Bundesbank Customer Classification in 2026: RS-57 sFEU Update and NACE Rev. 2.1

On 21 September 2026 the Deutsche Bundesbank issued Rundschreiben 57/2026 on the updated 2026 sFEU list. Counterparty sector classification is material to the monthly balance sheet statistics and the compilation of monetary statistics. Minimum-reserve treatment is separate: under Article 5 of Regulation (EU) 2021/378, liabilities to another institution are excluded from the reserve base only where that institution is subject to minimum reserve requirements and is not exempt, while liabilities to the ECB or a euro-area NCB are also excluded. The MFI sector code alone is therefore not the reserve-status test.

Two things moved at once for the 2026 reporting year. The customer classification (Kundensystematik) that MFIs map counterparties against was reissued in a July 2026 edition, and from the January 2026 reporting cycle the entire branch layer switched to NACE Rev. 2.1 under Rundschreiben 40/2025. Alongside that, the Federal Statistical Office maintains a list of other funds, institutions and enterprises, the sFEU, which resolves the awkward public-sector cases; the Bundesbank publishes an enriched version dated 18 September 2026.

For the NACE Rev. 2.1 transition, the BISTA and quarterly Kreditnehmerstatistik forms remain unchanged in structure and layout under Rundschreiben 57/2025. AnaCredit is different: the Bundesbank uses technical specification and schema version 2.8 from 1 February 2026, and AnaCredit submissions use NExt. The classification change should therefore not be described as leaving every reporting interface or schema unchanged.

Related reading: AnaCredit reporting in Germany: the Bundesbank Kreditdatenstatistik

The dates that govern the 2026 reclassification

The calendar for this change is spread across several instruments instead of a single go-live. The operative dates a German reporting team needs on one page:

• NACE Rev. 2.1 first mandatory application in bank statistical reporting: reference dates from January 2026 onward, under Rundschreiben 40/2025 (25 July 2025).
• Kundensystematik, Statistische Sonderveroeffentlichung 2: July 2026 edition, dated 1 July 2026, updated on a half-yearly cycle.
• sFEU list, Bundesbank enriched version: dated 18 September 2026, carrying the additions and deletions notified for the year.
• Reporting Circular RS-57/2026: issued 21 September 2026; the updated sFEU classifications apply from reporting month December 2026 per the circular’s instruction.
• Monthly balance sheet statistics (BISTA): due the sixth business day after month-end. The January 2026 reference date fell due 9 February 2026; the September 2026 reference date fell due 8 October 2026; the December 2026 reference date is due 11 January 2027.
• Borrower statistics (Kreditnehmerstatistik): due the tenth business day after each calendar quarter-end.
• AnaCredit (Kreditdatenstatistik): monthly data for observed units resident in Germany are due by the sixth business day, with approved extensions to the ninth or twelfth business day where applicable; monthly data for observed units resident abroad are due by the fifteenth business day. Quarterly data are due 12 May, 11 August, 11 November and 11 February.

The one date that does the damage if missed is the January 2026 cut-over. Because the branch layer changed at the start of the reporting year, a January 2026 filing prepared on the old branch keys is wrong at source, even if every figure ties out.

What Reporting Circular RS-57 actually transmits

Rundschreiben 57/2026 concerns the Bundesbank’s updated 2026 sFEU list. The July 2026 Kundensystematik is a separate half-yearly publication; the NACE Rev. 2.1 transition is governed by Rundschreiben 40/2025 and subsequent Bundesbank guidance.

The substance behind it is the publication called Bankenstatistik, Kundensystematik, issued as Statistische Sonderveroeffentlichung 2 and published under section 18 of the Act on the Deutsche Bundesbank. It is updated twice a year, so the reference an MFI maps against is a living document that carries a version date and moves on a fixed cycle. The classification does two jobs at once: it assigns each counterparty to an economic sector following the European System of Accounts (ESVG 2010, Regulation (EU) No 549/2013), and it assigns each counterparty an activity, or branch, through what the Bundesbank calls customer-classification keys (Kundensystematik-Schluessel).

