BCL S 1.1 Reporting: Luxembourg’s Monthly Statistical Balance Sheet

RegReportingDesk card: BCL, Banque centrale du Luxembourg, Luxembourg

Every resident credit institution in Luxembourg sends the Banque centrale du Luxembourg (BCL) report S 1.1, the monthly statistical balance sheet, no later than 10 working days after each month-end. BCL S 1.1 reporting is the Luxembourg leg of the euro area balance sheet statistics required by ECB Regulation (EU) 2021/379, and the same file carries line 2-ERO000, the institution’s own calculation of its minimum reserve requirement.

That double role sets the stakes. The ECB checks the data before aggregating them with the other Member States’ figures, and in the months the BCL’s maintenance-period calendar earmarks, the liability lines also set the reserves the bank must hold over a later maintenance period. Since the April 2024 reference period, the BCL and the ECB have monitored compliance with statistical reporting requirements under Regulation (EU) 2022/1917. BCL circular letter ST.24-0013 referred to a EUR 200,000 sanctions ceiling when it was issued; Council Regulation (EU) 2026/415 has since amended Regulation (EC) No 2533/98, and the current sanctions limits should be read from the consolidated Article 7 of that regulation.

The version in force is Layout 6, mandatory from the January 2022 reference period and since adjusted by BCL circular letters, including one that moved Bulgaria into the euro area country group from January 2026.

Related reading: BCL S 0.1 Report: Daily Deposit Reporting for Luxembourg Banks

The obligation starts in Regulation (EU) 2021/379 of the European Central Bank of 22 January 2021 on the balance sheet items of credit institutions and of the monetary financial institutions sector (recast), ECB/2021/2, usually called the BSI Regulation. It is directly applicable. Article 5(1)(a) requires monetary financial institutions (MFIs) to report the end-month outstanding amounts specified in Table 1 in Part 2 of Annex I. Article 7(1) leaves the frequency and timeliness of collection to each national central bank, which must inform its reporting agents, and Article 7(2) gives the central bank until close of business on the 15th working day after month-end to pass monthly statistics to the ECB. Article 10(2) makes it responsible for the reporting arrangements its population follows.

Article 18 sets the dates: the Regulation applied from 26 June 2021, but Articles 5, 8 and 9, covering the reporting requirements, the accounting rules and the derogations, applied from 1 February 2022, which lines up with Layout 6 starting from January 2022 data.

The BCL implemented the recast through Circular BCL 2021/244 of 10 February 2021, “Modification of the statistical reporting from credit institutions”. It kept the existing table architecture, added items such as notional cash pool positions, non-financial real estate assets and equity raised, simplified the revolving credit and credit card items, and discontinued the investment and operating loan items. The first reports under the new collection related to the end of January 2022.

A second ECB instrument explains one line. Under Article 5(1) of Regulation (EU) 2021/378 (ECB/2021/1) on minimum reserves, institutions calculate their reserve base from the deposits and debt securities issued that they report under Regulation 2021/379. S 1.1 is that report in Luxembourg, which is why the reserve calculation sits inside it as line 2-ERO000-XX-XXX-90000.

The legal chain runs through the circular and the two ECB regulations, none of which the S 1.1 instructions themselves cite. Beside the five S 1.1 documents (instructions, template, compendium of verification rules, its annex and XML schemas), the cross-report documents on the BCL’s reporting instructions page also apply, including “Definitions and concepts for the statistical reporting of credit institutions” (July 2024, DCBAN L2) and the “Manual of electronic transmission” (February 2021). Where the French and English texts differ, the French text prevails.

Who must report S 1.1: resident credit institutions, Luxembourg branches included

The instructions answer in one sentence: report S 1.1 must be provided by all resident credit institutions regardless of their legal status. That matches Article 3(1) of Regulation 2021/379, under which the actual reporting population consists of MFIs and non-MFI credit institutions resident in the euro area.

“Regardless of their legal status” brings in the Luxembourg branches of banks incorporated elsewhere. The BCL’s Definitions document confirms their format: Luxembourg-law credit institutions without foreign branches, and Luxembourg branches of credit institutions governed by foreign law, report in a single version, called version L.

