ECB IFRS 18 Reporting Option: The 2027 FINREP Profit and Loss Choice

On 15 October 2026 the ECB confirmed that banks will be able to report the profit and loss templates in their 2027 FINREP submissions under either IAS 1 or IFRS 18 until the EBA’s amended implementing technical standards (ITS) start to apply, which the ECB expects from the September 2027 reference period. Within the Single Supervisory Mechanism, the ECB confirms that significant institutions reporting under the EBA FINREP ITS or the ECB FINREP Regulation may use the voluntary interim ECB IFRS 18 reporting option. Less significant institutions may use it only where their national competent authority (NCA) permits the choice. Institutions outside the SSM should follow their own competent authority’s approach to the EBA Opinion rather than rely on the ECB announcement as their supervisory instruction.

The timing gap is real. IFRS 18 applies to accounting periods beginning on or after 1 January 2027, while mandatory use of the IFRS 18-aligned FINREP templates will begin on the application date specified in the amended ITS, following their adoption by the Commission. Both formats are acceptable in between, and each one fixes a template set, a data point model and a mapping workload for the quarterly reference dates that fall inside the gap.

The EBA set out the option in an Opinion of 8 July 2026 addressed to competent authorities. The ECB’s announcement adds three things that matter to a reporting team: the Single Supervisory Mechanism’s position on who may use the option, a template mapping for the ECB FINREP Regulation, and a statement that NCAs will collect each institution’s choice.

Related reading: IFRS 18 FINREP Reporting: The Interim Templates Banks Can File Early

The interim calendar, from the EBA Opinion to the September 2027 handover

The dates below come from the ECB release, the EBA Opinion (EBA/Op/2026/07), the EBA’s technical package announcements and Commission Regulation (EU) 2026/338, which endorsed IFRS 18 in the EU. The status column matters as much as the date, because several entries are expectations that no legal act has fixed yet.

The phrase “from January 2027” in the ECB release, and “for the reporting period from January 2027” in paragraph 16 of the Opinion, describes the period whose profit or loss is being reported. It does not create a January filing. Article 2(2) of Implementing Regulation (EU) 2024/3117 establishes the cumulative reporting basis, while Article 2(1)(b) sets the standard quarterly reference dates. For calendar-quarter FINREP filers, 31 March 2027 is the first expected reference date for the interim IFRS 18 templates. Institutions permitted to use non-calendar accounting-year reporting dates must also consider the adjustments allowed by Article 2(3). On the standard calendar timetable, the 31 December 2026 FINREP remitted by 11 February 2027 still covers a 2026 accounting year presented under IAS 1, and the option does not reach it.

Where a remittance date falls on a weekend or a public holiday in the competent authority’s Member State, Article 3(2) of the same Regulation moves it to the next working day.

Three populations, three routes into the ECB IFRS 18 reporting option

The ECB release treats three groups of banks differently. The distinctions that change the answer are the bank’s significance status and the instrument it reports under.

The first row maps to the population the EBA Opinion defines in paragraph 16: institutions subject to the FINREP reporting requirements in Article 430(3), (4) and (9) of Regulation (EU) No 575/2013 (CRR). Our FINREP reporting guide covers who falls inside that perimeter and on what basis.

Two limits of the option follow from the Opinion itself.

• It creates no obligation. Paragraph 12 of the Opinion describes the revised templates as providing “the option, but not the obligation” to report the relevant FINREP templates under IAS 1 or IFRS 18. A bank that keeps the existing templates for the interim reference dates is within the option.
• It swaps the profit or loss templates only. Paragraph 14 keeps “all other reporting requirements” of Implementing Regulation (EU) 2024/3117 unchanged, so the balance sheet templates, COREP and the remaining FINREP templates carry on as before.

For less significant institutions, a footnote in the release adds that the interim option applies to them “subject to indications from their NCA”. The ECB has left the decision for that population with each national authority, and the release does not list which NCAs have already decided.

The ECB FINREP Regulation side: Annex A, Annex B and an annex-number trap

The ECB FINREP Regulation is Regulation (EU) 2015/534 of the ECB (ECB/2015/13). It exists because the EBA’s ITS govern FINREP on a consolidated basis, while recital 6 of the 2015 Regulation explains that individual-basis reporting falls outside the ITS. The ECB Regulation therefore sets the common minimum set of supervisory financial information that significant and less significant supervised entities report to their NCAs, including on an individual basis. A significant banking group can file EBA FINREP at the consolidated level and ECB FINREP for its individual entities, which means two perimeters and potentially two choices under the option.

