EBA Supervisory Reporting Simplification: What to Flag

ByOfficer

Last updated: April 2026

On 10 April 2026 the EBA opened its simplification package on supervisory reporting. If you run FINREP, COREP, benchmarking or the stress test data collection in a Luxembourg bank, you now have two deadlines that matter before anything else: 10 May 2026 for the IFRS 18-related FINREP changes, and 10 July 2026 for everything else in the ITS on supervisory reporting and the ITS on supervisory benchmarking. The package proposes to cut the number of data points in the EU harmonised reporting by around 50% and to apply the new framework from September 2027. That application date sounds comfortably far away. It is not, because the window to push back on anything you do not like closes in weeks, not months.

This is a consultation, not a final ITS. That is exactly why it matters right now. Anything Luxembourg banks do not flag in the response gets baked into the September 2027 go-live. I have been through this cycle twice before with COREP and FINREP revisions, and the pattern is always the same. Teams read the press release, note the deadline, forget about it, and then discover in late 2027 that a template they never looked at now requires data their source systems do not produce. The value of the consultation window is catching that kind of thing while the EBA can still change the draft.

Related reading: FINREP reporting explained

What the EBA is actually consulting on

Two consultation papers, not one. The first amends Commission Implementing Regulation (EU) 2024/3117, the current ITS on supervisory reporting. The second amends the ITS on benchmarking of internal models (Regulation (EU) 2016/2070) and moves the credit risk and IFRS 9 benchmarking collection into the main ITS 2024/3117. That second move looks administrative and is not. It changes which legal text governs the benchmarking return and which templates feed it.

The main pieces on the table:

  • A roughly 50% reduction in the number of data points across harmonised EU reporting, net of new additions for IFRS 18, ESG and the Fundamental Review of the Trading Book (FRTB).
  • A new proportionality regime for small and non-complex institutions (SNCIs) built on a “core plus supplement” approach.
  • Integration of the EU-wide stress test and the supervisory benchmarking data collections into regular reporting.
  • Updated ESG reporting requirements, aligned to the final draft ITS on Pillar 3 ESG disclosures under Article 449a of the CRR.
  • An EU-wide public repository of European and national supervisory data requests, with guidance on data request best practices.
  • Adjustments to reporting frequency and scope, alignment of definitions, and tighter integration with national collections.

The package also sits on top of the Joint Bank Reporting Committee (JBRC) integrated reporting work and the DPM 2.0 / DPM Studio pipeline. If the bank still consumes the DPM 1.0 XBRL packages directly, this is a second signal that the modelling layer needs to move.

The two deadlines and why they are split

The 10 May 2026 deadline is narrow. It covers only the FINREP changes linked to IFRS 18 (“Presentation and Disclosure in Financial Statements”), which is the IASB standard replacing IAS 1 for annual periods beginning on or after 1 January 2027. The EBA pulled this strand forward because the IFRS 18 implementation inside the bank’s finance function is already live as a project. If the FINREP mapping is not fixed early, the accounting policy team and the regulatory reporting team end up building two different revenue, expense and subtotal classifications against the same general ledger.

The 10 July 2026 deadline covers everything else: the broader ITS amendments, the SNCI proportionality design, the stress test and benchmarking integration, the ESG templates, FRTB, and the benchmarking ITS amendments driven by changes to Article 78 of the CRD.

The EBA is holding two public hearings and one workshop. The first hearing, on the ITS on supervisory reporting consultation, runs on 5 May 2026, 10:00 to 13:00 CEST, with registration closing on 28 April 2026, 16:00 CEST. The workshop on “Efficient reporting: simpler, smarter, proportionate” runs on 4 June 2026, 09:30 to 13:30 CEST, with registration closing on 28 May 2026, 16:00 CEST. The second hearing, on the ITS on supervisory benchmarking consultation, runs on 24 June 2026, 09:30 to 12:30 CEST, with registration open until 17 June 2026, 16:00 CEST. If the LU bank wants to ask questions rather than just submit a written response, those are the dates to put in the diary this week.

Why this matters operationally for Luxembourg banks

The headline “50% fewer data points” is the number that will travel around senior management. It is also the number most likely to mislead. What the package actually does is reshuffle where the data sits, not delete half the obligation. Three operational realities Luxembourg teams should look at closely.

