EBA Reporting Framework 4.4 Final Package: The Phase 1 Build List

On 12 October 2026 the European Banking Authority released the final technical package for phase 1 of EBA reporting framework 4.4, a few weeks after the September 2026 publication it had announced alongside the draft on 24 July. The package fixes the Data Point Model (DPM), the XBRL taxonomies and the validation rules for reporting requirements behind an IFRS 18-aligned FINREP module, amended Pillar 3 disclosures on ESG risks, equity exposures and shadow banking, FRTB-related disclosure templates, technical corrections to resolution planning and MREL decisions, a fix to third-country branch liquidity template E 09.02, and two AMLA data collections. The earliest first reference date in the set is 31 December 2026.

For EU reporting and disclosure teams the job now is a rebase. Builds started on the July draft need the final artefacts. Institutions that report FINREP under IFRS have a choice to settle with their competent authority about using IFRS 18 templates from the 31 March 2027 reference date. And the much larger simplification changes stay out of this build until a second package, which the EBA now expects in early 2027.

Two strands also run ahead of their legal acts. The amended Pillar 3 ITS was a final draft awaiting Commission adoption when the package came out, and the FINREP templates behind the IFRS 18 module belong to an amending ITS the EBA expects to submit to the Commission by the end of 2026. The package settles the data format; the legal obligation still depends on adoption.

Related reading: our note on the July 2026 draft of the EBA 4.4 technical package sets out the draft scope that this final release replaces.

EBA reporting framework 4.4 phase 1: the dates in one table

The EBA’s framework 4.4 page labels these as expected first reference dates and states that release 4.4 “is expected to apply from Q4 2026”. The table pairs each date with the status of the text behind it, because the date and the legal status do not always move together.

The surrounding calendar matters just as much for planning:

• 24 July 2026: draft 4.4 phase 1 package published; comments closed on 24 August 2026.
• 12 October 2026: final 4.4 phase 1 package published.
• End of 2026: paragraph 21 of the IFRS 18 Opinion says competent authorities should receive institutions’ notifications and then inform the EBA of the option chosen by the end of the year 2026.
• January 2027: a targeted hotfix release, only if critical implementation issues surface.
• Early 2027 (expected): the phase 2 (4.4.1) technical package for the supervisory reporting simplification.
• End of September 2027: expected first application of the amended FINREP ITS, at which point the interim IFRS 18 module ceases to apply.

Most phase 1 items have expected first reference dates in December 2026 or March 2027. However, the Pillar 3 disclosure amendments for small and non-complex institutions remain a phase 1 item with an expected first reference date of 31 December 2027. Phase 2 separately includes benchmarking changes from June 2027, broader supervisory reporting amendments from September 2027 and DORA technical amendments from December 2027.

What the final technical package contains

The 4.4 page lists the artefacts under numbered headings. Verify the publication date and version identifier of each downloaded artefact against the final EBA release, because some items on the page carried draft labels from the July stage:

• Validation rules and scope (item 2), linked to the EBA’s validation rules packages page.
• DPM 4.4 phase 1 (item 3.A): the DPM 2.0 database, a full glossary export and a glossary usage exploration file, the annotated table layouts with data point categorisation, an identical-cells file, and the DPM 1.0 to DPM 2.0 glossary conversion file with its instructions.
• DPM known issues (item 3.B), in a file labelled as the September 2026 update.
• EBA XBRL 4.4 phase 1 (item 4): the full taxonomy, the taxonomy package and sample files.
• The FAQ for release 4.4 phase 1 (item 5).

Two limits follow from the press release wording. The EBA’s final-release announcement describes the phase 1 validation rules as being “for reporting requirements only”. The EBA’s release notes for 4.1 and 4.2 record that all validation rules in the Pillar 3 framework are deactivated because the disclosure ITS does not require them, so the final 4.4 release notes are where to confirm whether that still holds for the Pillar 3 modules. And the DPM comes in one form: the EBA stopped producing DPM 1.0 with release 4.2, so the 4.4 database is DPM 2.0, and the conversion file is the bridge for anyone still mapping from the old glossary.

