EBA 4.3 Technical Package: DPM Changes for COREP and FINREP

ByOfficer

Last updated: May 2026

The EBA 4.3 technical package does not touch a single COREP or FINREP template. That sentence alone will cause some teams to stop reading. It should have the opposite effect. Framework 4.3 is the first module-level expansion of DPM 2.0 since the 4.2 rollout completed the full transition in late 2025. The DPM database, the XBRL taxonomy, the validation rules format, and the glossary that 4.3 extends are the same infrastructure that framework 4.4 will use when it rewrites COREP own funds, FINREP under IFRS 18, FRTB, liquidity, ESG, and benchmarking templates later this year. If your platform cannot absorb 4.3 cleanly, it will not absorb 4.4 either.

I have watched two previous new-module rollouts where COREP teams treated the initial release as irrelevant because “it’s not our templates.” Both times, when the follow-on release landed with changes to their templates, the teams discovered taxonomy handling problems that had been sitting in the system since the earlier release. The 4.3 window is a free rehearsal. Use it.

Related reading: EBA 4.3 Draft Package: What Reporting Teams Should Map

What the EBA 4.3 Technical Package Contains

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

The package includes three categories of deliverables, all uploaded to the EBA’s reporting framework 4.3 page:

  • Validation rules release (draft, in a new format)
  • DPM 4.3 draft: DPM database 2.0, DPM dictionary (glossary full export), table layout and data point categorization, and identical cells mapping
  • XBRL 4.3 draft: full taxonomy, taxonomy package 4.3, and sample files 4.3

The scope is narrow by design. The EBA’s 16 April 2026 press release describes the draft as “covering anti-money laundering (AML) and third country branches (TCB) reporting.” The EBA’s reporting frameworks overview page confirms framework 4.3 is scoped to these two new modules. Amendments to existing COREP, FINREP, resolution, benchmarking, liquidity, ESG, and DORA reporting are placed under framework 4.4.

What is not in the draft yet

The EBA’s own disclaimer on the 4.3 page states that the final package will include two additional AMLA tables (AML.01.01 and AML.01.02) and further validation rules for AML reporting. Those tables are not in the April draft. Teams mapping the AMLA module should plan for a second pass once the final June package adds them.

What 4.3 Does Not Change: The Misreading That Costs Time

Framework 4.3 does not amend any existing COREP template. It does not amend any existing FINREP template. It does not change liquidity reporting, ESG disclosures, resolution planning templates, or supervisory benchmarking. Those are all framework 4.4, expected Q3 2026 per the EBA’s reporting frameworks overview table.

The mistake I see teams make is binary: either they assume 4.3 changes everything, or they assume it changes nothing relevant. Both readings are wrong.

It changes nothing at the template level for COREP/FINREP. But it changes the DPM database that underpins all templates. It changes the glossary that defines data points across all modules. It introduces a new validation rules format that will apply to COREP/FINREP when 4.4 ships. Those are infrastructure changes, not template changes. Ignoring them because “my templates didn’t change” is like ignoring a database migration because “my tables didn’t change.” The plumbing moved. Test the plumbing.

The DPM 2.0 Database: What the 4.3 Extension Means

The DPM (Data Point Model) is the EBA’s standard data dictionary. It defines every data point in every regulatory report: the dimensions, members, metrics, and relationships that turn a template cell into a reportable value. DPM 2.0 replaced the original model with a semantic structure built around a glossary of defined terms rather than template-specific identifiers.

Framework 4.2, published as a final package in late 2025, completed the full DPM 2.0 rollout. All modules except DORA were migrated to DPM 2.0 in that release. The EBA’s 4.2 press release explicitly noted that DORA would be implemented in version 4.3.

Framework 4.3 extends the DPM 2.0 database by adding data points for two new reporting streams. The DPM database file (in Access format) now includes the TCB and AMLA data point definitions alongside the existing COREP, FINREP, resolution, benchmarking, and other module definitions. This is a single integrated database, not a set of separate module files.

Why this matters to COREP/FINREP teams specifically

Because the DPM 2.0 database is a unified model. When your vendor loads the 4.3 DPM database into your reporting platform, they are loading a database that contains your COREP data points, your FINREP data points, and the new TCB/AMLA data points together. If the load fails, or if it introduces a regression in how your existing data points are handled, that is a COREP/FINREP problem even though the 4.3 changes were all in TCB/AMLA.

