Germany's Federal Financial Supervisory Authority (BaFin) issued a general administrative order requiring German-domiciled pension funds to report on their entire investment portfolios and the coverage position of their ring-fenced assets using quarterly Form F.678.01 submissions. The requirement applies to pension funds supervised under the German Insurance Supervision Act and excludes assets held to implement a pure defined contribution promise under the German Occupational Pensions Act. The report must be filed for each quarter-end (31 March, 30 June, 30 September and 31 December) and distinguishes investments held for the account and risk of employees and employers from other investments, with reporting in both book values and fair values. The template also requires a quarterly breakdown of coverage by specified business types, showing “IST” amounts against the “MindestSOLL” minimum, and triggers mandatory qualitative explanations where any ring-fenced assets are underfunded, including planned or implemented measures and updates until the shortfall is resolved. Submissions must be electronic via BaFin’s MVP portal in machine-readable formats, with the quantitative part based on BaFin’s current XBRL taxonomy and any qualitative annex submitted as PDF/A; for the second and fourth quarters, the quantitative (and any qualitative) parts must be filed together with the corresponding Form F.882.01 submission under section 11 of the Pension Fund Reporting Regulation. First-time reporting under the order starts with the 31 March 2025 reporting date, and BaFin simultaneously revoked the prior 29 July 2021 order with effect for reporting quarters from 1 January 2025. The order provides for prompt correction filings once errors are identified, rejection of non-compliant files as “not submitted”, and publication by BaFin of detailed electronic validation and submission rules for data format and content.

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