EBA 4.3 Draft Package: What Reporting Teams Should Map

ByOfficer

Last updated: April 2026

On 16 April 2026, the EBA published the draft technical package for version 4.3 of its reporting framework. The package includes the DPM database, XBRL taxonomy, validation rules, and sample files for two new reporting streams: third-country branch (TCB) supervisory reporting under CRD VI and a DPM/taxonomy supporting AMLA’s methodology for selecting obliged entities for direct supervision from 2028. The final package is scheduled for June 2026, and the EBA is accepting feedback until 10 May 2026.

If you run reporting for a bank with third-country branches in the EU, or for an obliged entity that could fall under AMLA’s direct supervision, this package is the first concrete technical artifact you can map your systems against. The policy texts have been out for weeks. The DPM and taxonomy turn those policies into field-level specifications.

Related reading: EBA Third-Country Branch Reporting: What the New Harmonised Standards Mean for Your Branch

What the EBA 4.3 Draft Technical Package Contains

The draft package uploaded on 16 April 2026 includes four deliverables:

  • Validation rules release (draft, new format)
  • DPM 4.3 draft: DPM database 2.0, DPM dictionary, table layout and data point categorization, and identical cells mapping
  • XBRL 4.3 draft: full taxonomy, taxonomy package 4.3, and sample files 4.3
  • Scope: covering TCB reporting and AMLA reporting modules

The EBA’s 16 April 2026 press release describes the draft as “covering anti-money laundering (AML) and third country branches (TCB) reporting,” and the Reporting frameworks overview confirms that 4.3 is scoped to these two new modules only, with amendments to existing modules (simplification, CRR3/CRD6 step 2, FRTB, FINREP/IFRS 18, liquidity, ESG, DORA) placed under framework 4.4. That is the defining characteristic of this release: it extends coverage to entity types (third-country branches and AMLA-supervised obliged entities) that were not previously captured in the EBA’s DPM and taxonomy. It does not amend existing COREP, FINREP, resolution, benchmarking, or liquidity templates.

Changes to existing reporting modules, including CRR3/CRD6 step 2 amendments (boundary, thresholds, market risk, FRTB), simplification-linked ITS amendments (COREP, FINREP, benchmarking), IFRS 18 adjustments, ESG reporting, DORA amendments, and liquidity reporting changes, are part of reporting framework 4.4. The EBA’s reporting frameworks overview table lists 4.4 as expected Q3 2026, with module-specific application from December 2026 (phase 1) or September 2027 (phase 2).

The 10 April 2026 simplification consultation is a separate but related work stream. It feeds framework 4.4’s ITS amendments. Consultation deadlines: 10 July 2026 for the main package, 10 May 2026 for the IFRS 18-related requirements. The proposed simplification changes would apply from September 2027. If you are responding to both the 4.3 feedback window and the simplification consultation, keep the timelines distinct.

Third-Country Branch Reporting: What the DPM Now Specifies

The ITS on third-country branch supervisory reporting was finalized by the EBA on 5 March 2026, under CRD VI (Directive (EU) 2024/1619). Article 48k establishes the reporting obligation for third-country branches; Article 48l(1) sets the proportionality framework. The policy text established two sets of templates: Annex I for branch-level financial and regulatory data, Annex II for head-undertaking-level quantitative and qualitative data. Framework 4.3 now provides the DPM and XBRL taxonomy that turn those templates into reportable data points.

The first reference date is 31 March 2027, per the EBA’s framework 4.3 page. That sounds distant, but the remittance deadline follows later, and the real constraint is mapping. Branches need to identify which data points in Annex I and Annex II they can source from existing systems and which require new feeds. I have seen this underestimated in previous new-module rollouts: the branch-level P&L, asset quality, and funding data in Annex I often sit in local accounting systems that were never connected to the group’s regulatory reporting platform.

The EBA retained its “core plus supplement” proportionality approach. Smaller and less complex branches submit a core set. Larger and more complex branches report additional detail. But the DPM does not make this distinction for you. Every data point is in the taxonomy. Your implementation team needs to determine which supplement templates apply based on the branch’s classification, and that classification itself depends on criteria the competent authority will assess.

Where Teams Typically Get This Wrong

The common mistake with new DPM modules is treating the taxonomy as a filing guide. The DPM tells you what data points exist and how they relate to each other. It does not tell you which templates your branch must file. That determination comes from the ITS text, the branch’s size classification, and the competent authority’s assessment. Teams that skip the ITS instructions and go straight to the XBRL sample files end up mapping data points they will never report, while missing the ones they actually need.

AMLA Reporting: The Selection Methodology Data Collection

The second module in framework 4.3 supports AMLA’s methodology for identifying obliged entities that will fall under its direct supervision from 2028. The EBA provides the DPM and taxonomy so that AMLA can run a risk-based selection process across the EU. The first reference date for this module is 31 December 2026, per the EBA’s framework 4.3 page.