First, the SNCI treatment. A Luxembourg-incorporated bank that is part of a larger European group often fails the SNCI test on consolidation even when the local entity looks small. The “core plus supplement” approach in the consultation is designed to give SNCIs a smaller base set with add-on modules. Before assuming the bank qualifies, the reporting team should read the draft SNCI criteria against the group structure and branch footprint, not against the balance sheet of the LU solo entity.

Second, stress test and benchmarking integration. Today the EU-wide stress test templates and the supervisory benchmarking portfolios are handled by separate teams in many Luxembourg banks, often with a different tool stack and different cut-off dates. Merging them into the regular supervisory reporting cycle sounds like a simplification on paper. It will rip through the operating model if those teams sit in different divisions. This is where Luxembourg subsidiaries of European groups should trace the internal ownership of each data point before the consultation closes, not after go-live.

Third, ESG. The consultation builds on the Pillar 3 ESG disclosure ITS under Article 449a of the CRR. Luxembourg banks that have built their ESG reporting pipeline around Pillar 3 disclosures and assumed FINREP would stay ESG-light should read this section carefully. ESG-related data points are being added to supervisory reporting, not just to disclosure. The sourcing logic that feeds the ESG section of Pillar 3 will almost certainly need to feed FINREP as well.

What Luxembourg teams should review now

Before putting any formal response together, work through a short list of questions against the bank’s current reporting footprint. These are the ones that catch people out in this kind of consultation.

FINREP and IFRS 18

Map each IFRS 18 subtotal (operating, investing, financing, the new management-defined performance measures) to the current FINREP income statement structure and to what the consultation proposes. The trap here is not the new categories in isolation, it is the reconciliation back to the prior period. If the bank’s IFRS 18 project team and the FINREP team are not already in the same room, they should be by end of April.

Check the treatment of interest income and interest expense. IFRS 18 changes the location of some items that used to sit as “other operating”. FINREP has historically kept its own definitions regardless of accounting standard changes. The consultation is the moment to flag any case where the two now drift.

COREP, FRTB and SNCI

FRTB is being added to the ITS at the same time as templates are being cut elsewhere. For Luxembourg banks that chose the standardised approach for market risk, the cut will probably feel larger than the addition. For banks running an internal models approach on a narrow trading book, the net impact can still be up-heavy because FRTB internal model templates carry their own granularity.

The SNCI “core plus supplement” model deserves a formal internal review. Write down which supplements the bank would have to file today under the current draft, not in principle. The common mistake is to check the core set, conclude the burden is manageable, and skip the supplements because “they probably do not apply”. That is where reality diverges from the consultation narrative.

Benchmarking and the stress test

Two structural changes here. The credit risk and IFRS 9 benchmarking returns move out of Regulation (EU) 2016/2070 and into the main ITS 2024/3117. That changes the legal base referenced in the bank’s internal policy documentation, not just the file format. Anyone with an internal reporting policy that cites the 2016 ITS by article number will need to update it when the final text is published.

The EU-wide stress test integration is the bigger one. Today the stress test is an exercise. Tomorrow it becomes a line in regular supervisory reporting. That changes the audit expectations, the SOX / ICAAP linkage, and the sign-off model. Flag internally whether your stress test data still goes through a spreadsheet somewhere in the pipeline. The ITS world has no tolerance for that.

DPM 2.0 and the ingestion chain

The simplification package is designed around DPM 2.0 and DPM Studio. If the reporting tool vendor is still delivering DPM 1.0 taxonomies natively and converting on the way in, this is where that debt surfaces. There is nothing in the consultation that forces DPM 2.0 adoption earlier than September 2027, but the whole modelling logic the EBA is using assumes it. Banks that postpone the vendor upgrade will discover the simplification benefits evaporate in the integration layer.

A practical response plan for the consultation window

Teams that get value out of these consultations treat them as a three-stage exercise, not a one-off comment letter.

Stage one, run immediately: a field-level diff. Take the current CIR 2024/3117 templates the bank actually files. Line them up against the draft templates in the consultation. Flag additions, removals, scope changes, and frequency changes per template. This is boring mechanical work and it is the only way to catch the cases where a “simplified” template has actually absorbed fields from elsewhere.

Stage two, by mid-May: internal impact note for the IFRS 18 strand. This has the earlier deadline and it touches finance as much as it touches reporting. One or two pages covering FINREP mapping, subtotal treatment, and any fields where the bank thinks the draft will not work. Route it through the CFO function before it becomes a comment to the EBA.

