https://www.epo.org/en/node/can-i-also-file-st25

Can I also file the ST.25 sequence listing from the parent application?

If you are concerned about subject-matter being added or lost during conversion to ST.26, you may also submit the ST.25 sequence listing from the parent application in PDF as part of the divisional application. This ensures that the requirements under Article 76(1) EPC are met.  

For a parent application's ST.25 sequence listing filed in PDF as a part of the divisional application, no additional page fee falls due (OJ EPO 2023, A98).  

You can also file a divisional application by reference to the parent application (Rule 40(1)(c) EPC). In that case, the certified copy under Rule 40(3) EPC, which constitutes the divisional application, contains the full description of the parent application, including any ST.25 sequence listing. 

In all of the above cases, a sequence listing complying with WIPO Standard ST.26 must be filed subsequently to comply with Rule 30(1) EPC. 

If the ST.26 sequence listing is filed before the EPO issues the invitation under Rule 30(3) EPC, the late furnishing fee under Rule 30(3) EPC is not raised (Guidelines for Examination in the EPO, A-IV, 5).