The Regulation works through annexes whose titles, as cited in the ECB’s amending Regulations (EU) 2020/605 and 2025/1958, are:

• Annex I, “Simplified supervisory financial reporting”;
• Annex II, “Over-simplified supervisory financial reporting”;
• Annex IV, “‘FINREP data points’ under IFRS or National GAAP compatible with IFRS”;
• Annex V, “‘FINREP data points’ under national accounting frameworks”.

Which annex a given entity files depends on its significance status, its position in a group, its accounting framework and its size, as set out in the Regulation’s articles. The ECB’s 15 October release leaves that allocation in place and says the Regulation “will be amended to reflect changes introduced by the new standard” and that, in the meantime, institutions subject to it “may refer to” the EBA Opinion together with Annex A or Annex B of the release.

Annex A: four templates in the simplified and over-simplified sets

Annex A of the release lists the ECB FINREP templates that have an IFRS 18 equivalent in the EBA’s version 4.4 (Phase 1) package. The ECB writes the codes without spaces; they are reproduced here as published.

The release states that the rest of the templates in Annex I and Annex II are unaffected. An entity on the over-simplified set therefore touches one template, the statement of profit or loss, while an entity on the simplified set touches four. Full EBA FINREP filers face a longer list: paragraph 17 of the Opinion gives twelve interim labels, running from F 02.01 to F 20.03.1.

Two rows break a naive mapping rule. A script that appends “.1” to every affected code gets F02 and F16.04 wrong, because the ECB maps them to F02.01 and F16.04.2. In the EBA’s own interim list, the separate existing template F 16.04.1 takes the label F 16.04.1.1 (paragraph 17 of the Opinion lists the labels in the same order as the templates in paragraph 8). Mapping tables built from the ECB’s Annex A row by row avoid that collision.

Annex B: the data-point worksheets

Annex B covers the two data-point annexes. The data points in template F02 of Annex IV and Annex V of the ECB FINREP Regulation are replaced by the data points in the worksheets “2.1 (Annex IV) DP 2027” and “2.1 (Annex V) DP 2027” of the templates file published with the release. The rest of the data points in those annexes are unaffected.

The templates file holds three worksheets: the two data-point sheets and a colour code. The legend distinguishes changed references, changed data points, deleted data points, data points to be submitted, new data points to be submitted, and cells not to be submitted by institutions under the relevant accounting framework. Both data-point sheets carry the new IFRS 18 structure, including row 0582 “OPERATING PROFIT or LOSS”, the investing-category rows 0591 to 0604, row 0605 “OPERATING and INVESTING PROFIT or LOSS” and row 0606 for income or expenses on non-operating liabilities. The Annex V sheet has two reference columns, one for national GAAP based on the Bank Accounts Directive and one for national GAAP compatible with IFRS.

Regulation (EU) 2025/1958 (ECB/2025/31), applicable from 30 December 2025, amended both data-point annexes. Its recitals explain that, under the proportionality principle, only a reduced set of data points is collected from certain less significant credit institutions with total assets of EUR 3 billion or less. The EBA’s 12 October announcement adds that the 4.4 package “also covers the ECB data collection on FINREP datapoints” for less significant institutions, and that this data will not be collected by the EBA. Neither the ECB release nor the EBA announcement states which entities report against Annex B; the ECB says only that Annex A or Annex B applies “as applicable”, and for a less significant institution the NCA’s permission decides whether the option is usable at all.

The annex-number trap

The EBA Opinion’s own attachments are labelled “FINREP templates IFRS 18 – Annex III”, “FINREP templates IFRS 18 – Annex IV” and “FINREP instructions IFRS 18 – Annex V”. The ECB’s Annex B refers to Annex IV and Annex V of the ECB FINREP Regulation, which are data-point lists. The numerals are identical and the documents are unrelated. A change ticket that says “update the Annex IV mapping” needs the instrument named, or a developer working from the EBA files will open a template workbook when the requirement was a data-point list.

What each format commits the reporting chain to

The Opinion keeps the mechanics of both routes close together. The difference sits in the template codes, the data point model and what happens when the amended ITS arrive.

The IFRS 18 route changes more than labels. The EBA’s Final Report (EBA/Rep/2026/18) reshapes the statement of profit or loss, F 02.00, around a retail and investment bank benchmark and splits income and expenses into operating, investing and financing categories. It keeps the existing subtotal “total operating income, net”, adds the IFRS 18 subtotal “operating profit or loss”, and adds a FINREP-only subtotal “operating and investing profit or loss” that IFRS 18 does not require. Templates F 16 and F 45 keep their current breakdowns with added columns for the three new categories. Consultation respondents warned that business models different from the benchmark may make greater use of residual rows in F 02.00, and the EBA responded by reviewing the operating and investing rows and adding worked examples to the Final Report. Our breakdown of the EBA reporting framework 4.4 final package covers the DPM and taxonomy files that carry these templates.