ECB Regulation (EU) 2021/379 sets the applicable balance-sheet reporting requirements and counterparty breakdowns for reporting agents within its scope. The Bundesbank’s Kundensystematik supports German reporting institutions in assigning counterparties by sector and branch in line with ESA 2010; Rundschreiben 57/2026 separately concerns the updated 2026 sFEU list. A team that treats RS-57 as a purely domestic administrative note misreads where the requirement comes from and why the sector definitions cannot be negotiated locally.

The sector map behind every counterparty in the customer classification

ESVG 2010 splits domestic counterparties into five sectors: non-financial corporations (S.11), financial corporations (S.12), general government (S.13), households (S.14) and non-profit institutions serving households (S.15). Foreign counterparties mirror the same five. That much is stable across editions. The classification detail that matters most lies one level down, inside financial corporations.

Financial corporations divide first into banks (MFIs) and the rest. The MFI block is the Bundesbank itself (S.121), other banks excluding the Bundesbank (S.122) and money market funds (S.123). Everything else is non-bank financial: investment funds other than money market funds (S.124), other financial institutions excluding insurers and pension funds (S.125), financial auxiliaries (S.126), captive financial institutions and money lenders (S.127), insurance corporations (S.128) and pension funds (S.129). Under ECB Regulation (EU) 2021/379, the reporting treatment of S.125, S.126 and S.127 is item-specific. For some balance-sheet items, such as loans and debt securities, the three subsectors are merged as S.125 + S.126 + S.127, with additional distinctions for central counterparties and financial vehicle corporations within S.125. The monthly liabilities side instead distinguishes S.125, S.126 and S.127 separately, so the merged treatment must not be generalised to monthly deposit reporting.

Money market funds are in the MFI sector (S.123), while investment funds other than money market funds are in S.124; that distinction matters for monetary-statistics sector breakdowns. It does not by itself determine minimum-reserve treatment. For reserve-base exclusions, the relevant test is whether the creditor institution is subject to minimum reserve requirements and is not exempt under Regulation (EU) 2021/378, rather than whether the counterparty is classified as an MFI.

The sFEU list and the public-sector decision it settles

The sFEU list covers public funds, institutions and enterprises that are market producers and are classified outside general government under ESA 2010. It must be distinguished from the separate Kernhaushalte and Extrahaushalte references; Extrahaushalte are public units classified in the general-government sector. The Bundesbank enriches the sFEU list with Kundensystematik keys and monthly balance-sheet-statistics positions.

For public-sector classification, the sFEU list must be used alongside the separate Kernhaushalte and Extrahaushalte references. The sFEU list identifies public market producers classified outside general government, whereas the Extrahaushalte list identifies qualifying public non-market units classified within general government. Public ownership alone does not determine the statistical sector.

Reporting teams should use the relevant Kernhaushalte, Extrahaushalte and sFEU references when classifying public counterparties rather than using the sFEU list as the sole public-sector reference. The Bundesbank’s current 2026 sFEU file is dated 18 September 2026 and includes additions and deletions relative to the previous year 2025.

NACE Rev. 2.1: the branch keys changed under you

The sector answer can stay identical while the branch answer moves, and 2026 is the year that happened wholesale. Rundschreiben 40/2025 brought NACE Rev. 2.1 into German bank statistical reporting for reference dates from January 2026, aligned to the Federal Statistical Office’s 2025 classification of economic activities (WZ 2025), which builds on NACE Rev. 2.1. The branch layer of the Kundensystematik is rebuilt on that base.

The clearest example is the motor trade. NACE Rev. 2.1 vacates the old Division 45 (sale, maintenance and repair of motor vehicles) to make Section G apply consistently. Trade in motor vehicles is redistributed into the wholesale and retail divisions (46 and 47), while maintenance and repair moves into a new group under Division 95. For a German MFI, a loan to a car dealership that used to carry the Division 45 branch key now carries a Division 46 or 47 key, and a garage’s loan moves toward Division 95. The counterparty is the same legal entity in the same ESVG sector; only its activity label changed.

The trap here is treating a branch reclassification as a data-quality event to fix later. The reporting side is neither optional nor gradual: from the January 2026 reference date the branch breakdown in the borrower statistics and the activity attributes in AnaCredit have to reflect NACE Rev. 2.1. A team that carried NACE Rev. 2 branch keys into filings for reference dates from 31 January 2026 would not have applied the mandatory NACE Rev. 2.1 classification. Genuine activity reclassifications caused by the NACE Rev. 2.1 transition should be distinguished from classification errors.