I would run a regression test on your existing COREP and FINREP submissions against the 4.3 DPM database. Generate the same report you filed last quarter using the 4.3 taxonomy, and compare the output to the 4.2 output cell by cell. If nothing changed, good. That tells you the database extension was clean. If something changed, you found the problem six months before it would have appeared as a validation failure in production.

The Glossary: Cross-Cutting Changes That Teams Miss

The DPM dictionary published alongside the 4.3 draft is a full glossary export. It covers all terms in the DPM, not just the new TCB and AMLA terms. The EBA also invited feedback on this glossary alongside the draft technical package, with comments accepted until 10 May 2026.

A glossary update that changes the definition of a term used across multiple modules can ripple into COREP and FINREP reporting even when no template layout changes. If a dimension member that appears in both a FINREP template and a new TCB template gets a tightened definition, the FINREP team needs to know about it. The change might not affect the cell structure, but it could affect what data belongs in that cell.

The practical step: download the 4.3 glossary export from the EBA’s reporting framework 4.3 page. Compare it against the 4.2 glossary. Identify any terms that appear in your current COREP or FINREP filings and check whether their definitions shifted. Most will not have changed. But the ones that did are worth documenting before the 4.4 wave arrives.

Validation Rules in a New Format

The 4.3 draft includes validation rules in what the EBA describes as a “new format.” This is a structural change, not a content change for COREP/FINREP. The validation rules in 4.3 apply to the TCB and AMLA modules, not to existing modules. But the format itself is the same format the EBA will use for all modules going forward, including COREP and FINREP under framework 4.4.

Teams that wait until 4.4 to learn the new validation rules format will be learning it under pressure, alongside substantive template changes. Teams that examine the 4.3 validation rules now can understand the format in isolation, with a small and manageable scope (two modules), before confronting it at full COREP/FINREP scale.

What teams commonly get wrong with validation rule format changes

The most frequent failure is assuming the vendor handles the format transition entirely. Vendors do handle the technical parsing. But your internal validation-monitoring process may depend on the old format. If your team uses the validation rules spreadsheet to build internal pre-checks, or if your data quality dashboard maps validation rule IDs to template cells, a format change breaks those mappings. That is your problem, not the vendor’s.

A second failure: not checking whether the new format changes how conditional rules are expressed. Conditional validation rules (rules that fire only when certain cells are populated, or only for certain entity types) are where format differences create real operational risk. The logic may be identical. The way it is expressed in the spreadsheet may not be. Verify that your team can read and apply the conditional rules in the 4.3 format before 4.4 makes them mandatory across all modules.

Identical Cells Mapping: A Quiet but Important Artefact

The identical cells file maps cells across different templates that must contain the same value. When the EBA adds new modules to the DPM, it sometimes creates new cross-template identity relationships. If a TCB template cell must equal a value that also appears in an existing template, the identical cells mapping will show that relationship.

For COREP/FINREP teams, the question is whether the 4.3 identical cells file introduces any new cross-references between existing module cells and the new TCB/AMLA module cells. If it does, those cross-references will need to validate in your submissions even if the only “new” templates are in TCB/AMLA. Download the 4.3 identical cells file from the EBA’s reporting framework 4.3 page and check whether any existing template cells gained new identity relationships.

This is the kind of check that takes fifteen minutes in a spreadsheet but can cause weeks of troubleshooting if discovered as a validation failure at submission time.

TCB Reporting: The DPM Specifics

The ITS on third-country branch supervisory reporting was finalized by the EBA on 5 March 2026, under CRD VI (Directive (EU) 2024/1619). Article 48k establishes the reporting obligation for third-country branches. Article 48l(1) provides the proportionality framework and the legal basis for the ITS. The policy text established two template sets: Annex I for branch-level financial and regulatory data, and Annex II for head-undertaking-level quantitative and qualitative data.

The first reference date is 31 March 2027, per the EBA’s framework 4.3 page. That is ten months from now. But the DPM artefacts are available in draft form today, and they are the concrete starting point for data mapping.

Where the implementation work sits

The DPM tells you every data point in both Annex I and Annex II. It does not tell you which templates your branch must file. The EBA retained a core plus supplement proportionality approach across the TCB package: all TCBs report a core set, while Class 1 TCBs provide additional information. For head-undertaking templates in Annex II, the final report applies proportionality at frequency level, with the same datapoints relevant to both classes. Your implementation team must map the applicable class, template scope, and frequency with the competent authority.

