KOFS Reporting in Denmark: Own Funds Returns and Deadlines

KOFS and KOFC were Finanstilsynet’s FIONA compilation names for individual and consolidated COREP own-funds reporting. The last reference period for those FIONA compilations was 31 December 2025; from the 31 March 2026 reference period, the e-Reg reporting module is COREPOF, with reporting level IND for individual reporting and CON for consolidated reporting.

COREP is the EU supervisory reporting framework for, among other things, own funds and own-funds requirements.

The data model is European. The templates, the reference dates and the remittance deadlines all come from an EU implementing regulation. What is Danish is the submission channel and national reporting identifiers, plus KOVER, a separate national return used to report the inclusion of interim or year-end profit; the conditions for recognising that profit in CET1 before the institution has taken the formal decision confirming its final annual profit or loss are governed by CRR Article 26(2).

Related reading: COREP reporting explained

The KOFS reporting calendar: four quarters, four remittance dates

KOFS is a fixed-calendar return with four reference dates each year: 31 March, 30 June, 30 September and 31 December. The remittance deadline for each quarter falls approximately six weeks later, on 12 May, 11 August, 11 November and 11 February in that order. Group solvency, reported through templates C 06.01 and C 06.02, runs on a semi-annual cycle, remitted on 11 August and 11 February. Where a remittance date lands on a Saturday, Sunday or a Danish public holiday, the deadline slides to the following working day.

The channel changed at the turn of 2025 to 2026. Finanstilsynet accepted the final FIONA own funds submission for the 31 December 2025 reference date; the first e-Reg submission covered the 31 March 2026 reference date. For any team managing the annual reporting plan, the practical question is which reference date is now closing and which taxonomy version applies to it.

The legal basis: CRR Article 430 and the own funds ITS behind KOFS

The obligation itself sits in the Capital Requirements Regulation, Regulation (EU) No 575/2013. Article 430(1), point (a), requires institutions to report information on own funds and own funds requirements to their competent authority. That is the Level 1 duty; KOFS is the Danish delivery of it.

The formats, frequencies and dates are set one level down, in the implementing technical standards. The governing ITS is Commission Implementing Regulation (EU) 2024/3117, as amended by Commission Implementing Regulation (EU) 2025/2475. Regulation 2024/3117 applies from 28 June 2025. Under its current Article 25, most of Regulation 2021/451 ceased to apply from 1 January 2025, but specified market-risk provisions and Article 15 for a limited purpose continue until 31 December 2026; Regulation 2021/451 is repealed with effect from 31 December 2026. Read the ITS as the rulebook for what a KOFS file must contain and when it is due.

One trap worth naming early: the Finanstilsynet COREP hub still carries older questions and answers that reference Regulation (EU) No 680/2014, the ITS that governed COREP before 2021. Regulation 680/2014 was repealed by Regulation 2021/451. Regulation 2024/3117 subsequently replaces Regulation 2021/451 subject to the transitional provisions in its current Article 25. When a legacy Q&A entry and the current ITS appear to disagree, the ITS in force at the reference date governs. KOFS is the EU own funds module carried on a national code, not a template Finanstilsynet designed independently, and the binding text is the EU regulation, read together with any guidance Finanstilsynet publishes.

Who must report KOFS: Danish credit institutions, solo and consolidated

KOFS applies to institutions subject to own funds requirements under the CRR. In practice that means credit institutions authorised in Denmark, together with the investment firms that continue to report own funds under the CRR reporting standards and not the separate investment-firm regime. The return is filed on an individual basis by each institution and, where the institution heads a group or is otherwise subject to consolidated supervision in Denmark, on a consolidated basis as KOFC.

The operative distinction is reporting level, not entity size. Individual and consolidated COREP own-funds reporting are separate obligations. A parent institution may have both individual and consolidated reporting obligations, but Article 7 distinguishes waivers by entity: Article 7(1) permits a waiver of Article 6(1) for a qualifying subsidiary, while Article 7(3) separately permits a waiver for a qualifying parent institution. Any individual-basis relief depends on the waiver granted to the relevant entity and is not automatic.

Firm size still matters, but the distinction is about detail and frequency, not about whether KOFS is owed at all. The ITS attaches entry and exit criteria to the small and non-complex classification and to the large-institution classification, and those criteria change how much template detail and how often certain data points are filed. The Finanstilsynet COREP hub and the underlying ITS are the reference for branch and third-country cases; where those sources do not spell out a particular branch treatment, a firm should ask Finanstilsynet directly and not try to read a rule across from a neighbouring return.

