ORBOF Reporting Guidance 2026: New Art 65(c) Resolution Fund Data

ByRegReportingDesk
RegReportingDesk card: SSB, Statistics Norway, Norway

Statistics Norway (SSB) has published a new edition of the ORBOF reporting guidance, dated 27 October 2026 and applying from 1 November 2026, together with ORBOF code lists for the fourth quarter of 2026 dated 26 October 2026. For Norwegian banks and kredittforetak, the edition adds one new block to ORBOF reporting: Report 12, tilleggsart 65(c), “Justering av grunnbidrag til krisetiltaksfondet”, which carries the adjustments to the base for contributions to Norway’s resolution fund. The guidance states that this data was previously reported directly to Bankenes sikringsfond and goes to ORBOF from the 31 December 2026 reference date.

ORBOF is a joint collection by Finanstilsynet, SSB, Norges Bank and Bankenes sikringsfond; SSB publishes the code lists and guidance and collects the data through Altinn. For banks, kredittforetak and finansieringsforetak, the guidance cites sections 3-1 and 3-4 of the Financial Supervision Act of 21 June 2024 (finanstilsynsloven) as the legal basis. Most of the yellow-marked changes in the November edition match topics SSB announced on 13 May 2026; the 65(c) block appears in no change notice on SSB’s ORBOF page as of 30 October 2026, and one marked sector-group edit (31000 in D2) already stood in the May 2026 edition although the 13 May notice does not list it.

Related reading: CSSF CODERES 26/22: the SRF data reporting form for 2027

ORBOF reporting dates for the November 2026 edition

  • 26 October 2026: date of the Q4 2026 code lists (Norwegian and English).
  • 27 October 2026: date printed on the guidance.
  • 1 November 2026: the guidance applies from this date.
  • 31 December 2026: first reference date for which the 65(c) data goes to ORBOF.
  • Annual deadline for 65(c): 30 calendar days under Table 1 of the guidance, while SSB’s ORBOF page gives 20 January for fourth-quarter and annual reporting (see the FAQ).
  • 31 March 2027: updated Reports 10 and 21 after the final annual accounts.

Two rules in section 4 of the guidance apply to every deadline. When a deadline falls on a Saturday or public holiday, the guidance requires the data to be submitted, with SSB’s receipt, by 11:00 on the first working day after it. It also requires errors found by SSB’s validation checks to be corrected as soon as possible and at the latest within two working days after the reporting deadline.

Art 65(c): resolution fund inputs move into ORBOF Report 12

Section 9.11 describes the contribution base for krisetiltaksfondet as total assets (forvaltningskapital) less own funds (ansvarlig kapital) and guaranteed deposits, adjusted for intra-group debt and derivative liabilities. Art 65(c) holds those two adjustments. The section lists no 65(c) item for total assets, own funds or guaranteed deposits, and the guidance contains no contribution rate or invoicing step.

The scope is narrow. Table 1 adds 65.c to the annual rows for Norwegian banks, next to art 39 and 65.b, and for Norwegian kredittforetak, next to art 39, each with a 30-day deadline. Its neighbour 65.b is the annual specification linked to the EU deposit guarantee scheme; our deposit guarantee scheme reporting guide covers that side. The two 65.c entries are qualified “for norske banker” and “for norske kredittforetak”, which leaves out NUF branches; the rows for finansieringsforetak, state lending institutions, Statens pensjonsfond utland and Norges Bank carry no 65.c entry. The English code list labels the block “Adjustment of the basic contribution to the resolution fund. Annual report for Norwegian banks and mortgage companies” (its term for kredittforetak) and heads its Report 12 sheet “From november 2026”, while the Norwegian code list heads the same sheet “Gjelder fra Desember 2026”.

Derivative adjustment (65.0.05)

Because derivative accounting is not harmonised across accounting standards, derivative liabilities in the base are revalued using the methodology in Articles 5a to 5e of Commission Delegated Regulation (EU) 2015/63, which Delegated Regulation (EU) 2023/662 inserted. The adjustment applies to financial undertakings with derivative liabilities under the CRR, and credit derivatives stay out of the reporting.

  • 65.0.05.0.10, derivative liabilities on and off balance sheet: .10 is the accounting value on balance sheet, which should in principle equal balance-sheet derivative liabilities (ORBOF reference Report 10 item 7.40); .20 is the IFRS 13 (or equivalent) fair value of derivatives held off balance sheet, with positive values excluded and negative values summed as an absolute amount, as the guidance instructs for this field. The underlying Article 5(3) rule of Delegated Regulation (EU) 2015/63, as the CSSF’s guidance describes it, refers to the sum of the fair values of those derivatives and treats that sum, where negative, as the replacement cost.
  • 65.0.05.0.20, derivative liabilities valued under the methodology: the Article 5b market-value method, which the guidance calls the Current Exposure Method (replacement cost plus potential future credit exposure), split into .10 not linked and .20 linked to intra-group debt.