The release notes that shipped with the July draft name the modules affected. The final notes sit inside the full taxonomy archive and are the version to check, but the draft list shows where the work falls:

The final release goes beyond that list. The July announcement carried a disclaimer that two pieces were still missing: the validation rules on AML eligibility and the revised templates for AMLA’s 2027 risk-assessment collection. The October press release lists the revised risk-assessment templates alongside the eligibility templates, and it adds the E 09.02 correction, which the July list did not mention.

The draft notes carry a captioning inconsistency. They caption the three taxonomy packages as the “4.3” dictionary, severity and framework packages, while the file names read EBA_XBRL_4.4_Dictionary_4.4.0.0, EBA_XBRL_4.4_Severity_4.4.0.0 and EBA_XBRL_4.4_Reporting_Frameworks_4.4.0.0. Go by the file names.

IFRS 18 in FINREP: optional templates with interim codes

IFRS 18 was endorsed in the EU by Commission Regulation (EU) 2026/338 of 13 February 2026 and applies to institutions’ financial statements for accounting periods beginning on or after 1 January 2027. The amended FINREP ITS, which amends Commission Implementing Regulation (EU) 2024/3117 under Article 430(7) CRR, is expected to apply only from the end of September 2027. To cover the gap, the EBA’s Opinion EBA/Op/2026/07 of 8 July 2026, addressed to competent authorities, advises them to allow institutions that wish to do so to report their profit or loss data on revised IFRS 18-aligned templates during the interim period, with every other requirement of CIR 2024/3117 unchanged.

The 4.4 phase 1 IFRS18 module is the technical side of that option. Its 31 March 2027 first reference date is the first quarter-end at which the templates can be used. Whether a given institution uses them depends on its competent authority allowing the option and on the institution choosing it. Paragraph 21 of the Opinion says authorities should receive notifications from institutions in their jurisdictions and then inform the EBA of the option chosen by the end of the year 2026. Our earlier note on the IFRS 18 interim FINREP templates covers the reshaping of the profit or loss statement in more depth.

The Opinion assigns interim labels in the 4.4 phase 1 package to keep these templates apart from the technical tables still in force under release 4.2:

The numbering needs care. The Opinion lists the interim labels in the same order as the affected templates, which pairs F 16.04 with F 16.04.2 and F 16.04.1 with F 16.04.1.1, a pairing that is easy to cross-wire in a lookup table; confirm it against the final IFRS18 module before keying a mapping on it. The labels are also temporary by design: once the amended ITS apply, the Opinion says the templates move into phase 2 of release 4.4, the original labels are reinstated and the phase 1 IFRS 18 module ceases to apply.

The calendar does not change for institutions that take the option. The Opinion asks authorities to keep the frequencies, reference dates and remittance dates in Articles 2, 3, 11 and 12 of CIR 2024/3117, and to require submission under Article 23 of that Regulation, respecting the DPM data point definitions and validation formulae of the 4.4 phase 1 package.

The draft-stage layouts carried a warning worth acting on. A note on the 4.4 page during the draft stage said some cell signs in the table layouts of F 02.01, F 02.01dp and F 20.03.1 did not represent the effective signs in the DPM database, and that the issue would be fixed in the final publication. Teams that took sign conventions from the July layouts have reason to re-check them against the final DPM database.

Pillar 3 ESG, equity and shadow banking: the DPM arrives before the legal act

The disclosure changes implement the EBA’s final draft ITS EBA/ITS/2026/02 of 22 June 2026, which amends Commission Implementing Regulation (EU) 2024/3172 under the mandates in Articles 434a and 449a CRR. It reflects three CRR3 changes: the revised ESG disclosure requirement in Article 449a, the new disclosure of aggregate exposure to shadow banking entities in Article 449b, and the amended equity exposure disclosure in Article 438(e). The press release describes the phase 1 package as implementing the requirements “as set out in the final draft amending Pillar 3 Implementing Technical Standards”, together with selected FRTB-related disclosure templates.