What the KOFS report contains: templates C 01.00 to C 06.02 and the requirement detail

The core of KOFS is the own funds template set. C 01.00 sets out the composition of own funds, Common Equity Tier 1, Additional Tier 1 and Tier 2, after regulatory adjustments and deductions. C 02.00 sets out the own funds requirements, built up from the total risk exposure amount. C 03.00 reports the resulting capital ratios: CET1, Tier 1 and total capital. C 04.00 holds memorandum items, while C 05.01 and C 05.02 carry the transitional adjustments that phase certain amounts in or out.

Group solvency sits in C 06.01 and C 06.02, which break the position down across the entities inside the scope of consolidation and are reported semi-annually. Behind the headline requirement, the own funds module also carries the risk-exposure detail that produces the number in C 02.00: standardised credit risk in C 07.00, internal ratings-based credit risk in the C 08 templates, the geographical distribution of exposures in the C 09 templates, plus the operational risk and market risk templates. For capital-ratio controls, reconcile the CET1, Tier 1 and total own-funds amounts with the total risk exposure amount used for the corresponding ratios in C 03.00. Under CRR Article 92, each capital ratio is the relevant capital amount expressed as a percentage of total risk exposure amount.

Large exposures, the leverage ratio and asset encumbrance are separate e-Reg modules: COREPLE, COREPLR and AE respectively, each with IND and CON reporting levels. KLES/KLEC, KLRS/KLRC and KAES/KAEC were the corresponding FIONA compilation names through the 31 December 2025 reference period. Values follow the ITS data-point conventions, with monetary data points reported using a minimum precision equivalent to ten thousands of units and institutions identified by their Legal Entity Identifier.

Reference dates and deadlines: the 12 May to 11 February remittance cycle

KOFS is a quarterly return. Under Article 2 of the ITS, the reporting reference dates are 31 March, 30 June, 30 September and 31 December. Under Article 3, institutions submit by close of business on the remittance dates 12 May, 11 August, 11 November and 11 February. So the quarter closing on 31 December is due by 11 February, the March quarter by 12 May, the June quarter by 11 August and the September quarter by 11 November. Group solvency in C 06.01 and C 06.02, being semi-annual, lands on the 11 August and 11 February dates.

First, the remittance dates are fixed by the EU regulation, not set nationally, so 11 February is 11 February whether or not Danish year-end accounts are finalised by then. Second, the ITS lets institutions submit unaudited figures and then correct them: where audited figures later deviate from the numbers already filed, the revised audited figures are submitted without undue delay, not deferred to the next quarter. When a remittance date falls on a weekend or a Danish public holiday, it rolls to the next working day.

For an evergreen planning view, the KOFS year runs on the same four dates every year.

Submission through e-Reg: xBRL-CSV, taxonomy and the move off FIONA

For Danish e-Reg file uploads, COREPOF is submitted in xBRL-CSV. EBA reporting framework 4.2 applies to COREP OF from the 31 March 2026 reference date, and reports with reference dates from 31 March 2026 onward must be submitted or resubmitted in xBRL-CSV. Article 23 of Regulation 2024/3117 leaves the data-exchange format for submissions to the competent authority, so national collection formats should not be described as identical in every Member State. Finanstilsynet is moving EU returns previously handled in FIONA to e-Reg in phases; EBA returns, including COREPOF, have already moved, while other reporting families follow Finanstilsynet’s published migration timetable. For own funds, the last FIONA submission covered the 31 December 2025 reference date and the first e-Reg submission covered the 31 March 2026 reference date. Finanstilsynet routes practical e-Reg questions to the mailbox e-Reg@ftnet.dk.

Each submission is identified by header information the ITS requires: the reporting reference date and period, the reporting currency, the accounting standard, the scope of consolidation and the institution’s LEI. Corrections follow the same route as the original filing and are expected without undue delay, not deferred in batches. For EBA file uploads to e-Reg, Finanstilsynet’s current guide specifies the filename syntax Identifier.rapporteringsniveau_modul_referenceperiode_tidsstempel.zip; firms should use the current guide and migration table to populate the module and reporting level.

Validation rules and the checks that send a KOFS file back

Before a KOFS submission reaches an analyst, it runs against the EBA validation rules that ship with each framework release. The EBA describes two validation-rule severity categories: Error and Warning. Failure of an Error rule causes immediate rejection, while a Warning does not cause immediate rejection but must be investigated and may require correction. The rule set is versioned alongside the taxonomy, and Finanstilsynet applies the EBA rules to Danish COREP filings. Our note on the EBA validation rules quarterly update tracks how that set changes from release to release.

For a specific e-Reg validation message, the applicable framework validation package and Finanstilsynet’s current e-Reg guidance should be checked before determining the cause. Finanstilsynet maintains a COREP questions-and-answers page for Danish-specific queries; where a validation result is ambiguous, that page and the e-Reg mailbox are the right first stop before guessing at intent.