Luxembourg-law banks with foreign branches need more care. The same document says they provide some statistical reports in two versions, version L for the Luxembourg head office and version N for the whole entity, with intra-group transactions eliminated in line with FINREP template F 31. The transmission manual gives S 1.1 a single file name, S0101_L6, while the quarterly balance sheet appears as S 2.5-L and S 2.5-N. My reading, which the S 1.1 documents do not state in a sentence, is that S 1.1 covers the resident Luxembourg business, consistent with the residency basis of the ECB Regulation.

The S 1.1 instructions contain no size threshold. Article 9 of Regulation 2021/379 lets national central banks grant derogations, for instance to small MFIs whose combined contribution stays within 5% of the total assets of the national MFI balance sheet, or to non-MFI credit institutions with total assets of EUR 350 million or less, and even then the central bank must keep collecting the information needed for the reserve base. The BCL’s S 1.1 instructions mention no derogation, so on the published documents the default for a resident credit institution is the full monthly report.

The file format separates two roles. The declarant is the entity whose data are reported; the reporter is the entity that submits the file. Each is identified by a type and the identification number allocated by the CSSF: type 23, letter B in the file name, for banks, and type 32, letter P, for professionals of the financial sector. The format therefore provides for a PSF to send S 1.1 on a bank’s behalf while the bank remains the declarant.

What the report contains: seven sub-tables and a five-part line key

The template has three main sub-tables and four detail sub-tables. The instructions describe the detail sub-tables as additional information on lines in the main ones and keep them out of the totals.

Sub-table What it holds
Assets Cash; loans by country group, currency, counterparty sectors and initial maturity; single totals for debt securities held and equity; non-financial assets; derivatives; remaining assets; total assets
Assets Details 1 Household loans by purpose; revolving loans, overdrafts and credit card credit; loans to affiliated entities; reverse repos with central counterparties; syndicated loans; notional cash pool positions; loans to the ECB (XA) and the EIB (XE); loans with initial and residual maturity over 12 (or 24) months and an interest rate reset within the next 12 (or 24) months
Assets Details 2 Lending for house purchase to households, with the additional initial-maturity breakdown specified in the S 1.1 Layout 6 template
Liabilities Overnight, agreed-maturity and notice deposits and repos by country group, currency, sector and maturity; short sales; debt securities issued; capital, reserves, provisions, value adjustments and results; derivatives; remaining liabilities; total liabilities; line 2-ERO000
Liabilities Details 1 Transferable deposits; notional cash pools; fiduciary deposits; debts to affiliated entities; syndicated borrowings; amounts attributable to institutions subject to reserve requirements (sector codes MRR02 and MRR01); debt securities issued with a nominal capital guarantee below 100%
Off-balance Credit lines and guarantees granted, by country group and sector; holdings of the bank’s own debt securities and equity
Off-balance Details 1 Credit lines and guarantees granted to affiliated entities

Every cell has a line identifier built from four codes plus a maturity column. In 1-002000-LU-EUR-22000, item 1-002000 is loans (the leading 1 marks assets, 2 liabilities and 3 off-balance sheet items), LU the counterparty country, EUR the currency and 22000 the sector, households and non-profit institutions serving households. The amount is reported in the applicable initial-maturity column. The precise XML element names, line identifiers and permitted combinations must be taken from the BCL’s S 1.1 Layout 6 schema package.

Only the breakdowns shown in the template are reported, using the codes in the Definitions document. Countries use LU, the ISO 3166 code for Luxembourg, and the BCL aggregation codes X3 for the other Monetary Union member states and X4 for the rest of the world. In the detail sheets XA stands for the ECB and XE for the European Investment Bank, and the Definitions document places them in different groups: XA is aggregated in X3, XE in X4. Currencies split into EUR and XX2, all currencies except the euro. Sectors use five-character codes from 11000 (central government) to 46000 (pension funds), with 90000 where no sector breakdown applies.

Maturity breakdowns differ between asset and liability items. Report only the maturity columns specified for each line in the BCL’s S 1.1 Layout 6 template, using the corresponding initial-maturity codes in the Definitions document. The no-breakdown codes I999-999 (maturity) and XXX (currency) may be used only where the instructions request them.

Amounts are reported in the institution’s accounting currency, with up to five decimals, as specified in section 2.3 of the BCL’s Definitions document. The XML header must follow the element names and constraints in the published S 1.1 Layout 6 schema. Beyond the minimum standard that reporting agents follow the BCL’s rounding policy, the documents reviewed do not set out a rounding rule.

