Regulatory Alerts2025-06-04 | Circular 3/2025 (VA) – Guidance notes on information submitted to the supervisory authority regarding the values used to calculate the minimum contribution reimbursementCircular 3/2025 (VA) – Guidance on Information for Minimum Contribution Reimbursement Calculations
BaFin has issued Circular 3/2025 (VA) to replace Statement 612 with Form F.612.01 and introduce Form F.030.03, aligning life insurance undertakings' minimum allocation reporting with the XBRL national reporting format. The updated forms retain existing content but mandate initial submission alongside 2025 annual financial statements, with a strict six-month post-year-end deadline. This circular applies to all financial years ending after 31 December 2024, ensuring consistent calculation of values for minimum contribution reimbursements across supervised German and cross-border life insurers.
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This translation is furnished for information purposes only. The original German text is binding in all respects.
Business sign: VA 26-FR 3210/00003#00025
04.06.2025
To all life insurance undertakings subject to the supervision of the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – BaFin ) with the exception of pension and death benefit funds a) domiciled in Germany,
b) domiciled outside the signatory states to the Agreement on the European Economic Area (EEA) or c) pursuant to Section 65 of the Insurance Supervision Act (Versicherungsaufsichtsgesetz – VAG ).
With Circular 1/2021 ( VA ), BaFin has provided life insurance undertakings with statement 612 for calculating the minimum allocation to the provision for bonuses and rebates in accordance with the Minimum Allocation Regulation in life insurance (Mindestzuführungsverordnung – MindZV ).
Due to the conversion of the reporting format for national reporting to XBRL , the existing statement 612 needs to be adjusted. Statement 612 is being replaced by Form F.612.01. No changes have been made to the content.
A sample Form F.612.01 and the new Form F.030.03 (list of minimum allocation groups) are attached as Annex 1 and the comments on Form F.612.01 are attached as Annex 2. Life insurance undertakings are being asked to complete the updated Form F.612.01 and the new Form F.030.03 for the first time with their annual financial statements for the 2025 financial year and to submit them both to BaFin no later than six months after the end of the financial year.
The principles developed in the course of the conversion of the national reporting system to XBRL and outlined in Sections 24a to 24e of the Insurance Reporting Regulation (Versicherungsberichterstattungs-Verordnung – BerVersV ) apply analogously to this transmission. For details, please refer to the submission guidelines, which are also attached (Annex 3).
This circular must be applied to submission of Forms F.612.01 and F.030.03 for all financial years ending after 31 December 2024. Statement 612 must be submitted and Circular 1/2021 ( VA ) must be applied for financial years ending before 1 January 2025.
Additional information
Circular 3/2025 ( VA ) – Annex 1: Forms
Circular 3/2025 ( VA ) – Annex 2: Comments on Form F.612.01
Circular 3/2025 ( VA ) – Annex 3: Submission guidelines
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