Caveats and interactions: KOVER, proportionality and the neighbouring returns

The most Danish part of KOFS is the return that sits next to it. KOVER is Finanstilsynet’s national FIONA return for reporting the inclusion of the year’s profit or an interim profit in regulatory own funds, and Finanstilsynet’s KOVER page specifies quarterly filing at solo and group level. That page still states the resubmission trigger by reference to the former KOFS/KOFC compilations; because EU own-funds reporting moved to COREPOF in e-Reg from the 31 March 2026 reference period, the current KOVER treatment following a COREPOF correction should be confirmed against Finanstilsynet’s current instructions. Under CRR Article 26(2), an institution may include interim or year-end profits in Common Equity Tier 1 before it has taken the formal decision confirming its final annual profit or loss only with prior permission of the competent authority, after independent verification of the profits and deduction of foreseeable charges and dividends. A CET1 figure that includes interim or year-end profit depends on the applicable Article 26(2) permission conditions being satisfied; KOVER serves as the separate national return for reporting that inclusion. Under Finanstilsynet’s current migration information, KOVER remains a FIONA national return.

Proportionality shapes the rest. Small and non-complex institutions, as defined by the CRR entry and exit criteria, file less granular detail and some templates less frequently than large institutions, though the own funds obligation itself does not disappear. KOFS also interacts with returns beyond COREP. FINREP accounting equity and COREP regulatory own funds are different measures and should not be expected to equal each other; specific items may reconcile where the applicable reporting instructions require it, and the own funds requirement in C 02.00 is where the CRR3 output floor lands as it phases in. Danish institutions are filing the same EU module as their Nordic peers; the Swedish capital-requirement returns run on the same COREP own funds templates under Finansinspektionen.

Recent and upcoming changes: the e-Reg migration and CRR3 own funds fields

Two changes matter for KOFS teams. The first is the platform move already described: own funds shifted from FIONA to e-Reg at the 31 December 2025 to 31 March 2026 cutover, alongside asset encumbrance, the leverage ratio and large exposures on the same window. Other EU returns migrate on their own timelines, with DORA reporting already on e-Reg from the 31 December 2025 reference date and the Solvency II and alternative investment fund returns scheduled through 2026. A team should confirm which of its returns has already moved and which is next.

The second is content. The supervisory-reporting framework incorporates CRR3 changes including the output floor and revised credit-risk reporting. COREP OF uses the framework 4.2 technical package from the 31 March 2026 reference date, while the additional operational-risk reporting requirements introduced in framework 4.2 have a first reference date of 30 June 2026. For market risk, however, Regulation 2025/2475 extended the transition: institutions continue to report the specified market-risk own-funds requirements under Article 5(12) and templates C 18.00 to C 24.00 of Regulation 2021/451 until 31 December 2026. Those changes reach KOFS through the template set and the data point model, not through any change to the return code. The EBA also updates the taxonomy and validation rules across framework releases, so the practical maintenance task is to map each new data point model version to the internal reporting engine ahead of the reference date it first applies to. Our summary of the DPM changes for COREP and FINREP sets out how those releases are structured. Before the next remittance date, the two things worth confirming are which taxonomy version applies to the closing reference date and whether the e-Reg credentials and contact are current.

Frequently Asked Questions

If we file KOFC at group level, do we still owe KOFS at solo level?

Individual and consolidated reporting are separate reporting levels. Article 7(1) permits a competent authority to waive Article 6(1) for a qualifying subsidiary, while Article 7(3) separately permits a waiver for a qualifying parent institution. A parent should therefore determine its own individual-basis obligation from the waiver, if any, granted to that parent rather than from a waiver granted to a subsidiary.

What happens to the own funds figure if the year’s profit has not been verified yet?

Before the institution has taken the formal decision confirming its final annual profit or loss, CRR Article 26(2) permits interim or year-end profits to be included in Common Equity Tier 1 only with prior competent-authority permission, after independent verification and deduction of foreseeable charges and dividends. KOVER is Finanstilsynet’s separate national return for reporting the inclusion of such profit.

Does the 11 February deadline move if it falls on a weekend?

Yes. The ITS provides that where a remittance date is a Saturday, Sunday or a public holiday in the Member State of the competent authority, the file is due on the following working day. The same rule applies to 12 May, 11 August and 11 November.

Do small and non-complex institutions file the full KOFS template set?

They remain subject to own-funds reporting, with proportionality determined by the applicable CRR classification and ITS reporting provisions. Under Article 4(1) of Regulation 2024/3117, reporting linked to small and non-complex institution status starts or stops on the first reporting reference date following the date on which the institution meets or ceases to meet the CRR Article 4(1)(145) criteria. The separate two- and three-consecutive-reference-date rules in Article 4(3) apply to specified reporting thresholds, not to the small and non-complex classification itself.

We already submit FINREP. Does KOFS duplicate it?