This is not traditional supervisory reporting. The EBA’s role stems from the service-level agreement signed between the two authorities, with EBA and AMLA completing the handover of AML/CFT mandates effective 1 January 2026 (announced in the EBA press release of 19 January 2026). Under that SLA, the EBA provides technical infrastructure (DPM, taxonomy, statistical support) while AMLA defines the policy objectives.

The draft technical package does not yet include two tables: AML.01.01 and AML.01.02. These will be added in the final package in June 2026, along with additional validation rules for AML reporting. The EBA’s press release states this explicitly: “The final package will include additional elements not yet covered, notably two tables related to the AMLA framework (AML.01.01 and AML.01.02), as well as further validation rules applicable to AML reporting.”

AMLA’s Own Data Collection Exercise

Separately from the EBA’s 4.3 framework release, AMLA launched its own data collection and testing exercise on 16 March 2026 to test and calibrate its risk assessment models. Sampled entities were notified by their national competent authorities and asked to submit data by 22 April 2026. This exercise serves two purposes: informing the selection of up to 40 entities for AMLA’s direct supervision starting in 2028, and ensuring consistent ML/TF risk assessment by supervisors across the EU. The EBA’s press release directs readers to AMLA’s published templates and instructions for that exercise.

If you were not notified by your NCA, you are not part of this testing exercise. But the EBA’s 4.3 taxonomy is the technical infrastructure that will support future AMLA data collections beyond this initial calibration round. That is why the framework 4.3 module matters even if your entity was not in the first sample.

What This Means in Practice

Do not confuse AMLA’s selection-related data collection with the AML reporting you already do under national frameworks. GoAML filings, STR submissions, and CSSF’s annual AML/CFT data collection are separate obligations. AMLA’s data collection is a supervisory selection tool, not a recurring reporting requirement. Whether it evolves into one depends on how AMLA’s direct supervision mandate develops.

DPM 2.0 and the New Glossary

Framework 4.3 uses DPM 2.0, the restructured data point model the EBA has been migrating to since framework 4.2. The draft includes a DPM database, dictionary, table layout with data point categorization, and identical cells mapping.

The EBA is also asking for feedback on a new glossary alongside the draft technical package. This is not just a cosmetic change. The glossary standardizes terminology across reporting modules. For teams that have built their own internal mapping dictionaries over the years, this matters because the EBA’s glossary may use different terms for concepts your systems already reference under legacy names.

One area where I expect friction: the identical cells mapping. This file identifies data points that must contain the same value across different templates. In previous framework releases, discrepancies in identical cells were a leading source of validation errors. With two entirely new modules, the identical cells relationships are untested. Check them early against your data, not after your first submission fails validation.

Validation Rules: What to Check

The EBA published draft validation rules alongside the 4.3 package. The validation rules release uses a new format, which the EBA has been gradually introducing across recent framework releases.

For reporting teams and vendors, this means you should test your existing validation rule parsers against the 4.3 draft rules early. If you have automated processes that ingest validation rule files and map them to internal checks, verify compatibility now. Do not wait for the final package in June. Format surprises in production are harder to fix than format surprises in a sandbox.

The draft validation rules cover TCB templates. The AML validation rules are incomplete in this release. The EBA has stated that additional AML validation rules will be included in the final package.

What Is Not in Framework 4.3

Framework 4.3 is scoped to two new modules that extend reporting coverage to new entity types. It does not include changes to existing reporting templates or frameworks. Specifically, it does not cover:

  • CRR3/CRD6 step 2 adjustments (boundary, thresholds, market risk, FRTB)
  • Simplification-linked ITS amendments (COREP, FINREP, benchmarking)
  • FINREP adjustments for IFRS 18
  • New ESG reporting
  • Amendments to liquidity reporting (ALMM, LCR), asset encumbrance, and leverage ratio
  • Supervisory benchmarking integration
  • DORA reporting amendments
  • Operational risk (operational losses)
  • New reporting on initial margin models
  • Technical amendments to resolution

All of those are listed under framework 4.4 on the EBA’s reporting frameworks overview page. The overview table shows 4.4 as expected Q3 2026, with module-specific application from December 2026 (phase 1) or September 2027 (phase 2). Framework 4.4 is where the simplification consultation proposals, if adopted, will be implemented alongside the CRR3/CRD6 step 2 amendments and new ESG and DORA reporting requirements.

The risk here is that teams conflate the two. If your project plan says “EBA framework changes H2 2026,” you need to distinguish between the 4.3 release (TCB and AMLA, applying from Q4 2026) and the broader 4.4 release (existing-module amendments, applying from December 2026 or September 2027). Resourcing and timelines are different.

Feedback Window and Next Steps

The EBA is accepting comments on the draft technical package and the new glossary until 10 May 2026, via the EBA feedback form on their website.