Annex I branch-level data typically sits in local accounting systems, often disconnected from the group’s central regulatory reporting platform. I have seen this gap repeatedly in new-module implementations. The data exists somewhere. It is rarely in the format the DPM requires, and the extraction pipeline rarely exists at the start of the project. If you have third-country branches in the EU, begin the data-sourcing assessment now, not when the final package arrives in June.

AMLA Reporting: A Different Kind of DPM Module

The AMLA component of framework 4.3 is not supervisory reporting in the traditional sense. It is a DPM and taxonomy supporting AMLA’s methodology for identifying obliged entities that will fall under AMLA’s direct supervision from 2028. The EBA provides the technical infrastructure (DPM, XBRL taxonomy) under a service level agreement with AMLA, concluded in January 2026.

The first reference date is 31 December 2026. Entities that participate in AMLA’s testing and calibration exercise have already been notified by their national competent authorities. AMLA published the reporting package, including an Interpretative Note and template, on its own website. The EBA’s DPM and taxonomy should be read alongside AMLA’s materials.

What is missing from the draft

The EBA’s disclaimer on the 4.3 page explicitly states that two tables related to the AMLA framework, AML.01.01 and AML.01.02, are not yet included in the April draft. Additional validation rules for AML reporting are also missing. These will be included in the final June 2026 package. Any implementation mapping against the AMLA module today is incomplete by design. Plan for a second mapping cycle when the final package drops.

What teams get wrong with AMLA scoping

The common error is assuming AMLA reporting affects every institution. It does not. AMLA’s direct supervision will cover up to 40 entities selected through the methodology that this DPM module supports. The testing and calibration exercise involves a sample of entities already notified by their NCAs. If you have not been notified, the AMLA module in framework 4.3 is not your immediate filing obligation. It is, however, part of the DPM database that your platform loads. See the regression-testing point above.

Framework 4.4: What Actually Hits COREP and FINREP Templates

The EBA’s reporting frameworks overview table lists framework 4.4 as expected Q3 2026, with module-specific application in two phases.

Phase 1 covers FINREP changes for IFRS 18, DORA reporting amendments, resolution planning amendments, and Pillar 3 disclosure updates. Within Phase 1, the FINREP IFRS 18 amendments carry a first reference date of March 2027, while the DORA, resolution planning, and Pillar 3 changes carry a first reference date of December 2026.

Phase 2, with a first reference date of September 2027, covers the heavier lift: amendments to COREP supervisory reporting ITS across own funds, large exposures, leverage ratio, asset encumbrance, ALMM, LCR, benchmarking credit risk, IFRS 9, FRTB, ESG reporting, and new reporting on initial margin models.

The 10 April 2026 simplification consultation is a separate but related work stream that feeds framework 4.4’s ITS amendments. Consultation deadlines are 10 July 2026 for the main package and 10 May 2026 for the IFRS 18-related requirements. Proposed simplification changes would apply from September 2027.

This is where the rubber hits the road for COREP and FINREP teams. Framework 4.3 is the rehearsal. Framework 4.4 is the production run.

What COREP and FINREP Teams Should Do Now

Six practical steps, none of which require waiting for the final June package.

1. Run a DPM 2.0 regression test

Load the 4.3 DPM database and XBRL taxonomy into your test environment. Generate your last COREP and FINREP submission using the 4.3 taxonomy. Compare the output to your 4.2 production submission. If nothing changes, document that result. If something changes, investigate before 4.4 arrives.

2. Review the glossary diff

Download the 4.3 glossary full export. Compare it term by term against the 4.2 glossary. Flag any terms that appear in your COREP or FINREP filings. Most will be unchanged. The ones that changed need a brief impact note.

3. Learn the new validation rules format

Open the 4.3 validation rules file and understand its structure. The scope is small (TCB and AMLA rules only), which makes it manageable. Map the format to your internal pre-check process. If your process breaks under the new format, fix it now while the stakes are low.

4. Check identical cells for cross-module references

Scan the 4.3 identical cells file for any relationships between existing template cells and new TCB/AMLA cells. If none exist, move on. If they do, flag them for your next submission cycle.