The draft act replaces Section 21 of Annex I (ESG), adds a new Section 23 with template EU SB1 for shadow banking through a new Article 23a, replaces template EU CR 10.5 for equity exposures, and swaps in revised versions of EU CQ5, EU CMS2, EU LIQ2 and EU CVA2. Its Article 2 provides for entry into force on the twentieth day after publication in the Official Journal and application from 1 December 2026.

The ESG part is proportionate, and the template set depends on the CRR category of the discloser:

Disclosure templates sit in a DPM because of the Pillar 3 Data Hub. According to the EBA’s June 2026 discussion paper EBA/DP/2026/02, the hub went live for large and other institutions on 26 January 2026, with centralised disclosures available from the June 2025 reference date; those institutions submit their Pillar 3 data and the EBA publishes it without transformation. For SNCIs the EBA is mandated to prepare and publish the disclosures itself from supervisory reporting data, a process it is still rolling out. That is why the package updates Pillar 3 modules (the July draft notes name CODIS, ESGDIS, FINDIS, GSIIDIS and P3DH) alongside the supervisory returns.

Seeing ESG templates in a final taxonomy invites the assumption that the amending ITS is in force. On 13 October 2026 the EBA’s page for the ITS still showed it as a final draft submitted to the Commission, marked not yet applicable, with no application date filled in. Any change the Commission makes on adoption sits outside this package. Our earlier analysis of the CRR3 Pillar 3 ESG, equity and shadow-banking ITS goes through the template content.

The FRTB-related disclosure templates carry a 31 March 2027 first reference date on the 4.4 page. The July announcement said the draft reflected the impact of the third FRTB Delegated Act on disclosures. They are disclosure templates; the expansion of FRTB supervisory reporting (ASA details, AIMA) is a phase 2 item.

Resolution, MREL decisions and E 09.02: corrections that still change files

For resolution planning, MREL decisions and Pillar 3 templates, phase 1 implements technical amendments and corrections to the DPM and taxonomy identified in the list of DPM known issues the EBA published on 9 April 2026. The July draft notes record updated RESOL1 and RESOL2 modules and an updated MREL_DECISIONS module. Both carry a 31 December 2026 first reference date.

Template E 09.02 belongs to the third-country branch liquidity reporting introduced with release 4.3. The October press release describes corrections to it following the identification of taxonomy and DPM inconsistencies. TCB reporting itself rests on the ITS the EBA developed under Article 48l(1) CRD, which the Commission has since adopted as Commission Implementing Regulation (EU) 2026/1757, applicable from 28 March 2027; the first reference date is 31 March 2027.

The EBA characterises these changes as technical amendments and corrections to the DPM and taxonomy rather than new reporting regimes. Implementers should nevertheless compare the final table structures, data point definitions and validation rules with the preceding versions before concluding that no data extraction or mapping change is required. The EBA’s release notes count updated modules as new module versions; release 4.2 alone created 51. A resolution or TCB pipeline that stays pinned to the 4.2 or 4.3 module versions after the 4.4 versions apply would be checking data against superseded definitions, although the detailed impact on data definitions must be determined from the final DPM and taxonomy differences.

AMLA eligibility and the 2027 risk-assessment collection

The EBA’s 4.4 page explains that, under the EBA-AMLA Service Level Agreement of January 2026, the EBA supports AMLA in running the methodology to identify the obliged entities that AMLA will supervise directly from 2028, and provides the DPM, taxonomy and statistical support. The new eligibility reporting applies to obliged entities identified as “provisionally eligible” as of 31 December 2025 and serves to verify whether they remain eligible as of 31 December 2026, the reference date on which selection will be based.

The population is narrow. Article 12(1) of Regulation (EU) 2024/1620 frames AMLA’s periodic assessment around credit and financial institutions operating in at least six Member States, including the home Member State, and AMLA has said the 2027 selection covers up to 40 entities for direct supervision starting in 2028. An institution that has not been identified as provisionally eligible has no eligibility return to build.