For resolution-fund contribution calculations, Article 5(3) of Delegated Regulation (EU) 2015/63 requires the yearly average amount of derivative liabilities to be calculated on a quarterly basis. The annual contribution valuation is the average of the year’s quarterly values. ORBOF collects the accounting value (65.0.05.0.10) and the methodology value (65.0.05.0.20) as separate fields. A derivative liability to a qualifying group entity appears twice in the block: at methodology value in 65.0.05.0.20.20 and at carrying amount in 65.0.06.0.30.20.

Intra-group adjustment (65.0.06)

Contributors to krisetiltaksfondet include banks, kredittforetak and certain investment firms (verdipapirforetak), so one group can contain several contributing entities. To avoid double counting, liabilities between two group institutions come out of the base when all three conditions in the guidance hold:

  • both institutions are established in the EEA;
  • both are fully included in the same consolidated supervision under Articles 6 to 17 of the CRR (Article 5(1)(a)(ii) of Delegated Regulation (EU) 2015/63 adds that each must be subject to appropriate centralised risk evaluation, measurement and control procedures);
  • there is no current or foreseen material practical or legal impediment to prompt repayment of the liability when due.

The guidance leaves liabilities to a group company that does not pay contributions out of the reporting. For qualifying liabilities, Article 5(2) of Delegated Regulation (EU) 2015/63 provides that the deduction is made evenly, transaction by transaction, from the total liabilities of the institutions that are parties to each transaction; the guidance describes this as an even split for each transaction between the entities concerned. The items are 65.0.06.0.30 (carrying amount of qualifying intra-group debt, split by whether it arises from derivatives), 65.0.06.0.40.00 (carrying amount of qualifying intra-group assets) and 65.0.06.0.45.00 (those assets after any derivative adjustment by the group counterparty).

The asset item depends on another entity’s filing. An intra-group asset counts in the contribution calculation only where another group company holds the corresponding liability and reports it, so a bank and its kredittforetak need matching figures before either submits.

The rest of the yellow text: May 2026 edition changes, including sector group D2

The guidance marks changes in yellow without dating them. Set against the topics in SSB’s 13 May 2026 notice (central bank certificates, other paid-in equity, subsidised-rate loans), the marked passages sort as follows; the sorting compares the marked text with the notice, which gives topic-level entries only.

Item Where What the marked text says Topic in 13 May 2026 notice?
Norges Bank certificates held Report 10, 2.30.91/92 Short-term certificates issued by Norges Bank, a new liquidity-management instrument from May 2026, sit in other interest-bearing negotiable securities Yes
Certificates issued Report 10, 7.30.91 For Norges Bank as reporter, covers its issued short-term certificates from May 2026 Yes
Other paid-in equity Report 10, 9.26 Capital contributions not tied directly to share capital or share premium, including contributions that give no right to shares Yes
Subsidised-rate loans Report 12, art 75 and 76 Reported under the customer’s borrower sector, at the customer rate plus the subsidised part paid by others Yes
Sector group D2 Part III, table 26 31000 (Norges Bank) marked within the D2 list used in Report 10 No
Resolution fund adjustment Table 1 and section 9.11 New annual art 65(c) for Norwegian banks and kredittforetak No

Norges Bank’s Financial Stability Report 2026 H1 gives the background to the first two rows: the bank decided to issue one- and three-month central bank certificates and held the first auction on 5 May 2026. For the wider liquidity context, see our note on Norges Bank’s 2026 circular on bank reserve quotas.

Two of the rows need care. The interest rate statistics exclude loans whose rate departs from the market rate because of default, debt collection or debt settlement. Subsidised-rate loans are a separate case: they stay in art 75 and 76, at the gross rate. On 9.26, the marked text now opens with a general definition and says the item “also” applies to state lending institutions and NUF branches, while Table 14, the Report 13 conversion table, still labels 9.26.00 as applying only to those two groups.

D2 is defined as all detailed sectors except 36000, 36008, 36009, 43000, 85000, 92000 and 98000, and table 26 shows 31000 marked inside its sector list. The May 2026 edition, applying from 1 May 2026, already listed 31000 in D2, while the April 2025 edition excluded it. A reporter whose validation tables still mirror the April 2025 D2 list would see Report 10 lines coded to sector 31000 under D2 rejected in-house.

Frequently Asked Questions

Our bank has branches abroad. Which reporting unit files art 65(c)?

The November 2026 edition does not say. Table 2, for reporters with foreign branches, has no 65.c row; 65.c appears only in Table 1, which covers reporters without foreign branches and NUF branches. Section 4.1 says the reporting unit for each tilleggsart in Reports 12 and 13 is marked in the code-list headings, but the 65(c) heading names none. The guidance gives InnFin@ssb.no as SSB’s contact.