The IAS 1 route has its own cost. The EBA framed the Opinion as a way to avoid “maintaining two different profit or loss formats”. A group whose 2027 consolidated accounts follow IFRS 18 and whose FINREP stays on IAS 1 templates for two quarters is, in effect, keeping that second format alive for the interim reference dates. Which cost is lower depends on the state of the general ledger mapping, and neither the EBA nor the ECB expresses a preference.

The label reversion affects any mapping keyed on template codes. On the IFRS 18 route, a mapping keyed on template codes changes at the first expected IFRS 18 reference date of 31 March 2027, when F 02.00 content moves to F 02.01, and changes again when the amended ITS apply and paragraph 17 of the Opinion reinstates the original labels. That second change is written into the Opinion. The content of the final templates is a separate question: the EBA describes the interim templates as the draft final version it will submit for adoption, and the Commission’s adopted text is still to come. Validation formulae for the module arrive through the same package, so the EBA’s periodic validation rule updates apply to the IFRS 18 templates as well.

Recording the choice: NCAs, the end-2026 checkpoint and two open questions

The ECB release names the collection channel and stops there: “Information regarding the chosen option will be collected from institutions by their NCAs.” It does not distinguish significant from less significant institutions on that point, and it sets no institution-level date or format.

The EBA Opinion supplies the outer limit. Paragraph 21 says competent authorities should receive notification from the institutions in their jurisdictions and then inform the EBA of the option chosen by the end of 2026. That date governs the authorities’ reporting to the EBA, and the Opinion does not frame it as an institution deadline. A reasonable planning assumption is that NCA requests will arrive before year-end because the authorities need the answers to meet it, but the date and form of each request are for the NCA to set.

Paragraph 14 of the Opinion adds that competent authorities may engage with institutions on the use of the templates as part of their supervisory dialogue, so the notification may not be the last word.

Two questions remain unanswered by both texts. The first is whether a significant group must make the same choice for its consolidated EBA FINREP and for the individual ECB FINREP submissions of its subsidiaries. The release treats the two populations in separate sentences and says nothing about consistency between them. The second is whether a bank that chooses IAS 1 for 31 March 2027 may move to IFRS 18 for 30 June 2027. The Opinion’s design, a single notification of “the option chosen” by the end of 2026, reads as a one-time declaration, but neither document addresses a mid-window switch.

When the interim option ends: amended ITS and release 4.4.1

The end of the window is tied to an event. Paragraph 16 of the Opinion runs the option “until the first application date” of the ITS amending Implementing Regulation (EU) 2024/3117, and paragraph 13 says the IFRS 18 module in Phase 1 of version 4.4 ceases to apply at that point. The September 2027 figure is the EBA’s and the ECB’s expectation of when that event happens. The EBA’s 8 July press release says mandatory application is “currently expected from the end of September 2027”, and the ECB release says the amended ITS are “expected to apply only from the September 2027 reference period”.

Two pieces have to land first. The EBA expects to submit the final draft amended FINREP ITS to the Commission by the end of 2026, and the Commission then has to adopt them. On the technical side, the EBA’s 12 October announcement says the second phase of release 4.4 (4.4.1), expected in early 2027, will cover the remaining elements of its consultation on the major simplification of supervisory reporting, published on 10 April 2026. The EBA’s framework 4.4 page shows those CRR3/CRD6 step 2 and simplification amendments with an expected first reference date of 09/2027, in Phase 2. Our note on the EBA supervisory reporting simplification consultation sets out what that package proposes for FINREP beyond IFRS 18.

The practical consequence for the interim choice is asymmetric. An IFRS 18 build for 31 March 2027 is work on templates the EBA intends to make mandatory, subject to whatever the Commission changes on adoption. An IAS 1 choice defers the IFRS 18 reporting-template migration until the amended ITS apply. The currently expected September 2027 application date may coincide with the planned Phase 2 supervisory reporting simplification changes, but their final requirements and application dates remain subject to the relevant adoption process.

Frequently Asked Questions

Our financial year ends on 31 March. How does the option work for us?

IFRS 18 applies to accounting periods beginning on or after 1 January 2027, so a 31 March year-end bank first applies it to the year starting 1 April 2027. A respondent raised exactly this case in the consultation, and the EBA’s Final Report answers that the instructions (Annex V, Part 1.49) let institutions with a non-calendar financial year keep reporting the same data points as today under the new template formats, in the rows and columns of the operating category, with the operating, investing and financing distinction not applicable to them. Article 2(3) of Implementing Regulation (EU) 2024/3117 separately allows reference dates adjusted to a non-calendar year-end where national law permits.

