EBA Pillar 3 Data Hub for Smaller Banks: What the SNCI Discussion Paper Changes

ByOfficer

Last updated: June 2026

If you run Pillar 3 disclosure at a smaller bank, the change worth watching is not a new template. It is who produces the numbers once the EBA Pillar 3 Data Hub reaches your institution. For large banks that switch already happened. For small and non-complex institutions it is now on the table, and the EBA is proposing to calculate and publish your disclosures for you, from supervisory data you already file.

On 8 June 2026 the EBA published discussion paper EBA/DP/2026/02 on the Pillar 3 Data Hub process for small and non-complex institutions. It sets out how the EBA will build, calculate and publish disclosures on behalf of around 2,300 smaller banks, the timeline, and the points it still wants feedback on, with comments open until 20 July 2026. The mechanics below are proposals, not binding rules, but the direction is clear enough to start mapping the impact now.

Related reading: Pillar 3 disclosure requirements for banks

What the Pillar 3 Data Hub actually is

The Pillar 3 Data Hub, or P3DH, is a centralised platform on the EBA website that holds prudential disclosures for the whole sector in one place. Users can view the data online or download raw data for a single institution and template, or for a group of institutions and templates at once. The point is comparability, side by side, to support market discipline.

The legal basis sits in the CRR. CRR3, introduced by Regulation (EU) 2024/1623 amending Regulation (EU) No 575/2013, changed the rules on the means of disclosure. Where the earlier text required each institution to disclose Pillar 3 information in a single location, usually its own website, the amended Article 434 now mandates the EBA to publish that information centrally. That platform is the data hub.

The EBA announced the P3DH go-live on 28 January 2026. Large and other institutions began submitting Pillar 3 reports through the platform from 26 January 2026, including reports for the 2025 transitional reference dates. One detail shapes how you read the rest: for those institutions the EBA publishes the disclosure report exactly as submitted, without transformation. The bank prepares the file, signs it off, and owns it. So the first thing teams get wrong is assuming the hub going live removed a large or other institution’s duty to prepare its own disclosures. It changed where the finished disclosure is published, not who builds it.

Why smaller banks get a different process

For small and non-complex institutions the model flips. Under the CRR the EBA is required to publish the disclosures on behalf of these institutions, based on what they report to their competent authorities under Article 430 on supervisory reporting. The press release ties this SNCI route to Article 434(4) of the CRR. Instead of submitting a finished disclosure package, an SNCI submits its normal supervisory return and the EBA does the rest.

Whether your bank sits in this bucket is a classification question, not a choice. The categories follow Article 4 of the CRR: large institution under point (146), small and non-complex institution under point (145), and “other institution” for anything that fits neither. The EBA runs its calculations against a list drawn from master data that competent authorities maintain, not from a self-declaration.

This is where a smaller bank can misread the change. Under the proposal an SNCI does not file a separate Pillar 3 disclosure at all. There is no new return to build and no new portal to learn. The EBA derives the published figures from the supervisory data you already send. The trade-off is that you give up direct control over the rendered disclosure in exchange for not running a disclosure process of your own.

How the EBA will build SNCI disclosures from supervisory data

The engine is a mapping exercise. The EBA takes data points already collected in supervisory reporting, maps them to the relevant Pillar 3 fields, and applies calculation formulas to produce the disclosure figures. Those formulas sit in the EBA’s internal Data Point Model and run on an internally developed calculation engine. The proposed formulas for the first template are set out in an annex to the discussion paper, and future templates’ formulas will each go out for a short consultation before they are finalised.

The first launch is deliberately narrow: a single template, EU KM1, the key metrics template required under Article 447 of the CRR. For non-listed SNCIs, the majority, that one template already covers the full set of Pillar 3 templates currently applicable to them. EU KM1 pulls together the own funds, risk-weighted exposure, capital ratio, leverage and liquidity figures that already flow through supervisory reporting. The EBA can rebuild EU KM1 centrally because the template is designed around quantitative data points already available, or proposed to be made available, through supervisory reporting.