Is the first art 65(c) deadline 30 days after 31 December 2026, or 20 January 2027?

The sources point in different directions. Table 1 lists 65.c among the annual items with a 30-calendar-day deadline; by calculation, 30 days after 31 December 2026 is Saturday 30 January 2027, which the weekend rule moves to 11:00 on Monday 1 February 2027. SSB’s ORBOF page states that Reports 10, 21, 12 and 13 for the fourth quarter and annual reporting are due on 20 January. Section 7 of the guidance says the deadline for each form is shown in the Altinn message box.

Can we use the simplified exposure method instead of the Article 5b method, and does ORBOF apply the 75% floor?

Under Article 5a(5) of Delegated Regulation (EU) 2015/63, the Simplified Exposure Method in Article 5c is available only for derivative contracts listed in points 1 and 2 of Annex II to the CRR, provided that the institution’s on- and off-balance-sheet derivative business satisfies the conditions in Article 273a(2) CRR. The 75% floor applies separately: the derivative-liability value assigned for contribution purposes may not fall below 75% of the accounting value.

The ORBOF guidance names only the Article 5b method and describes no floor, although it collects both the accounting value (65.0.05.0.10) and the methodology value (65.0.05.0.20). Norway has incorporated Delegated Regulation (EU) 2023/662 through finansforetaksforskriften § 20-2 second paragraph no. 9 (amendment FOR-2025-12-05-2818, in force 5 December 2025), and the ORBOF guidance’s footnote 7 points to Article 5(3) of Delegated Regulation (EU) 2015/63 for the derivative-liability methodology. The floor and the simplified-method option are therefore part of the contribution calculation itself. What remains to be confirmed with SSB is how the ORBOF fields capture the selected valuation method and any floor adjustment.

Key Takeaways

  • Agree 65.0.06 intra-group figures across the group’s ORBOF reporters before the first year-end filing; an asset without a reported counterparty liability does not count.
  • Reconcile 65.0.05.0.10.10 to Report 10 item 7.40 as a pre-submission check.
  • Source 65.0.05.0.20 from a derivative exposure calculation under Article 5b, excluding credit derivatives, and split it by intra-group link; confirm with SSB how the Article 5(3) quarterly averaging maps to the field.
  • For Table 2 reporters, the 65(c) reporting unit is the open point to clear with SSB before January 2027.
  • Load the 26 October 2026 code lists into validation before the first filing under the November edition, and confirm that Report 10 validation treats sector 31000 as part of D2, as table 26 already did in the May 2026 edition.

Sources and References

  • SSB, Finanstilsynet, Norges Bank and Bankenes sikringsfond, Veiledning til rapporteringen (ORBOF), 27 October 2026, applies from 1 November 2026: SSB guidance PDF
  • SSB, ORBOF reporting page (material, change notices, year-end deadlines): ssb.no/innrapportering/orbof
  • SSB, Finanstilsynet, Norges Bank and Bankenes sikringsfond, Veiledning til rapporteringen (ORBOF), editions dated 31 March 2025 (applying from April 2025) and 19 April 2026 (applying from 1 May 2026), table 26 (sector group D2): superseded editions, no longer published on SSB’s ORBOF page
  • SSB, ORBOF code lists Q4 2026, Norwegian, 26 October 2026: Kodelister (xlsx)
  • SSB, ORBOF code lists Q4 2026, English, 26 October 2026: Code lists (xlsx)
  • Finanstilsynet, ORBOF: offentlig regnskapsrapportering fra banker, kredittforetak og finansieringsforetak: finanstilsynet.no
  • Lov om Finanstilsynet (finanstilsynsloven), LOV-2024-06-21-41, sections 3-1 and 3-4: Lovdata
  • Finansforetaksforskriften § 20-2 second paragraph no. 9, as amended by FOR-2025-12-05-2818: Lovdata
  • Commission Delegated Regulation (EU) 2015/63 on ex ante contributions to resolution financing arrangements: EUR-Lex
  • Commission Delegated Regulation (EU) 2023/662 of 20 January 2023 amending Delegated Regulation (EU) 2015/63 as regards the methodology for the calculation of liabilities arising from derivatives: EUR-Lex
  • CSSF Circular CODERES 26/22, Annex 4, definitions and guidance for the SRF data reporting form, 2027 contribution period: CSSF
  • Norges Bank, Financial Stability Report 2026 H1 (central bank certificates): Norges Bank PDF

Building the first art 65(c) year-end submission

The 65(c) block needs two inputs that a general ledger does not hold: an Article 5b exposure value for derivative liabilities and intra-group balances agreed with the counterparty entity’s own filing. Under section 7 of the guidance, Altinn places a period’s forms in the message box from the first day of the following month, so the year-end 2026 forms arrive from 1 January 2027. Before then, two points need SSB’s confirmation: which date governs the first 65(c) deadline, and which reporting unit files the block in groups with foreign branches.

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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