Germany's Federal Financial Supervisory Authority overhauls small insurers’ investment reporting with XBRL submissions and a EUR 5 million quarterly exemption

Germany's Federal Financial Supervisory Authority (BaFin) issued a collective administrative order setting standardised reporting requirements on capital investments for supervised small insurance undertakings, pension funds and certain separate accounting associations of public-law pension institutions, covering the full portfolio of assets except those used for pure defined contribution arrangements. The order requires quarterly submissions using forms F.670.01 (overview of all investments by Investment Ordinance asset classes), F.660.01 (derivatives, forward purchases/sales and structured products where held), F.671.01 (book and fair values, hidden reserves/losses and a quarterly coverage calculation of insurance technical liabilities by restricted assets (Sicherungsvermögen), on a gross basis including reinsurers’ shares), plus a quarterly “Streuung” annex to check debtor-based concentration limits. An annual “Fonds” annex must be filed for investment funds holdings and must reconcile to year-end totals in F.670.01. Quarterly reports are due by the end of the month following the quarter-end, and the annual “Fonds” annex by the end of the month following year-end, with no nil return required where a filing obligation does not arise. Filings must be made electronically via BaFin’s MVP portal, with quantitative parts submitted in machine-readable formats based on BaFin’s XBRL taxonomy (or an alternative format offered by BaFin that is converted into XBRL) and qualitative explanations submitted as PDF/A; BaFin also sets bundling, naming, correction and rejection rules, including re-submission of all quantitative parts sharing the same filing deadline when correcting one of them. The new regime applies first to the 31 March 2025 reporting date for the quarterly forms and the “Streuung” annex, and to the 31 December 2025 reporting date for the annual “Fonds” annex. BaFin also withdrew its 28 July 2021 collective order with effect for reporting (quarter-)years from 1 January 2025 and aligned prior exemptions: mutuals with capital investments not exceeding EUR 5 million are exempt from preparing and filing forms F.670.01, F.671.01 and F.660.01 for the first three quarters of a financial year, while other undertakings can apply for a similar first-three-quarters exemption but must still file for the fourth quarter under the standardised process.