Our individual accounts follow national GAAP based on the Bank Accounts Directive. Does Annex B change anything for us?

The EBA’s Final Report says the IFRS 18 changes have no major impact for national GAAP reporters, which continue to present income and expenses under the Bank Accounts Directive (paragraph 24), and its feedback table states that institutions on national GAAP based on the Bank Accounts Directive use only the operating-category rows, with no distinction between operating and investing categories. In the ECB’s “2.1 (Annex V) DP 2027” worksheet, the new IFRS 18 rows such as 0582 and 0591 to 0604 carry references only in the column for national GAAP compatible with IFRS, while rows that carry only Bank Accounts Directive references, such as 0415 for goodwill and 0632 to 0634 for extraordinary items, remain. The file’s colour code marks the cells that are not submitted under each accounting framework, and the NCA is the authority to confirm the cell scope for a specific bank.

We are a less significant institution and our NCA has not said anything yet. Can we assume permission?

The release gives no default for silence. The EBA Opinion is addressed to competent authorities and does not itself grant banks anything. Until the NCA gives an indication, the existing templates remain the requirement for a less significant institution.

What happens if the Commission adopts the amended ITS later than expected?

Read literally, a later application date extends the interim window to further quarterly reference dates, and the IFRS 18 module stays in use until the amended ITS apply. Neither the EBA nor the ECB has published a scenario for that case, so the September 2027 expectation works as a planning assumption for build and test calendars.

Will the interim F 45 labels ever be used?

F 45.02 and F 45.03 are in the interim set as F 45.02.1 and F 45.03.1. Under Article 11(c) of Implementing Regulation (EU) 2024/3117, templates F 40.01 to F 46.00 are reported annually, with a 31 December reference date for calendar-year filers. If the amended ITS apply from the September 2027 reference period, the first annual date after 1 January 2027 falls after that handover, so on the current timetable a calendar-year filer would not submit the interim F 45 labels. A slip in adoption, or adjusted reference dates for a non-calendar year-end, changes that answer.

Could the IFRS 18 module change before the first submission?

The EBA said on 12 October 2026 that it may issue a targeted hotfix release in January 2027, if necessary, to address critical implementation issues found through early user feedback. It also updated its reporting FAQs that day with guidance that includes IFRS 18 reporting. A build frozen in December 2026 needs a check against any January release before the first IFRS 18 run.

Related Articles

• IFRS 18 FINREP Reporting: The Interim Templates Banks Can File Early: the EBA’s July 2026 Opinion, the twelve interim templates and the F 02.00 restructure in detail.
• EBA Reporting Framework 4.4 Final Package: The Phase 1 Build List: the DPM, XBRL taxonomy and validation rules released on 12 October 2026, including the IFRS 18 module.
• FINREP Reporting Explained: EBA Templates, IFRS 9, Deadlines: the FINREP template families, reporting perimeter and remittance calendar.
• ECB Supervisory Reporting: The Cuts Buch Confirmed at Bruegel: the ECB’s September 2026 plan to reduce its supervisory reporting requests.
• EBA Updates Supervisory Reporting Validation Rules: What XBRL and DPM Reporting Teams Must Check: how EBA validation rule updates affect XBRL and DPM builds.
• EBA Supervisory Reporting Simplification: the April 2026 consultation that feeds the second phase of release 4.4.

Key Takeaways

• List every reporting perimeter that files profit or loss templates, the consolidated EBA FINREP and each individual ECB FINREP filer, before deciding; the ECB treats the two populations separately.
• A less significant institution needs its NCA’s indication before building the IFRS 18 route; the ECB makes its access to the option conditional on it.
• Test the ECB FINREP mapping table against Annex A before the first run; F02 to F02.01 and F16.04 to F16.04.2 are the rows a suffix rule gets wrong.
• Name the instrument on every “Annex IV” or “Annex V” ticket: the EBA Opinion’s annexes are template and instruction files, the ECB FINREP Regulation’s are data-point lists.
• Budget two code changes on the IFRS 18 route: interim labels from the first expected reference date (31 March 2027 for standard calendar-quarter filers), original labels back when the amended ITS apply.
• Put both open questions to the NCA in the notification itself: whether consolidated and individual choices must match, and whether the choice can change between the 31 March and 30 June 2027 reference dates.
• For profit or loss reporting, implement the IFRS 18-aligned module, its DPM mappings, taxonomy and validation rules where the interim option has been selected and is permitted. Retain the applicable IAS 1 profit or loss mapping where that format is chosen. Assess the other reporting changes in framework 4.4 independently: the IAS 1 choice does not exempt an institution from unrelated technical or reporting changes.