Valuation follows supervisory reporting with one exception: loans and deposits are reported at nominal value at month-end, the principal the debtor is contractually obliged to repay, without regard to provisions and value adjustments and excluding write-offs and write-downs. Article 8(2) of Regulation 2021/379 sets the same principal-outstanding rule and bars netting loans and deposits against other assets or liabilities. Provisions and value adjustments have their own liability lines, 2-008000 and 2-009000.

Interest needs a split. Under the Definitions document, interest accrued but not yet due goes to the accrued interest items 1-090010 or 2-090010, with any maturity breakdown following the underlying loan or deposit, while interest accrued and due stays in the loan or deposit line itself. A ledger that books both to one accrual account has to be split before S 1.1 can be filled.

Derivatives with a market value should generally be recorded gross, with positive market values on the asset side and negative market values on the liability side. The BCL’s Definitions document also permits reporting the available net positions, or positions recorded at another valuation, where only those amounts are available. Of the lines that carry one figure with no country, currency or sector breakdown, four have their detail in the security-by-security report TPTBBL: debt securities held (1-003000), equity (1-005000), short sales (2-002050) and debt securities issued (2-003000). Section 4.2 of the instructions also keeps 2-005010, 2-005020, 2-010010, 2-010999 and 2-ERO000 out of total liabilities.

S 1.1 deadlines: ten ECB working days and the reserve maintenance calendar

The reference date is, in principle, the last day of each month, and the instructions require S 1.1 to reach the BCL no later than 10 working days after the end of the reference period. The BCL publishes a calendar of remittance dates each year, and a footnote ties the count to the working days the ECB defines for national central banks’ statistical transmissions. My working assumption is to take each date from that calendar instead of counting on a local holiday calendar.

The window leaves the BCL five working days before its own 15th-working-day deadline under Article 7(2) of Regulation 2021/379, a point Circular 2021/244 makes when it asks banks to respect the BCL’s deadlines scrupulously. The cycle runs apart from the CSSF’s prudential deadlines, which our CSSF reporting calendar covers.

Each month-end is a reference date, and the month now closing is due on the tenth ECB working day of the following month. The 2026 calendar, issued in December 2025, sets these dates, shown next to the BCL’s 2026 calendar of maintenance periods for minimum reserves:

Reference month S 1.1 due Maintenance period it serves
January 2026 13 February 2026 2026MP2, starting 25 March 2026
February 2026 13 March 2026 None listed
March 2026 16 April 2026 2026MP3, starting 6 May 2026
April 2026 18 May 2026 2026MP4, starting 17 June 2026
May 2026 12 June 2026 2026MP5, starting 29 July 2026
June 2026 14 July 2026 None listed
July 2026 14 August 2026 2026MP6, starting 16 September 2026
August 2026 14 September 2026 None listed
September 2026 14 October 2026 2026MP7, starting 4 November 2026
October 2026 13 November 2026 2026MP8, starting 23 December 2026
November 2026 14 December 2026 None listed
December 2026 15 January 2027 Outside the 2026 maintenance calendar

S 1.1 shares its 2026 dates with S 1.4, S 1.8, S 1.9, S 1.12-L and TPTBBL; S 1.5, the interest rate report, falls a few days later.

The right-hand column follows Article 5(5) of Regulation 2021/378: the reserve base for a maintenance period uses the data for the month two months before the month in which the period starts. Maintenance periods do not start every month, so in 2026 the February, June, August and November reports serve none. The ERO000 line is still mandatory in each of them, because the compendium lists it among the lines that must be provided even with zero values. The maintenance calendar also gives a freeze date for the final amounts to maintain, for example 4 February 2026 for the period starting 11 February 2026, which drew on December 2025 data.

The instructions close the loop: if the BCL does not question the 2-ERO000 amount before the maintenance period starts, the institution considers it correct and fulfils its reserve requirement on that basis. Under section 2.5 of the Definitions document, reporting agents keep monthly and quarterly statistical reports and related documents for 24 months.

Submission of the S0101 XML file through Sofie or e-file

S 1.1 goes to the BCL as an XML file built to the BCL’s schema. The BCL publishes an XML schema package for S 1.1 Layout 6 alongside its reporting instructions. Implementers must validate the submission against that package and apply the corresponding reporting dimensions, code lists and transmission specifications. The general electronic-transmission manual does not itself establish the detailed XML element hierarchy or schema-version attributes.