Stage three, through June: the broader response. Pick three or four issues that genuinely matter to the LU entity and make them precise. Generic complaints about burden do not change draft ITS. Specific, template-and-row-number feedback does. If the bank does not want to sign a letter in its own name, the Luxembourg Bankers’ Association (ABBL) and the European Banking Federation are both likely to coordinate responses. Feeding the bank’s field-level diff into those channels is lighter-weight than going it alone and usually more effective.

Where teams commonly get this wrong: waiting until the consultation closes to look at the actual text because “it is only a draft”. The September 2027 go-live dates are fixed. What is not fixed is the content. This eight-to-twelve week window is the only chance to influence the content before the operational constraints land.

Frequently Asked Questions

When does the simplification package apply?

The proposed changes would apply from September 2027, based on the EBA press release of 10 April 2026. The dates during 2026 are consultation and hearing dates, not go-live dates. The final ITS text has to be adopted by the European Commission before September 2027, so timelines can still move.

What happens on 10 May 2026?

That is the closing date for written comments on the IFRS 18-related FINREP changes. If the bank wants the EBA to reconsider any element of how IFRS 18 maps into FINREP, the comment has to be submitted by that date through the dedicated survey in the consultation paper.

What happens on 10 July 2026?

That is the closing date for written comments on the rest of the package: the broader ITS on supervisory reporting amendments and the ITS on supervisory benchmarking amendments, including FRTB, ESG, SNCI proportionality, and the integration of the stress test and benchmarking collections.

Does this affect Luxembourg branches of third-country banks?

Indirectly. The ITS on supervisory reporting applies to CRR institutions. Third-country branches in Luxembourg file under the CSSF’s own framework for third-country branch returns, which draws on the EBA templates. If the harmonised templates change, the branch return will follow, usually with a lag. Third-country branches should still review the consultation to anticipate changes the CSSF will pass through.

Is the stress test still a separate exercise?

Under the consultation, the EU-wide stress test data collection would be integrated into regular supervisory reporting rather than running as a standalone collection. The exercise itself, with its methodology and scenarios, is a separate EBA workstream. What changes is how the input data is collected, not whether stress tests happen.

What is the “core plus supplement” approach for SNCIs?

It is a proportionality mechanism in the draft: a smaller core set of templates that all SNCIs file, plus supplementary modules triggered by specific activities or exposures. The classification criteria and the content of each supplement are part of what the consultation is asking for feedback on.

Do we need to register for the public hearings?

Yes. The hearing on the ITS on supervisory reporting consultation is on 5 May 2026, 10:00 to 13:00 CEST, with registration closing on 28 April 2026, 16:00 CEST. The workshop on “Efficient reporting: simpler, smarter, proportionate” is on 4 June 2026, 09:30 to 13:30 CEST, with registration closing on 28 May 2026, 16:00 CEST. The hearing on the ITS on supervisory benchmarking consultation is on 24 June 2026, 09:30 to 12:30 CEST, with registration open until 17 June 2026, 16:00 CEST. All three run through the EBA event pages.

What should our consultation response focus on?

Specific, template-and-row-number issues where the draft would force a change that is operationally difficult or produces a mismatch against accounting policy, group reporting, or national collections. Avoid generic burden arguments. The EBA has already accepted a simplification mandate at political level. The question now is where the draft gets it wrong in detail.

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Key Takeaways

  • The EBA simplification package has two consultation deadlines: 10 May 2026 (IFRS 18-related FINREP changes only) and 10 July 2026 (everything else).
  • The proposed application date is September 2027, but the content is decided during the 2026 consultation window.
  • Headline “50% fewer data points” is net of additions for IFRS 18, ESG and FRTB. The real burden picture per bank depends on the template mix.
  • SNCI “core plus supplement” treatment is new and must be checked against the LU entity’s group position, not the solo balance sheet.
  • Stress test and benchmarking collections are being folded into regular supervisory reporting, which changes ownership, sign-off and audit expectations.
  • ESG data points move further into supervisory reporting, not just Pillar 3 disclosure, so the sourcing pipeline needs to cover both.
  • Public hearings on 5 May 2026 (supervisory reporting) and 24 June 2026 (supervisory benchmarking) and workshop on 4 June 2026 require advance registration (28 April, 17 June and 28 May 2026 respectively).
  • The useful response is specific: template-and-row-number feedback, coordinated where possible through ABBL or the European Banking Federation.

Sources and References

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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