One limit is built into the data. Only quantitative information is currently collected under supervisory reporting; the qualitative narrative tables are not all there, which is why the EBA has put questions about collecting qualitative information into a separate consultation. And do not read this as the EBA taking ownership of your numbers. The discussion paper is explicit that responsibility and ownership of the data stay with the reporting institution. The EBA’s role is limited to running the calculations correctly and keeping the methodology transparent, with a disclaimer to that effect in the hub.

The timeline reporting teams should map

The change is staged across several years, and the dates are the part worth writing down. The first publication is planned for the fourth quarter of 2026, covering a reduced set of requirements, the EU KM1 template, for listed SNCIs with a December 2025 reference date. The EBA frames this as a transition launch that also buys time to test the calculation engine through a pilot exercise with volunteering SNCIs. For 2027 the paper sets out several publication options and asks the industry which to prefer, with amendments reflected in the Data Point Model depending on the supervisory reporting consultation. A complete publication of all Pillar 3 requirements applicable to SNCIs is then envisaged in 2028, with a December 2027 reference date.

Steady-state publication dates differ by institution type. For non-listed SNCIs the EBA proposes end-September, chosen so that supervisory data has cleared its reporting deadlines, most audit work, and the bulk of resubmissions before figures go public. For listed SNCIs that would be too late: the Transparency Directive (Directive 2004/109/EC) requires annual financial reports within four months of year-end, and Article 433 of the CRR ties annual Pillar 3 publication to the day institutions publish their financial statements. The paper proposes end-April for listed SNCIs while asking whether end-June would work better given how late audited supervisory data arrives.

One ESG thread runs alongside this. From a 31 December 2027 first reference date, non-listed SNCIs become subject to ESG disclosure requirements under Article 449a of the CRR, which is why the early launches can stay narrow. We cover those in our note on the EBA ESG Pillar 3 disclosure templates.

What this changes in your reporting workflow now

The practical shift is that supervisory data quality becomes your Pillar 3 quality. Once the EBA calculates the disclosure from your submitted returns, an error or a late adjustment flows straight into what the public sees. The first thing I check on a centralised-disclosure change is the resubmission handling, because a resubmitted supervisory return after publication is no longer just an internal correction. The discussion paper devotes a section to how resubmitted data will be treated.

One manual lever stays with the institution. The CRR allows an institution to omit non-material, proprietary or confidential information under Article 432, and only the institution can make that call. Under the proposal, if there is information you do not want the EBA to publish on your behalf, you contact the EBA helpdesk with reasons up to one month before the scheduled publication date. Communications after that point would be disregarded.

The most common misread is treating any of this as settled. It is a discussion paper, and its own disclaimer says the views are preliminary and do not bind the EBA’s eventual implementation. Some data points the EBA needs do not yet exist in supervisory reporting, which is the subject of a separate consultation on revisions to the supervisory reporting standards under Commission Implementing Regulation (EU) 2024/3117 that runs until 10 July 2026. Both consultations have to close before the SNCI process is fixed. This sits alongside the wider framework changes we track in our coverage of the EBA framework 4.3 DPM changes. The EBA is also holding a public hearing on 1 July 2026 from 15:00 to 16:30 CEST, with registration open until 26 June 2026 at 16:00 CEST.

Frequently Asked Questions

Is the Pillar 3 Data Hub already live?

It is live for large and other institutions, since 26 January 2026, with disclosures available from the June 2025 reference date. The extension to small and non-complex institutions is still at the discussion-paper stage.

Will my SNCI have to submit a separate Pillar 3 file to the EBA?

Under the proposal, no. The EBA would prepare and publish the disclosures for SNCIs based on the supervisory data you already report under Article 430 of the CRR. That differs from large and other institutions, which submit finished disclosure reports that the EBA publishes without transformation.