XML schema validation is necessary but not sufficient. The BCL’s transmission manual warns that a code may satisfy schema format constraints without being valid under the applicable nomenclature. Duplicate-key restrictions, element-level constraints and aggregation requirements must therefore be checked against the actual S 1.1 Layout 6 XSD files and the verification-rule annex.

The manual sets the file name for monthly reports with a layout as S0000_L0_yyyymm_Rrrrrrrrrr_Dddddddddd_yyyymmdd_nnn. For S 1.1 that is S0101_L6, the reference year and month, the reporter type letter and nine-digit CSSF number, the declarant type letter and number, the file’s creation date and a sequence number. Numbers are left-padded with zeros, so bank 999 becomes 000000999, and the sequence restarts each day at 001; 000 must not be used. An illustrative filename constructed from the BCL’s published naming convention is S0101_L6_202201_B000000999_B000000999_20220210_001.xml: a January 2022 report from bank 999 for bank 999, created on 10 February 2022.

The transmission manual names two channels, Sofie and e-file, and says the BCL is willing to accept any new secure channel both sides accept. E-mail is closed: circular letter ST.24-0013 of 15 January 2024 told reporters that the BCL no longer accepts statistical reports by e-mail.

The BCL’s April 2025 feedback document, which covers S0101 among other collections, describes a staged migration of feedback delivery to Sofie and e-file, with notification by report type before the first transmission through those channels. It describes FL-OK or FL-NOK on whether the file has technical errors, DQ-FDB for data points the BCL needs corrected or confirmed, and ADHC-FDB for requests outside the ordinary cycle. Feedback file names start with FDBBUSI and include the name of the file answered. The move away from e-mail aligns with the process banks know from BCL AnaCredit reporting. Each feedback states its own deadline, and the document places compliance with it inside the ECB’s non-compliance framework.

On corrections the S 1.1 documents are thin. The sequence number distinguishes files created on the same day for the same report, and the minimum standards require reporting agents to follow the BCL’s revisions policy and to explain revisions that deviate from regular revisions. None of the documents reviewed describes a separate resubmission procedure or how a replacement file is treated.

Validation: the S 1.1 compendium, its annex and the TPTBBL cross-checks

The compendium of verification rules (April 2022) states that, for the time being, S 1.1 has permanent rules only, which the BCL invites software providers to implement. A short list sits in the compendium; the detail sits in an annex workbook where every rule has an identifier.

Three global rules come first. Lines 1-000000, 2-000000 and 2-ERO000 must be provided even if zero. The sum of all breakdowns of total assets must equal that of total liabilities. And every line must have what the compendium calls a credit trend, which I read as a positive amount, except a listed set allowed a debit trend: accrued interest and other remaining assets (1-090010, 1-090999), reserves (2-007000), the results lines (2-010000, 2-010010, 2-010999), accrued interest on liabilities (2-090010), and total liabilities in its no-breakdown maturity column only.

The annex groups the detailed rules by sheet:

  • Zero-value cells. The Assets – 1, Liabilities – 1 and Off-balance sheet – 1 sheets identify cells required to contain zero values.
  • Hierarchy checks. The compendium identifies simple and complex hierarchy checks covering assets, liabilities and off-balance-sheet items.
  • Total exclusions. Dedicated asset and liability sheets identify lines that must be excluded when calculating the corresponding totals.
  • Warnings. The Liabilities – 5 sheet contains hierarchical relationships that generate warnings rather than errors.
  • Reserve requirement. The reserve-requirement sheet covers the calculation of 2-ERO000, which is also explained in section 5 of the S 1.1 reporting instructions.

The compendium adds four checks against TPTBBL: S 1.1 lines 1-003000, 1-005000, 2-002050 and 2-003000 must each correspond to the totalReportedAmount TPTBBL reports for the same balance sheet line. Both reports fall due the same day, so the reconciliation belongs in the same close.

Behind the rule book sit the Annex IV minimum standards for transmission, accuracy, compliance with concepts and revisions, which Article 10(1) of Regulation 2021/379 imposes and section 6 of the Definitions document restates.

