Annex 3 to Circular 3/2025 (VA): Submission guidelines

This translation is furnished for information purposes only. The original German text is binding in all respects. 1 Annex 3 to Circular 3/2025 (VA): Submission guidelines Companies are requested to observe the following submission guidelines to ensure proper transfer of data. Failure to observe these guidelines means that acceptance of the submission cannot be guaranteed. Reporting and publishing platform: The forms must be submitted electronically to BaFin’s reporting and publishing platform (Melde- und Veröffentlichungsplattform – MVP Portal). Insurance companies can access this portal online once they have registered with BaFin for the service. BaFin also publishes (further) guidance on its website regarding electronic data submission, as well as the rules to be observed when checking and submitting data in terms of data format and content. This guidance supplements or provides more detail than the guidance contained in this circular. XBRL and PDF submissions: A form comprises quantitative information (the “quantitative part” of the form) and, where applicable, an annex containing additional envisaged or voluntary disclosures (the “qualitative part” of the form). Form F.030.03 is deemed the quantitative part of the form for submission purposes. The quantitative and qualitative parts of a form are submitted in separate report files. One report file containing quantitative parts of forms and one report file containing qualitative parts of forms can be submitted together in one single reporting round. The submissions must be in a machine-readable and searchable file format. The quantitative part of a form is submitted in a single report file based on the latest XBRL taxonomy published by BaFin on its website, including the general information and notes on the scope of the report. If BaFin also offers another submission format on its website that it will convert into XBRL, this format can be used instead for the submission. If an alternative format is offered for the submission of forms in accordance with the Insurance Reporting Regulation (Versicherungsberichterstattungs-Verordnung – BerVersV) and Capital Resources Regulation (Kapitalausstattungs-Verordnung – KapAusstV), BaFin will also offer this alternative format for submission of forms in accordance with this circular. Any supplementary qualitative part of the form must be transmitted in a PDF file (specification PDF/A-1a, PDF/A-2a or PDF/A-3a or, if applicable, a higher version, and this specification must also be recognisable from the document properties/metadata). Naming convention for the submission: Specialised procedure in the MVP Portal: “Insurance Supervision Sector”

This translation is furnished for information purposes only. The original German text is binding in all respects. 2 Submission: “‘National reporting (prefix NB)” For successful receipt, the report content (i.e. the files to be transmitted in XBRL format or an alternative file format and/or as a PDF) must be uploaded in a zip archive. The following naming convention applies to the zip archive: NB_<4-digit reg. no.><JMVU entry point><reporting period (format: YYYYMM)>.zip Example: NB_1234_JMVU_202512.zip: Report for the financial year 1 January 2025 to 31 December 2025 of the company with registration number 1234. The following naming conventions apply to files to be transmitted in XBRL format (or alternative file format) and/or as PDF files: NB_<4-digit reg. no.><JMVU entry point><reporting period (format: YYYYMM)><serial number/ 4 digits>.xbrl <serial number> is a mandatory four-digit number that indicates whether this is an initial report (‘0001’) or a follow-up or correction report for the reporting period (‘0002’, ‘0003’, etc.). or NB<4-digit reg. no.><JMVU entry point><reporting period (format: YYYYMM)><serial number/ 4 digits><suffix/ 32 alphanumeric characters>.xlsm By way of example, provided that .xlsm is authorised as an additional permissible reporting format. <Suffix> is a string with a maximum of 32 alphanumeric characters. There are no further requirements for the suffix apart from the above restrictions. or NB_<4-digit reg. no.><JMVU entry point><reporting period (format: YYYYMM)>_<serial number/ 4 digits>.pdf Parts of the form to be submitted together: For technical reasons and for the purposes of improving data quality through extended validation options, the quantitative part of Form F.612.01 and Form F. 030.03, together with

• all other quantitative parts of forms in accordance with the Insurance Reporting Regulation with the same submission deadline and

This translation is furnished for information purposes only. The original German text is binding in all respects. 3

• any quantitative parts of forms already submitted in an earlier reporting process in accordance with the Insurance Reporting Regulation and, if applicable, the Capital Resources Regulation for the respective financial year, must be (re-)transmitted in one report file. In order to facilitate the evaluation and improve the supervisory process, a supplementary qualitative part of Form F.612.01 together with
• all other qualitative parts of forms in accordance with the Insurance Reporting Regulation with the same submission deadline and
• any qualitative parts of forms already submitted in an earlier reporting process in accordance with the Insurance Reporting Regulation and, if applicable, the Capital Resources Regulation for the respective financial year, must be (re-)transmitted in one report file. If Forms F.612.01 and F.030.03 were submitted early and before other forms for this financial year,
• the quantitative part of Form F.612.01 and Form F.030.03 must be resubmitted in one report file, this time together with any quantitative parts of forms submitted later for this financial year in accordance with the Insurance Reporting Regulation and, where applicable, the Capital Resources Regulation;
• any supplementary qualitative part of Form F.612.01 must be resubmitted in one report file, this time together with any qualitative parts of forms submitted later for this financial year in accordance with the Insurance Reporting Regulation and, where applicable, the Capital Resources Regulation. Correction notifications If a quantitative or qualitative part of the form needs to be corrected after it has been submitted, this part of the form must be corrected and resubmitted without undue delay as soon as the need for correction has been ascertained. If a quantitative part of the form is corrected, all other quantitative parts of the form that have been submitted for this financial year must be resubmitted in a report file together with the corrected quantitative part of the form. Example 1: In the event of a correction to the quantitative part of Form F.612.01 for the 2025 financial year, then in addition to Form F.030.03, the quantitative parts of the forms submitted for this financial year in accordance with the Insurance Reporting Regulation and, where applicable, the Capital Resources Regulation must also be resubmitted in a report file together with the corrected quantitative part of the form, including in cases where the correction is only required for Form F.612.01.

This translation is furnished for information purposes only. The original German text is binding in all respects. 4 Example 2: In the event of a correction to the quantitative part of Form F.213.01 (Section 10 of the Insurance Reporting Regulation) for the 2025 financial year, the quantitative parts of the other forms previously submitted for this financial year (i) in accordance with the Insurance Reporting Regulation, (ii) where applicable, in accordance with the Capital Resources Regulation, and (iii) in accordance with this circular (quantitative part of Form F.612.01 and Form F.030.03) must also be resubmitted in one report file together with the corrected quantitative part of the form, including in cases where the correction is only required for Form F.213.01. The statements also apply analogously to correction reports for qualitative parts of the form. Form F.030.03 should not be submitted here. If the corrections relate solely to quantitative parts of the form (including Form F.030.03) or solely to qualitative parts of the form, the other parts of the form do not need to be resubmitted. However, if a correction made in the quantitative or qualitative report file results in erroneous statements in the other report file, i.e. the correction to one report file triggers a need for a correction in the other report file, then both corrected report files must be submitted. Rejecting data A report file will be rejected if the data content or data format is not in line with the indications specified above. Data records that have been rejected are deemed not to have been submitted. The rejection notification, including the reason for the rejection, can be found in the MVP Portal.