For context, on 14 December 2023, the EBA initiated a public consultation on draft Implementing Technical Standards (ITS) to amend Pillar 3 disclosures and supervisory reporting requirements, aligning them with the latest Basel III reforms outlined in the Banking Package. The consultation seeks clarity and support for institutions in meeting their reporting obligations, with a focus on changes related to the output floor, credit risk, market risk, and leverage ratio. Once finalized, the draft ITS will be submitted to the European Commission by June 2023, in line with Regulation (EU) No 575/2013.

In its response, ESBG stressed that it anticipates high compliance costs, especially due to increased granularity and complexity in reporting requirements. It proposes prioritizing essential information for regulators to mitigate disproportionate compliance costs and eliminating less relevant data points and providing waivers for certain templates to streamline reporting efforts.

Moreover, ESBG raises concerns about the clarity of instructions and templates due to missing information, such as the z-axis of exposure classes. As such, we request more details on new exposure classes. Additionally, we highlight discrepancies between different reporting requirements, such as the inconsistency in exposure class listings between reports. ESBG also seeks clarification on reporting transitional provisions and missing columns in certain templates.

Finally, ESBG advocates for a postponement of at least six months for the first reference date of the EBA’s supervisory reporting, suggesting an end date of September 2025. We stress that banks require adequate time for implementation, especially concerning new rules like the output floor, which entail significant efforts.

We propose focusing initially on specific changes to own funds and credit risk templates and suggest extending submission deadlines and increasing error margin allowances for validation rules for the first two reporting dates.