Since 30 April 2024 those standards have been enforced through Regulation (EU) 2022/1917 (ECB/2022/31) on infringement procedures, which repealed Decision ECB/2010/10. Circular letter ST.24-0013 explains that, from the April 2024 reference period, the ECB and BCL record alleged infringements detected during each production month. Its EUR 200,000 sanctions figure reflects the law when the circular was issued. Council Regulation (EU) 2026/415 has since amended Regulation (EC) No 2533/98, so the current maximum fines and penalty payments should be taken from the consolidated Article 7 of that regulation rather than from the circular. Systematic or intentional failure to report on time, correctly, completely or in the prescribed form, and failure to cooperate effectively with the BCL, are recorded as serious misconduct.

The BCL’s April 2025 feedback guidance distinguishes FL-NOK, indicating technical errors in a submitted file, from DQ-FDB, identifying data points requiring correction or confirmation. It does not establish a comprehensive mapping of individual schema, file-naming, reconciliation or reserve-base failures to specific feedback types. Reporting agents should assess these issues against the applicable verification rules and the deadline stated in any feedback received.

Caveats: reserve-base mechanics, dated wording and overlapping returns

The 2-ERO000 computation has the most moving inputs in S 1.1. Section 5 of the instructions builds it in four steps:

  • Reserve base at 1%: overnight deposits, deposits with agreed maturity or notice up to and including 2 years, and debt securities issued with an initial maturity up to and including 2 years.
  • Reserve base at 0%: longer agreed-maturity and notice deposits, repurchase agreements and debt securities issued over 2 years.
  • Deductions: liabilities to the ECB, the EIB, euro area national central banks and institutions subject to the Eurosystem’s reserve requirements, reported in the MRR02 (deposits) and MRR01 (debt securities) lines and checked against the ECB’s official list of institutions subject to minimum reserves.
  • Allowance: EUR 100,000 deducted from the gross requirement.

The 2021 instructions word two inputs as provisional, a 15% standardised deduction for debt securities issued “for the time being” and the EUR 100,000 allowance. The ECB’s minimum reserve calculation page still shows both: 15% for debt securities with a maturity of up to two years for maintenance periods starting from 14 December 2016, and the EUR 100,000 lump-sum allowance since 1 January 1999, with the 1% ratio in place since 18 January 2012. The EUR-Lex consolidated text of Regulation 2021/378 dated 20 September 2023 carries the ratios in Article 6(1) and the allowance in Article 6(2). An MRR01 amount above 15% of line 2-003000-XX-XXX-90000 needs evidence, sent with S 1.1, that the actual holders are subject to the ECB’s reserve requirement.

The instructions’ worked example shows the arithmetic: a 1% reserve base of EUR 11,217,750 gives a gross requirement of EUR 112,178, and after the allowance the net EUR 12,178 goes into 2-ERO000. On 27 July 2023 the ECB set the remuneration of minimum reserves at 0% from the maintenance period starting 20 September 2023. That changed what the reserves earn; the duty to calculate the requirement in S 1.1 and hold it stayed.

The documents also carry dated references. The Definitions document still grounds the nominal-value rule for loans and deposits in Regulation ECB/2004/21, while the current text is Article 8(2) of Regulation 2021/379. And the S 1.1 instructions, template and schema all predate the July 2024 Definitions edition and the 2024 and 2025 circular letters, which a build has to read alongside them.

Counterparty classification drives most breakdowns. The BCL’s July 2025 euro adoption circular letter tells banks to identify counterparties with the CSSF’s official list of credit institutions and the ECB’s MFI list, and the S 1.1 instructions point to the ECB’s list of institutions subject to minimum reserves for the MRR lines. Article 4(3) of Regulation 2021/379 shields a reporting agent that relied in good faith on an incorrect version of the ECB’s MFI list from ECB sanctions. Germany applies the same BSI Regulation with its own classification scheme, covered in our article on the Bundesbank customer classification for MFI statistics.

Overlaps sit in a few places. TPTBBL carries the securities detail behind four S 1.1 lines. The quarterly balance sheet S 2.5 comes in L and N versions and breaks countries down by two-digit ISO code; the Bulgaria circular letter found no impact on it because its sector breakdown is identical for all countries. S 1.4 on valuation effects and S 1.8 on securitisations and loan transfers use the same monthly country groupings as S 1.1. On the supervisory side, the Definitions document aligns valuation with prudential reporting except for loans and deposits and models the L and N versions on FINREP template F 31, so a bank whose FINREP reporting runs on the same data can start from shared mappings, with the nominal-value adjustment applied.

