During a test upload we discovered a possible issue with validation BV1243 in template S.08.01. The case is as follows: For exposures towards a specific counterparty we’d like to report as counterparty group a natural person, who is owner of the group. As he is a person, there is no LEI code available. Therefore, we keep the item “counterparty group code” blank and report “None” as counterparty group code type. The same constellation might be possible for undertakings without valid LEI code. The filing rules (version 2.5.0) allow this constellation. On the other hand, the validation rule BV1243 only allows metrics like “LEI/*”, “SC/*”, but not “None”. Could you please check this validation rule or clarify how to report in such cases as mentioned above?

The BV1243 implementation reflects the Instructions regarding reporting templates for S.08.01 template which provides two possible options to report, LEI code or Specific Code. However, based on provided example EIOPA agrees that in some scenarios, such as provided in the question, no code can be provided. Therefore, we would like to inform that the validation in question was deactivated on 17 June 2024. Furthermore, EIOPA plans to amend the instructions amended accordingly (allowing for LEI, Specific Code or ‘None’ options) during the ITS review and reactivate updated validation.