The final technical package for framework 4.3 is expected in June 2026. That final package will include the missing AML tables (AML.01.01 and AML.01.02), additional AML validation rules, and any amendments based on stakeholder feedback.

For TCB reporting, the first reference date is 31 March 2027. For the AMLA data collection module, the first reference date is 31 December 2026. That means AMLA-related data needs to be ready by year-end 2026, which leaves roughly six months from the final package publication.

What to Do Now

If TCB reporting is in your scope: download the DPM 4.3 draft and the sample XBRL files. Map them against the Annex I and Annex II templates from the March 2026 ITS final report. Identify gaps in your data sourcing, especially for branch-level data that may not currently flow to your regulatory reporting system. Flag the identical cells file for early testing.

If AMLA selection is relevant: monitor for the final package in June. The missing AML.01.01 and AML.01.02 tables mean you cannot do a full mapping yet. But you can review AMLA’s templates and instructions from its March 2026 data collection exercise to understand the data categories AMLA is working with.

If neither applies directly but you manage the EBA reporting framework: review the draft validation rules for compatibility with your tooling, especially the new format. And keep a separate workstream for framework 4.4, which will bring the much larger set of changes to existing reporting modules later this year.

Frequently Asked Questions

What is the EBA reporting framework 4.3?

Reporting framework 4.3 is an incremental release of the EBA’s technical package for supervisory reporting. It introduces two new modules extending coverage to entity types not previously in the EBA framework: ITS on third-country branch reporting under CRD VI and a DPM/taxonomy supporting AMLA’s obliged entity selection methodology. The draft was published on 16 April 2026, with the final package expected in June 2026.

Does framework 4.3 change COREP or FINREP templates?

No. Framework 4.3 adds new modules for new entity types only. Changes to COREP, FINREP, resolution planning, benchmarking, liquidity, ESG, and DORA reporting are part of framework 4.4, expected Q3 2026, as shown on the EBA’s reporting frameworks overview page.

When is the first reporting reference date for third-country branches?

The first reference date for TCB reporting under framework 4.3 is 31 March 2027, as specified on the EBA’s framework 4.3 page and consistent with the final report on the ITS published 5 March 2026.

What is the AMLA data collection in framework 4.3?

The AMLA module provides the DPM and taxonomy for a data collection that AMLA will use to identify which obliged entities it will directly supervise from 2028. The first reference date is 31 December 2026. This is a supervisory selection tool, not a recurring reporting obligation. Separately, AMLA ran its own testing and calibration exercise starting 16 March 2026, with a 22 April 2026 submission deadline for sampled entities.

Are the AML tables complete in the draft package?

No. Two tables (AML.01.01 and AML.01.02) and additional AML validation rules are not included in the draft. They will be added in the final package in June 2026, as stated in the EBA’s 16 April 2026 press release.

How does framework 4.3 relate to the EBA simplification consultation?

They are separate work streams on different timelines. The simplification consultation published on 10 April 2026 feeds into framework 4.4, which covers amendments to existing reporting modules. Simplification covers COREP, FINREP, benchmarking, and other existing modules, with a target 50% reduction in data points. The simplification consultation deadlines are 10 July 2026 (main) and 10 May 2026 (IFRS 18-related). Proposed changes would apply from September 2027. Framework 4.3 is scoped to TCB and AMLA reporting only.

How do I submit feedback on the draft technical package?

The EBA accepts comments via its feedback form, with a deadline of 10 May 2026. Feedback can cover both the draft technical package and the new glossary.

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Key Takeaways

  • EBA reporting framework 4.3 introduces two new modules for entity types not previously in the EBA reporting framework: third-country branch supervisory reporting (first reference date: 31 March 2027) and AMLA obliged entity selection data collection (first reference date: 31 December 2026).
  • The draft technical package was published on 16 April 2026. The final package is expected in June 2026. Feedback deadline: 10 May 2026.
  • Framework 4.3 does not change COREP, FINREP, or any existing reporting modules. Changes to existing modules (simplification, CRR3/CRD6 step 2, FRTB, ESG, IFRS 18, DORA, liquidity, benchmarking) are under framework 4.4, listed on the EBA’s reporting frameworks overview page as expected Q3 2026.
  • The TCB ITS legal basis is Article 48k (reporting obligation) and Article 48l(1) (proportionality) of CRD VI. The ITS was finalized on 5 March 2026.
  • Two AML tables (AML.01.01 and AML.01.02) and additional AML validation rules are not in the draft. They arrive in the final package in June.
  • AMLA launched its own separate testing and calibration exercise in March 2026, with a 22 April 2026 submission deadline for sampled entities. The EBA’s press release links to AMLA’s published templates for that exercise.
  • The 10 April 2026 simplification consultation feeds framework 4.4’s ITS amendments, not 4.3. Consultation deadlines: 10 July 2026 (main), 10 May 2026 (IFRS 18).
  • The identical cells mapping for new TCB modules should be tested early to avoid validation errors on first submission.

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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