The risk-assessment strand revises the release 4.3 templates in light of the 2026 data collection, to support 2027 submissions. AMLA’s 20 July 2026 notice set out two changes: the templates will better capture cases where information is not available, distinguishing them from a reported value of zero, and they add two new data points. The first change has a direct build consequence. A feed that converts empty source fields to zero will now report something different from “not available”, so the default handling of nulls needs a decision. Our coverage of AMLA’s risk-assessment data collection for the 2027 selection sets out the wider exercise.

Validation rules: final at publication, then subject to the quarterly cycle

From release 4.0 the EBA embeds validation rules directly in the DPM and the taxonomy, written in the DPM-XL language. The EBA’s reporting frameworks page explains that the rules linked to a framework release can change through an updated validation rules package, published around two months before the first reference date of a release, or through the small validation rules packages published every quarter, and that the published Excel file includes the latest version of the rules for all framework releases.

The latest quarterly round, on 14 September 2026, deactivated some rules and reactivated others, and shipped a micro taxonomy package with DPM update scripts. The EBA reminded competent authorities that data should not be formally validated against deactivated rules. Treat the 4.4 phase 1 rule set as a baseline the quarterly process will amend. Our guide to EBA supervisory reporting validation rules explains how those updates reach reporting tools.

The EBA also says it may issue a targeted hotfix in January 2027 to deal with critical implementation issues identified through early user feedback, without waiting for the next regular release. A hotfix is conditional, so a build plan cannot count on one arriving. The EBA made a similar offer with release 4.3, for the end of September 2026.

Rebasing a build from the July draft to the October final

For teams that built against the 24 July draft, the October release touches these inputs:

1. Replace the DPM database and the full taxonomy, and re-run any mapping that references table or module versions.
2. Reload the annotated table layouts and compare the cell signs in F 02.01, F 02.01dp and F 20.03.1 with the final DPM database.
3. Apply the phase 1 conversion file. The EBA says it reflects targeted glossary updates, mainly for ESG disclosures, plus a limited number of adjustments related to CODIS.
4. Read the September 2026 known-issues file before logging a defect against the package.
5. Read the updated FAQ, which the EBA says adds guidance on third-country branch reporting, AMLA reporting, IFRS 18 reporting and the use of the conversion file.
6. Confirm that the AML-eligibility rules flagged as missing in July now appear in the validation rules file, before relying on them.
7. Record the IFRS 18 decision and how it was notified to the competent authority, since the interim codes only apply where that option is used.

Steps 2 and 6 come straight from caveats the EBA attached to the draft; the rest follow from the contents list of the final release.

What release 4.4 phase 1 leaves for 4.4.1

Phase 2 (4.4.1) will implement the rest of the supervisory reporting simplification the EBA consulted on from 10 April 2026. The main consultation closed on 10 July 2026 and the IFRS 18 strand on 10 May 2026, and the EBA’s April announcement said the proposed changes would apply from September 2027. The October press release describes the simplification package as being finalised, with its technical implementation expected in early 2027.

The 4.4 page lists what that phase covers, with expected dates:

• Amendments to the ITS on supervisory reporting for CRR3/CRD6 step 2 and simplification: COREP own funds (operational losses, transitional arrangements, module split, boundary and market risk, stress-test integration), COREP large exposures to shadow banking, credit risk and IFRS 9 benchmarking, FRTB reporting (ASA details, AIMA), FINREP, ALMM and asset encumbrance, LCR and leverage ratio, new ESG reporting and SNCI alignment with Pillar 3: September 2027.
• New IMMV reporting on initial margin models: September 2027.
• Supervisory benchmarking for market risk, with new columns 0041 and 0051 in C 106.00 for ASA-only institutions: end of June 2027.
• Technical amendments to DORA reporting: December 2027.

The DORA line has moved. An earlier version of the EBA’s reporting frameworks overview listed DORA among the phase 1 topics; the current 4.4 page places DORA reporting amendments in phase 2 with a December 2027 date.

Frequently Asked Questions

Our competent authority has not said whether it allows the IFRS 18 templates. What applies at the 31 March 2027 reference date?

