Article 7 of the IFR specifies that ‘Union parent investment firms, Union parent investment holding companies and Union parent mixed financial holding companies shall comply with the obligations laid down in Parts Two, Three, Four, Six and Seven on the basis of their consolidated situation’. The reporting requirements under Article 54 are laid down in Part Seven of the IFR. From a combined reading of Article 7 and 54 of the IFR, it could be inferred that the requirement to comply with Article 54 of the IFR on a consolidated basis rests exclusively on Union parent investment firms, Union parent investment holding companies and Union parent mixed financial holding companies.

However, Article 4 of the Commission Implementing Regulation (EU) 2021/2284, titled as ‘Application of reporting requirements on a consolidated basis’, provides that ‘In order to comply with the reporting requirements referred to in Article 54 of Regulation (EU) 2019/2033 on a consolidated basis, investment firms shall report the information specified in Articles 5 and 6 of this Implementing Regulation with the frequency specified therein’. This would imply that the consolidated reporting requirement in fact rests on the investment firm.