In T 62/13 the board observed that a decision to refuse based on the file as it stands could be issued either by way of a form (EPO Form 2061) referring to an earlier communication, or alternatively by way of a fully reasoned decision. In T 1360/05 the board stated that the examining division is not obliged to restrict itself to a decision by reference using the standard form when the necessary reasons in relation to the latest filed claims have not been formulated in any document on file.
Source: http://www.epo.org/law-practice/legal-texts/html/caselaw/2019/e/clr_iii_k_3_5_2.htm
Date retrieved: 17 May 2021