The Opinion is addressed to competent authorities and advises them to allow the option; it does not amend CIR 2024/3117. Without that permission, the existing FINREP templates of CIR 2024/3117 continue to govern profit or loss reporting; the Opinion refers to their technical tables as still in force under release 4.2. The authority’s own communication settles which route applies.

We report FINREP on a national GAAP basis. Does the IFRS 18 module affect us?

The EBA’s final report on the IFRS 18 FINREP templates (EBA/Rep/2026/18) states that the IFRS 18 changes do not apply to N-GAAP institutions. The wider FINREP simplification in phase 2 is a separate exercise.

We are a non-listed SNCI. Does the ESG strand create anything to disclose at 31 December 2026?

Under the final draft ITS, SNCIs use the Part 3 ESG templates from the 31 December 2027 reference date. The EBA’s discussion paper EBA/DP/2026/02 notes that non-listed SNCIs are currently limited to template EU KM1 under Article 447 CRR, and that a complete EBA publication of all Pillar 3 requirements applicable to SNCIs is envisaged in 2028, with reference date December 2027.

The package includes FINREP datapoint templates for less significant institutions. Do those go to the EBA?

No. The press release says the package covers the ECB’s data collection on FINREP datapoints for less significant institutions and that this data will not be collected by the EBA. The submission route follows the ECB collection.

We prepared AMLA risk-assessment files using the release 4.3 components. Can we submit them?

AMLA stated in July 2026 that the 4.3 components were intended only to help reporting agents prepare and must not be used for submissions to national competent authorities, the EBA or AMLA. The 4.4 revision is the version AMLA tied to 2027 submissions.

Does the xBRL-CSV rule for EBA reception also bind our filing to the national supervisor?

The EBA’s November 2025 reporting-innovations FAQ states that EUCLID accepts only xBRL-CSV for submissions with reference dates from 31 March 2026; the FAQ should be checked for any collection-specific exceptions. The Pillar 3 Data Hub separately requires xBRL-CSV. These EBA reception-format rules must not be read as a universal institution-to-national-supervisor submission requirement: Article 23 of CIR (EU) 2024/3117 provides that institutions submit data in the exchange formats and representations specified by their competent authorities. The format of the final 4.4 sample instances should be checked against the published taxonomy package.

Related Articles

• EBA Reporting Framework 4.3: TCB and AMLA Reporting From 2027: the release that introduced third-country branch reporting and the first AMLA risk-assessment modules.
• SRB Resolution Reporting: RESOL 1 and RESOL 2 Under the New ITS: the RESOL 1 and RESOL 2 resolution reporting sets and how the SRB collects them.
• EBA Pillar 3 Data Hub for Smaller Banks: What the SNCI Discussion Paper Proposes: how the EBA plans to calculate and publish SNCI disclosures centrally.
• EBA DPM Known Issues List: how the EBA’s known-issues file works and why it is the first stop before raising a taxonomy defect.
• EBA Supervisory Reporting Simplification: the April 2026 consultation that phase 2 of release 4.4 will implement.

Key Takeaways

• Swap every July draft artefact (DPM database, taxonomy, table layouts, conversion file) for the 12 October versions before testing any 31 December 2026 return.
• The IFRS 18 route needs a decision and a notification channel with the competent authority before the end of 2026, the date by which paragraph 21 of the Opinion says authorities should have informed the EBA of the option chosen.
• Any mapping keyed on F 02.01, F 16.04.2 or the other interim codes needs an end date: the original labels return when the amended FINREP ITS apply, expected from end-September 2027.
• Track Official Journal publication of the amending Pillar 3 ITS: the draft provides for application from 1 December 2026, and the 4.4 DPM reflects the June 2026 final draft.
• AMLA risk-assessment feeds need explicit handling of “not available” versus zero before 2027 submissions.
• Schedule a validation-rule refresh after each quarterly EBA package and after any January 2027 hotfix.
• COREP, liquidity, ESG reporting, IMMV and DORA changes belong to the 4.4.1 package expected in early 2027.