Changes to S 1.1 since Layout 6, from Bulgaria to IReF

Date Source Effect on S 1.1
10 February 2021 Circular BCL 2021/244 Layout 6 implements Regulation 2021/379, mandatory from January 2022 data (Layout 5 ran from December 2014 to December 2021)
26 January and 21 April 2022 Compendium annex and compendium Current verification rule set
15 January 2024 Circular letter ST.24-0013 Regulation 2022/1917 applies from 30 April 2024; e-mail transmission no longer accepted
July 2024 Definitions and concepts, DCBAN L2 Current general definitions
April 2025 Feedbacks for the statistical reports Feedback moving to Sofie and e-file in stages
31 July 2025 Circular letter ST.25-0366 Bulgaria in the other Monetary Union member states group from January 2026 data
8 June 2026 ECB press release on IReF Consultation planned for the second half of 2027; first official IReF reporting in the second quarter of 2031

The Bulgaria letter changed the content of S 1.1 directly. On 8 July 2025 the EU Council approved Bulgaria’s accession to the euro area on 1 January 2026, and from that date the other Monetary Union member states category includes Bulgaria, which until 31 December 2025 sat in the rest of the world. The new classification applies first to the reports for January 2026, and liabilities to the Bulgarian central bank and to Bulgarian credit institutions subject to the Eurosystem’s reserve requirement leave the reserve base. For the maintenance periods starting 23 December 2025 and 11 February 2026, banks could deduct them early by completing an annex table for October and December 2025, and the BCL undertook to adjust the reserve requirements reported in those months’ S 1.1 on that basis.

The longer horizon is the ECB’s Integrated Reporting Framework (IReF). On 8 June 2026 the ECB announced a public consultation on the draft IReF Regulation in the second half of 2027, a one-year pilot phase starting in the second quarter of 2030, and first official reporting in the second quarter of 2031, with an initial one-year parallel phase in which existing statistical reporting within the IReF’s scope continues. The timelines are subject to adoption of the IReF Regulation. The ECB’s April 2024 IReF overview lists the BSI Regulation (ECB/2021/2) among the regulations in scope, for MFIs and non-MFI credit institutions, with money market funds left out. Neither the announcement nor the BCL’s IReF page names S 1.1 or gives it an end date; the BCL says an implementation plan, still being prepared, will set out how national collection frameworks evolve.

Frequently Asked Questions

Do positions with the ESM, the EFSF or the Single Resolution Board go to X3 or X4?

The Definitions document aggregates the European Stability Mechanism (XI) and the European Financial Stability Facility (XJ) in X3, alongside the ECB. The Single Resolution Board (XN), the EIB (XE) and the Bank for International Settlements (XH) aggregate in X4. A deposit from the ESM therefore sits with Monetary Union counterparties, while a loan to the Single Resolution Board is a rest-of-the-world position.

If December 2025 data are corrected after January 2026, does Bulgaria count as X3?

Circular letter ST.25-0366 says S 1.1, S 1.4, S 1.5, S 1.8 and S 2.5 must treat Bulgaria as outside the Monetary Union up to and including 31 December 2025. On that wording, a corrected December 2025 report keeps Bulgarian counterparties in the rest of the world.

Which exchange rate converts positions held in other currencies?

Section 2.3 of the Definitions document requires conversion into the accounting currency at the exchange rate prevailing on the day on which the report is compiled. The S 1.1 documents name no rate source, a question to put to the BCL where the accounting system uses a different convention.

Does the 15% standardised deduction apply to all debt securities issued?

Article 5(3) of Regulation 2021/378 applies the standard deduction only to debt securities issued with an original maturity of up to and including two years, where the institution cannot evidence the holders. The instructions’ worked example applies 15% in the bands up to two years and reports zero beyond, where the ratio is 0% anyway.

Do liabilities to our own head office outside the euro area count in the reserve base?

Yes. Article 5(1) of Regulation 2021/378 includes liabilities owed to a branch, head office or registered office of the same entity located outside the euro area. My reading is that in S 1.1 they sit in the rest-of-the-world lines and stay out of the MRR02 deduction, since such a head office is not on the ECB’s list of institutions subject to minimum reserves.

Can a remedial plan head off an infringement procedure?

