Topic: Supervisory Reporting

On 29 November, ESBG responded to the European Commission’s invitation for feedback on the Common Data Dictionary (CDD), a significant element in the EU’s financial services landscape. The CDD, discussed in a recent virtual workshop by the Directorate General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA), aligns with the Commission’s supervisory data strategy, striving for consistency in reporting requirements and data standardization.

In this context, ESBG views the CDD as a means to establish a shared language, simplifying interpretations, reducing discrepancies, and facilitating data reuse, particularly beneficial for financial conglomerates. It underscores the importance of use cases such as group consolidated statements’ standardization and merger information simplification. Additionally, ESBG proposes expanding the CDD’s scope to include end-to-end reporting solutions, integrating features like conceptual family domains.

Furthermore, ESBG delves into the components of the Data Dictionary, emphasizing the significance of the Data Catalogue and suggesting clarifications on the role of Assertions/Transformation. It advocates for machine-readable and machine-executable requirements, proposing a staged implementation prioritizing key elements like ISIN and LEI codes. While expressing support for the initiative, ESBG seeks clarification on the necessity of the Data Catalogue and emphasizes the importance of strategic clarity and stakeholder involvement for successful implementation.

ESBG also recognizes the necessity of cross-sectoral development but cautions about potential timing-related costs for entities. Moreover, it stresses the need for coordination to avoid additional regulatory developments during CDD implementation, minimizing duplication of costs and resources. Addressing challenges related to property types within operational limitations is essential.

Overall, ESBG underscores the significance of the CDD in creating a unified common dictionary across EU financial services, promoting consistency, efficiency, and shared standards in reporting.

Executive SummaryFull Position Paper

Contact Info:
Andreea Lungu
Advisor- Financial Reporting And Taxation
t. : +32 2 211 11 64