FINREP and KOFS have different jobs. FINREP carries financial information drawn from the accounts; KOFS carries the regulatory own funds position. FINREP accounting equity and C 01.00 regulatory own funds can differ because they are based on different accounting and prudential definitions. Specific data points may be linked by reporting instructions, but the two totals should not be treated as equal; one return does not discharge the other.

Where do the credit and market risk numbers behind the requirement go?

Inside the own funds module. The standardised credit risk template C 07.00, the internal ratings-based templates in the C 08 series and the market and operational risk templates build the total risk exposure amount that C 02.00 reports. Large exposures, leverage and asset encumbrance are filed separately as their own Danish returns.

Related Articles

• COREP Reporting Explained: the EU-wide own funds and requirements framework that KOFS delivers in Denmark.
• FINREP Reporting Explained: the financial-information return whose accounting equity differs from the regulatory own funds in C 01.00.
• EBA Validation Rules Quarterly Update: how the Error and Warning rules that check a COREP file change each release.
• CRR3 Output Floor Phase-In: the requirement change that lands in the own funds template C 02.00.
• EBA 4.3 DPM Changes for COREP and FINREP: how the data point model and taxonomy releases behind KOFS are structured.
• Finansinspektionen Swedish Bank Capital Requirements: the same COREP own funds module as filed by Danish institutions’ Nordic peers.

Key Takeaways

• KOFS and KOFC are the former FIONA compilation names. From the 31 March 2026 reference period, e-Reg uses COREPOF with IND and CON reporting levels; individual and consolidated reporting obligations depend on the applicable CRR scope and any waiver granted to the relevant entity.
• The principal current reporting ITS is Commission Implementing Regulation (EU) 2024/3117, as amended, and it applies from 28 June 2025. Regulation 680/2014 was repealed by Regulation 2021/451; specified provisions of 2021/451 remain applicable through 31 December 2026 under the current transitional rules.
• Reference dates are 31 March, 30 June, 30 September and 31 December; remittance dates are 12 May, 11 August, 11 November and 11 February, rolling to the next working day on weekends and holidays.
• Group solvency templates C 06.01 and C 06.02 are semi-annual, due 11 August and 11 February.
• Own funds returns now file through e-Reg as COREPOF (IND/CON), not FIONA: the last FIONA reference date was 31 December 2025 and the first e-Reg reference date was 31 March 2026; EBA framework 4.2 and xBRL-CSV apply from that date.
• Before the institution has taken the formal decision confirming its final annual profit or loss, interim or year-end profit may be included in CET1 only when CRR Article 26(2)’s conditions and competent-authority permission are satisfied; KOVER separately reports the inclusion to Finanstilsynet.
• Before each remittance date, confirm the taxonomy version for the closing reference date and that e-Reg credentials are current; market-risk reporting under 2021/451 templates C 18.00 to C 24.00 continues until 31 December 2026.

Sources and References

• Regulation (EU) No 575/2013 (Capital Requirements Regulation), Article 430 and Article 26 (consolidated text as at 26 June 2026): eur-lex.europa.eu
• Commission Implementing Regulation (EU) 2024/3117 of 29 November 2024 (ITS on supervisory reporting, applying from 28 June 2025): eur-lex.europa.eu
• Commission Implementing Regulation (EU) 2025/2475 of 8 December 2025 (amending 2024/3117 on operational risk reporting and extending market-risk transitional provisions to 31 December 2026): eur-lex.europa.eu
• Commission Implementing Regulation (EU) 2021/451 (predecessor ITS, transitional provisions applicable through 31 December 2026): eur-lex.europa.eu
• Finanstilsynet, COREP reporting hub: finanstilsynet.dk
• Finanstilsynet, KOVER return (inclusion of the year’s profit in KOFC/KOFS): finanstilsynet.dk
• Finanstilsynet, returns migrating from FIONA to e-Reg (COREPOF/IND/CON mapping): finanstilsynet.dk
• EBA reporting framework 4.2 (xBRL-CSV taxonomy for COREP OF from 31 March 2026 reference date): eba.europa.eu

Where KOFS stands after the e-Reg switch

The quarterly reference and remittance calendar remains fixed, but the Danish filing identifiers and the EBA reporting framework have changed. From the 31 March 2026 reference period, e-Reg uses COREPOF with IND and CON reporting levels, and the applicable EBA framework and taxonomy must be checked for each reference date. What moved in Denmark was the channel and, through the 2024 ITS recast, some of the content inside the templates. For a reporting team, the recurring work is small and specific. Check that the taxonomy version matches the reference date now closing, confirm whether CRR Article 26(2) applies and, where it does, that the required competent-authority permission and conditions are satisfied before counting current-year profit in C 01.00, and file COREPOF through e-Reg by the applicable remittance date.

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.