Which template comes first for SNCIs?

The EU KM1 key metrics template, required under Article 447 of the CRR. The EBA proposes a staggered approach starting with EU KM1, which for non-listed SNCIs already covers the full set of Pillar 3 templates currently applicable to them.

When is the first SNCI publication expected?

The fourth quarter of 2026, covering a reduced set of requirements for listed SNCIs with a December 2025 reference date. A complete publication of all Pillar 3 requirements applicable to SNCIs is envisaged in 2028, with a December 2027 reference date.

How do I keep confidential information out of the published disclosures?

Article 432 of the CRR lets an institution omit non-material, proprietary or confidential information, and only the institution can make that decision. The discussion paper proposes that you notify the EBA helpdesk, with reasons, at least one month before the scheduled publication date.

Related Articles

Key Takeaways

  • The EBA Pillar 3 Data Hub centralises prudential disclosures and has published for large and other institutions since 26 January 2026.
  • Discussion paper EBA/DP/2026/02, published 8 June 2026, sets out the proposed process for extending the hub to around 2,300 small and non-complex institutions, with comments open until 20 July 2026.
  • For SNCIs the EBA will calculate and publish Pillar 3 disclosures from supervisory data reported under Article 430, rather than the institution submitting a finished disclosure file.
  • The first publication is planned for Q4 2026, covering the EU KM1 template for listed SNCIs with a December 2025 reference date; full coverage is envisaged in 2028 with a December 2027 reference date.
  • Data ownership stays with the institution, which can still omit information under Article 432 by notifying the EBA helpdesk at least one month before publication.
  • The proposal is not yet binding, and some required data points depend on the supervisory reporting consultation under Commission Implementing Regulation (EU) 2024/3117 that closes on 10 July 2026.

Sources and References

  • EBA, press release, “EBA launches a discussion paper on the Pillar 3 data hub for small banks”, 8 June 2026: eba.europa.eu
  • EBA, Discussion Paper EBA/DP/2026/02, “Discussion Paper on Pillar 3 Data Hub process to SNCIs”, 8 June 2026 (PDF): eba.europa.eu
  • EBA, press release, “The EBA Pillar 3 data hub goes live”, 28 January 2026: eba.europa.eu
  • EBA, Pillar 3 data hub (platform and resources): eba.europa.eu
  • EBA, Final Report EBA/ITS/2025/01, “Draft ITS on the Pillar 3 data hub for large and other institutions” under Article 434a CRR, 12 February 2025 (PDF): eba.europa.eu
  • Regulation (EU) 2024/1623 (CRR3) amending Regulation (EU) No 575/2013, EUR-Lex: eur-lex.europa.eu
  • Regulation (EU) No 575/2013 (CRR), consolidated text including Articles 430, 432, 433, 434, 434a, 447 and 449a, EUR-Lex: eur-lex.europa.eu
  • Commission Implementing Regulation (EU) 2024/3172 on institutions’ public disclosures (Pillar 3 ITS), EUR-Lex: eur-lex.europa.eu
  • EBA, Consultation module “Alignment with P3 disclosures for SNCIs” (EBA/CP/2026/07, Module 8, 10 April 2026), revisions to the ITS on supervisory reporting (Commission Implementing Regulation (EU) 2024/3117), open until 10 July 2026: eba.europa.eu

Getting ahead of the SNCI data hub switch

The smaller your bank, the more this proposal works in your favour, because it lifts the cost of running a disclosure process and hands the calculation to the EBA. The catch is that it moves quality control upstream. Once the EBA builds your figures from supervisory returns, the discipline that used to sit in your disclosure workflow has to live in your reporting submission instead. Read EBA/DP/2026/02 against your own COREP process, decide whether you have an Article 432 omission to flag, and put the 20 July 2026 deadline in the calendar if you want a say in how the listed and non-listed dates land.

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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