5. Coordinate with your vendor on 4.3 uptake

Ask your vendor when they plan to absorb the 4.3 taxonomy into their product. If they are deferring until the final June package, confirm that the deferral does not block your regression testing. Most vendors provide test-environment taxonomy uploads separately from production releases.

6. Map the 4.4 timeline against your project capacity

Within framework 4.4, the FINREP IFRS 18 amendments carry a first reference date of March 2027, while DORA, resolution planning, and Pillar 3 changes carry a first reference date of December 2026. Phase 2 targets September 2027. The 4.4 draft package is expected Q3 2026. That gives you roughly three to six months from draft to first filing, depending on the phase. If your team also handles the EBA DPM known issues process, the CRR3 output floor phase-in, and the simplification consultation response, you are stacking three change streams in the same six-month window. Plan capacity now.

Frequently Asked Questions

Does EBA framework 4.3 change COREP templates?

No. Framework 4.3 adds new modules for third-country branch reporting and AMLA reporting. It does not amend any existing COREP template. Changes to COREP own funds, large exposures, leverage ratio, and other modules are in framework 4.4, expected Q3 2026.

Does framework 4.3 change FINREP templates?

No. FINREP amendments, including changes for IFRS 18, are part of framework 4.4 phase 1, with a first reference date of March 2027 for the IFRS 18 changes. Framework 4.3 does not alter any FINREP reporting template.

Why should COREP and FINREP teams care about 4.3 if their templates are unchanged?

Because the DPM 2.0 database is a unified model. The 4.3 extension adds data points to the same database your COREP and FINREP submissions rely on. The validation rules arrive in a new format that 4.4 will use for all modules. The glossary update is cross-cutting. Ignoring 4.3 means losing the chance to test your platform against the new DPM structure before 4.4 introduces substantive template changes.

When is the final 4.3 package expected?

June 2026, per the EBA’s framework 4.3 page and the 16 April 2026 press release. The final package will include the missing AMLA tables (AML.01.01 and AML.01.02) and additional AML validation rules.

What is the first reporting reference date for TCB reporting?

31 March 2027, per the EBA’s framework 4.3 page. This applies to EU branches of non-EU credit institutions under the new ITS on third-country branch supervisory reporting.

What is the first reporting reference date for AMLA reporting?

31 December 2026. This covers the DPM and taxonomy supporting AMLA’s methodology for identifying obliged entities subject to direct AMLA supervision from 2028. Participating entities in the testing and calibration exercise have already been notified by their national competent authorities.

What is the new validation rules format?

The 4.3 draft includes validation rules in what the EBA describes as a new format. The rules themselves apply to TCB and AMLA modules only, but the format is expected to be used across all modules from framework 4.4 onward. Teams should familiarize themselves with the structure now while the scope is small.

Should we respond to the EBA feedback consultation?

The feedback window closed on 10 May 2026. Feedback has been submitted. The final package in June 2026 will reflect any amendments based on stakeholder input.

Related Articles

Key Takeaways

  • EBA framework 4.3 adds third-country branch and AMLA reporting modules to the DPM 2.0 database. It does not amend any existing COREP or FINREP template.
  • The DPM 2.0 database is a unified model. Extending it with new modules affects the same infrastructure your COREP and FINREP submissions rely on. Test the extension for regressions.
  • Validation rules ship in a new format in 4.3. This format will apply to all modules under framework 4.4. Learn it now while the scope is small.
  • The glossary update is cross-cutting. Check whether any term definitions used in your COREP or FINREP filings shifted in the 4.3 export.
  • The identical cells mapping may introduce cross-module identity relationships between existing templates and new TCB/AMLA templates. Verify before your next submission.
  • Framework 4.4, expected Q3 2026, is where COREP and FINREP template changes land. Phase 1 covers FINREP/IFRS 18 (first reference date March 2027) plus DORA, resolution, and Pillar 3 (first reference date December 2026). Phase 2 (September 2027) covers COREP own funds, large exposures, leverage ratio, ALMM, LCR, FRTB, ESG, and benchmarking.
  • The draft 4.3 package is missing AMLA tables AML.01.01 and AML.01.02, which will be added in the final June 2026 package.
  • Use the 4.3 draft as a free rehearsal. Load the DPM and taxonomy into your test environment, run regression checks, and fix any platform issues before 4.4 introduces substantive template changes under deadline pressure.

Sources and References

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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