Circular letter ST.24-0013 says that, except for serious misconduct or suspected infringements of the money market statistics obligations under Regulation (EU) No 1333/2014, a reporting agent may submit a remedial plan once it has been warned of an alleged infringement and the accumulated alleged infringements reach the threshold for a procedure. If the plan is approved and implemented, the BCL does not open a procedure for the same alleged infringement before the final deadline, or its extension, expires.

What does a merger of two reporting banks change for S 1.1?

Article 11 of Regulation 2021/379 requires a reporting agent to notify the national central bank, a reasonable time in advance and once the intention is public, of a merger, division or other reorganisation likely to affect its reporting, specifying how the requirements will be met. Where the merger takes effect between the end of a reference period and the BCL’s reporting deadline for that period, Article 11(3) requires the acquiring institution to report for the acquired institutions for that period as if the merger had not occurred. For a merger during a reference period, Article 11(4) lets the national central bank permit the acquiring institution to report the acquired institutions separately, for no longer than six months after the merger.

Key Takeaways

  • Load each year’s BCL remittance calendar into the close plan when it appears; its dates follow ECB working days.
  • Give 2-ERO000 a second review in months the maintenance calendar ties to a maintenance period, checking MRR counterparties against the ECB’s reserve list.
  • Report an MRR01 deduction above 15% of debt securities issued only with the evidence on holders attached to the same submission.
  • Reconcile 1-003000, 1-005000, 2-002050 and 2-003000 to TPTBBL before either file is released.
  • Map accrued-but-not-due interest to 1-090010 and 2-090010; leave accrued-and-due interest in the loan or deposit line.
  • Submit S 1.1 through Sofie or e-file, unless another secure transmission arrangement has been expressly agreed with the BCL. Do not submit statistical reports by e-mail, and retain reports and related supporting documents for 24 months.
  • Put the IReF consultation planned for the second half of 2027 on the watch list; the BSI Regulation behind S 1.1 is within IReF’s scope.

Sources and References

  • Regulation (EU) 2021/379 (ECB/2021/2), BSI Regulation: EUR-Lex
  • Regulation (EU) 2021/378 (ECB/2021/1) on minimum reserve requirements, consolidated text of 20 September 2023: EUR-Lex
  • Regulation (EU) 2022/1917 (ECB/2022/31) on infringement procedures for statistical reporting: EUR-Lex
  • BCL, S 1.1 Monthly statistical balance sheet, report page: bcl.lu
  • BCL, Report S 1.1 L6 reporting instructions (February 2021): PDF
  • BCL, Report S 1.1 L6 template: XLS
  • BCL, Report S 1.1 L6 compendium of verification rules (April 2022): PDF
  • BCL, Annex to the compendium of verification rules: XLS
  • BCL, S 1.1 Layout 6 XML schemas: ZIP
  • BCL, Definitions and concepts for the statistical reporting of credit institutions (July 2024): PDF
  • BCL, Manual of electronic transmission (February 2021): PDF
  • BCL, Feedbacks for the statistical reports (April 2025): PDF
  • BCL, Calendar of remittance dates 2026: PDF
  • BCL, Maintenance periods for minimum reserves 2026: PDF
  • Circular BCL 2021/244 (10 February 2021): PDF
  • BCL circular letter ST.24-0013, Monitoring compliance with statistical reporting (15 January 2024): PDF
  • BCL circular letter ST.25-0366, Adoption of the euro by Bulgaria (31 July 2025): PDF
  • BCL, Project: Integrated Reporting Framework (IReF): bcl.lu
  • ECB, How to calculate the minimum reserve requirements: ecb.europa.eu
  • ECB press release on remuneration of minimum reserves (27 July 2023): ecb.europa.eu
  • ECB press release on IReF milestones (8 June 2026): ecb.europa.eu
  • ECB, IReF Overview (April 2024): PDF
  • Council Regulation (EU) 2026/415 amending the ECB statistical-reporting legal framework: EUR-Lex
  • Council Regulation (EC) No 2533/98, consolidated text as at 12 March 2026, Article 7 (sanctions): EUR-Lex

Preparing the next S 1.1 monthly file

The reserve line and the TPTBBL totals ride on the same remittance date as the balance sheet. For the month now closing, the deliverable is an S0101_L6 XML file sent through Sofie or e-file by the date in the BCL’s remittance calendar, the tenth ECB working day of next month, with the TPTBBL reconciliation and the ERO000 working paper filed for the 24-month retention period.

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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