FI classification criteria

Dear all,

Question regarding asset management/owner definition for energy companies.

We have a specific case with a client. This company defines itself as a company where: Our operational framework relies on three income-generating sectors and a cost-effective corporate division. The Development sector serves as a green-field developer for projects both onshore and offshore. With a robust history, Development specializes in the organic, in-house creation of wind and hydropower assets. Meanwhile, the Production sector actively manages renewable power assets.

In the national company register centre, they are classified as a “producer of electricity” and are publicly listed. The company’s NACE-code is 35.119.

According to our back-of-the-envelope calculations, more than 60% of their revenues stem from being an asset manager/owner. This would indicate that they fall under the Financial Institution sector classification. However, they are well-below the threshold for SMEs only employing 62 FTEs in the 2022 reporting year. From our understanding a company defined as FI would override the SME-route. This company however does not classify itself as a financial institution, is there any more guidance available for defining asset management/owner? Or do you have any similar cases from the power sector that could give some insight?

Thank you in advance for any feedback and insight into this case.

Best regards
Asgaut Holm