The issue concerns the reporting of counterparty identifiers in templates Z 12.00 and Z 14.00. While template Z 13.00 explicitly instructs entities to use the counterparty identifier “0000” when reporting at an aggregated level, no equivalent guidance is provided for templates Z 12.00 and Z 14.00.

In the case of template Z 12.00, the general instructions (paragraph 62) state that “where the creditor identifier (column 0210) is not available (e.g. in the case of instruments traded on platforms), each row shall be reported at the aggregate level with respect to this field.” However, the instructions do not specify which value should be reported in the counterparty identifier field to represent this aggregated level when the counterparty is unknown.

A similar situation arises in template Z 14.00, where no guidance is provided on how to report counterparty identifiers when reporting at an aggregated level (e.g. employee liabilities) or in cases where the counterparty is unknown.

Despite this lack of clarification, both templates are subject to existence-type validation rules requiring the counterparty identifier and, where applicable, the identifier type to be populated in all cases. As a result, entities apply divergent reporting practices, such as leaving the identifier blank, reporting placeholder values (e.g. “Not applicable”), and/or leaving the identifier type column empty.