on Supervisory Reporting, ‘institutions shall report the identification of any counterparty for which information is being submitted in any of the templates C 28.00 to C 31.00. The identification of the group of connected clients shall not be reported, unless the national reporting system provides a unique code for the group of connected clients.’

While the first sentence establishes a general rule, the second sentence provides an exception from that general rule. This is due to the fact that the code provided in c010 of C 27.00 is a row identifier and must be unique for each row in the table (see instruction on c010 of C 27.00 in Annex IX and validation rule v3995_u).

The consequence of this is the following:

• The identification of individual clients to which an institution has an exposure always has to be reported in template C 27.00, whether this individual client forms part of a group of connected clients or not. Codes for individual clients are usually available in national reporting systems.
• The identification of groups of connected clients only has to be reported in C 27.00 under certain circumstances: If the national reporting system does not provide a unique code for the group of connected clients – hence the code used to identify this group would be same as the one used for the parent / most significant entity at individual level (see also Q&A 2014_1080) –, this group of connected clients shall not be reported in C 27.00 at all.

Whether the identification of a group of connected clients is separately reported in C 27.00 or not, exposures to this group of connected clients and entities belonging to it have to be reported in templates C 28.00, C 29.00, C 30.00 and C 31.00, as applicable, and identified according to the instructions provided for the respective columns of those templates.

The instructions will be modified to indicate that the identification of a group of connected clients to which an institution has an exposure shall be reported only in the following two cases: a) the national reporting system provides a unique code for the group of connected clients or b) the national reporting system does not provide a unique code for the group of connected clients, and the institution does not have an exposure to the parent / most significant entity of the group of connected clients.

With regard to the example mentioned in the background to the question, the decisive fact is whether the reporting system of the competent authority the institution is reporting to provides a unique code for groups of connected clients, not whether such a unique identifier is used in the country where the counterparty is located.

Thus, an institution located in Luxemburg

• reports neither the group of connected clients incorporated in Luxembourg nor the one incorporated in Germany in C 27.00, if the reporting system of Luxembourg’s competent authority does not provide a unique code for groups of connected clients respectively
• reports both groups of connected clients in C 27.00, if the reporting system of Luxembourg’s competent authority provides a unique code for groups of connected clients.