Sources and References

• EBA press release, 12 October 2026, “The EBA releases the final technical package for release 4.4 of its reporting and Pillar 3 disclosure framework”: eba.europa.eu
• EBA, Reporting framework 4.4 (scope table, phases, technical package files): eba.europa.eu
• EBA, Reporting frameworks overview (release table and validation rules cadence): eba.europa.eu
• EBA press release, 24 July 2026, “The EBA seeks feedback on the 4.4 draft technical package of its reporting and disclosure framework”: eba.europa.eu
• EBA, DPM/XBRL taxonomy revision notes for release 4.4 phase 1 (draft notes dated 15 July 2026), inside the full taxonomy archive: EBA full taxonomy 4.4 (ZIP)
• EBA Opinion EBA/Op/2026/07 of 8 July 2026 on profit or loss reporting between the application of IFRS 18 and the amended CIR 2024/3117: Opinion (PDF) and press release
• EBA Final Report EBA/Rep/2026/18, draft ITS on the implementation of IFRS 18 in FINREP under Article 430(7) CRR: Final Report (PDF)
• Commission Regulation (EU) 2026/338 of 13 February 2026 amending Regulation (EU) 2023/1803 as regards IFRS 18: EUR-Lex
• Commission Implementing Regulation (EU) 2024/3117 of 29 November 2024 (ITS on supervisory reporting): EUR-Lex
• EBA Final Report EBA/ITS/2026/02 of 22 June 2026, draft ITS amending CIR (EU) 2024/3172 on disclosures of ESG risks, equity exposures and aggregate exposure to shadow banking entities: Final Report (PDF) and ITS page
• Commission Implementing Regulation (EU) 2024/3172 (ITS on institutions’ public disclosures): EUR-Lex
• Regulation (EU) No 575/2013 (CRR), Articles 13, 430, 433a, 433b, 433c, 434a, 438, 447, 449a and 449b: EUR-Lex
• Directive 2013/36/EU (CRD), Article 48l(1), as amended by Directive (EU) 2024/1619: EUR-Lex
• EBA Discussion Paper EBA/DP/2026/02 of 8 June 2026 on the Pillar 3 Data Hub process for SNCIs: Discussion Paper (PDF)
• EBA press release, 9 July 2026, final technical package for reporting framework 4.3 (TCB and AMLA): eba.europa.eu
• EBA press release, 5 March 2026, final report on the ITS on supervisory reporting of third-country branches: eba.europa.eu
• Commission Implementing Regulation (EU) 2026/1757 (ITS on supervisory reporting of third-country branches), applicable from 28 March 2027: EUR-Lex and EBA ITS page
• AMLA, 20 July 2026, updated taxonomy for the 2027 risk assessment data collection: amla.europa.eu
• AMLA, 16 March 2026, data collection exercise to test risk assessment models: amla.europa.eu
• Regulation (EU) 2024/1620 establishing AMLA, Article 12: EUR-Lex
• EBA press release, 14 September 2026, quarterly update of validation rules: eba.europa.eu
• EBA FAQ for Reporting Innovations (release 4.0 and beyond), 25 November 2025: FAQ (PDF)
• EBA press release, 10 April 2026, consultation on the major simplification of supervisory reporting: eba.europa.eu
• EBA press release, June 2024, plan for the implementation of DPM 2.0: eba.europa.eu

First reporting reference date under release 4.4: 31 December 2026

The earliest phase 1 modules of the EBA reporting framework 4.4 have an expected 31 December 2026 reporting reference date. They cover resolution-planning reporting by in-scope institutions, MREL-decision reporting by resolution authorities to the EBA, AMLA eligibility data from obliged entities identified as provisionally eligible, the revised AMLA risk-assessment templates supporting 2027 submissions, and amended Pillar 3 disclosures for in-scope institutions other than SNCIs, subject to adoption of the relevant amending ITS. The artefact to produce now is a version map recording which modules move to 4.4 at that date, which stay on 4.2 or 4.3, and whether the FINREP profit or loss templates switch to the IFRS 18 codes at the 31 March 2027 reference 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.