Sources and References

• ECB Banking Supervision, press release “Regulatory reporting on profit and loss: institutions will have option to report under IAS 1 or IFRS 18” (15 October 2026), with Annex A and Annex B: https://www.bankingsupervision.europa.eu/press/pr/date/2026/html/ssm.pr261015~9c7bd1ee8e.en.html
• ECB Banking Supervision, templates file published with the 15 October 2026 release (worksheets “2.1 (Annex IV) DP 2027” and “2.1 (Annex V) DP 2027”): https://www.bankingsupervision.europa.eu/press/pr/date/2026/html/ssm.pr261015_annex~d9b74eb178.en.xlsx
• EBA, Opinion EBA/Op/2026/07 on profit or loss reporting between the application of IFRS 18 and the amended Implementing Regulation (EU) 2024/3117 (8 July 2026): https://www.eba.europa.eu/sites/default/files/2026-07/5ebd21e8-52f4-4b99-acbc-f7d725c3694e/Opinion%20Finrep%20IFRS%2018%20-%20interim%20period.pdf
• EBA, press release on the IFRS 18 Opinion, with the list of annexes (8 July 2026): https://www.eba.europa.eu/publications-and-media/press-releases/eba-issues-opinion-implementation-ifrs-18-supervisory-financial-reporting-support-consistency-ifrs
• EBA, Final Report EBA/Rep/2026/18 on draft ITS on the implementation of IFRS 18 in FINREP (8 July 2026): https://www.eba.europa.eu/sites/default/files/2026-07/ad6fd07d-c637-42d3-a4a7-4a4802a8ff26/Annex%201%20(Final%20Report%20-%20Finrep%20IFRS%2018).pdf
• EBA, press release on the final technical package for release 4.4 (12 October 2026): https://www.eba.europa.eu/publications-and-media/press-releases/eba-releases-final-technical-package-release-44-its-reporting-and-pillar-3-disclosure-framework
• EBA, press release on the draft technical package for release 4.4, with the 31/03/2027 first reference date for the IFRS 18-aligned templates (24 July 2026): https://www.eba.europa.eu/publications-and-media/press-releases/eba-seeks-feedback-44-draft-technical-package-its-reporting-and-disclosure-framework
• EBA, reporting framework 4.4 page: https://www.eba.europa.eu/risk-and-data-analysis/reporting/reporting-frameworks/reporting-framework-4.4
• Commission Implementing Regulation (EU) 2024/3117 of 29 November 2024 laying down ITS on supervisory reporting of institutions (Articles 2, 3, 11, 12 and 23): https://eur-lex.europa.eu/eli/reg_impl/2024/3117/oj/eng
• Commission Regulation (EU) 2026/338 of 13 February 2026 amending Regulation (EU) 2023/1803 as regards IFRS 18: http://data.europa.eu/eli/reg/2026/338/oj
• Regulation (EU) No 575/2013 (CRR), Article 430: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0575
• Regulation (EU) No 1093/2010 (EBA Regulation), Article 29(1)(a), legal basis of the Opinion: https://eur-lex.europa.eu/eli/reg/2010/1093/oj
• Regulation (EU) 2015/534 of the ECB on reporting of supervisory financial information (ECB/2015/13): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015R0534
• Regulation (EU) 2020/605 of the ECB amending Regulation (EU) 2015/534 (ECB/2020/22), Article 1 (annex titles): https://eur-lex.europa.eu/eli/reg/2020/605/oj
• Regulation (EU) 2025/1958 of the ECB amending Regulation (EU) 2015/534 (ECB/2025/31): https://eur-lex.europa.eu/eli/reg/2025/1958/oj

Settling the profit and loss format before 31 March 2027

The ECB IFRS 18 reporting option leaves each bank with one format decision per reporting perimeter. For standard calendar-quarter EBA FINREP reporting, the first expected IFRS 18-format reference date is 31 March 2027, with a remittance date of 12 May 2027. ECB FINREP filers must separately check for earlier NCA deadlines, while institutions permitted to report against a non-calendar financial year must confirm their adjusted reference and remittance dates. The artefact to produce before the NCA asks is a decision record for each perimeter: the format chosen, the templates affected from the EBA’s twelve interim labels or the ECB’s Annex A and Annex B, the DPM version, and for a less significant institution the NCA indication that permits the choice.

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.