Where the classification feeds: BISTA, borrower statistics and AnaCredit

One counterparty record drives several returns, which is why a single misclassification propagates. The monthly balance sheet statistics (BISTA) is the core collection: the assets and liabilities of domestic banks at month-end, broken down by type, maturity and the sector of the debtor or creditor, filed in the XMW XML format through ExtraNet by the sixth business day. BISTA is also load-bearing for supervision, because under section 4 of the Financial and Risk-Bearing Capacity Regulation (FinaRisikoV) the same submission serves as supervisory financial information, the Vermoegensstatus, sitting next to the supervisory financial reporting a bank already maintains.

The borrower statistics (Kreditnehmerstatistik, form 10205) is a quarterly collection of outstanding loans to domestic enterprises and private persons, including non-profit institutions, by borrower group, loan type and maturity. It must reconcile to BISTA: the total of the classified loans must equal the corresponding loans to domestic enterprises and private persons in the monthly balance sheet statistics, down to the sub-sectors and to the housing and instalment-loan splits. AnaCredit separately reports granular credit data within its own reporting scope; it does not replicate the full Kreditnehmerstatistik population. Cross-return controls should therefore compare classifications where the same counterparty and exposure fall within the respective reporting populations and definitions.

That reconciliation chain rewards the same reference-data discipline that BCBS 239 risk data aggregation expects. Apply the classification version and application rule that governs each return and submission. Where the same counterparty and classification concept falls within multiple reporting populations, reconcile the underlying mapping and document any return-specific differences in coding or applicability.

Working the reclassification across the reference-date break

For teams that own the counterparty master, the 2026 change resolves into a short sequence. Re-run the counterparty mapping against the current Kundensystematik edition, because the sector and branch reference is versioned and moved in July; a cached copy from 2025 will not carry the changes. Resolve public counterparties against the current Kernhaushalte, Extrahaushalte and sFEU references as applicable before assigning a sector; do not use the sFEU list alone as the government-sector test. Apply the NACE Rev. 2.1 branch keys from the January 2026 reference date, and expect legitimate breaks where activities such as the motor trade were redistributed. Then reconcile the borrower statistics back to the monthly balance sheet statistics and confirm AnaCredit carries the same sector and activity, because that is where an inconsistency surfaces first.

Rundschreiben 40/2025 expressly addresses historical corrections: from 31 January 2026, correction reports relating to earlier reference dates must also be prepared using NACE Rev. 2.1 and WZ 2025. For AnaCredit master-data reporting, the change applies with reporting schema 2.8 from 1 February 2026.

Frequently Asked Questions

Do non-MFI credit institutions have to apply the same customer classification, or only banks classified as MFIs?

Both report the monthly balance sheet statistics, and both rely on the same customer classification for the sector and branch of their counterparties. For both MFIs and non-MFI credit institutions, the monthly balance sheet statistics cover the part of the institution located in Germany. From reporting month January 2025, separate BISTA reports for foreign branches and the total institution, together with the quarterly regional BISTA and Kreditnehmerstatistik reports, ceased to be required. The classification reference is shared; the set of returns it feeds differs by reporter type.

A counterparty’s ESVG sector has not changed, but its NACE activity has. Do we need to refile earlier 2026 periods?

The obligation is that filings for reference dates from January 2026 carry NACE Rev. 2.1 branch keys. If a period from January 2026 onward was filed on the old NACE Rev. 2 keys, that filing does not reflect the applicable classification and should be corrected through the Bundesbank’s normal correction process. A genuine branch break caused by the redistribution of activities is expected and is documented as such.

How do we treat a money market fund counterparty against an ordinary investment fund?

A money market fund is part of the MFI sector (S.123), so positions with it are inter-MFI for the monetary statistics. An investment fund that is not a money market fund is S.124 and is a non-MFI counterparty. The test is whether the fund meets the money-market-fund definition; the legal form of the vehicle does not decide it, so the classification follows the definition even where the marketing name points elsewhere.

What do we do with a public entity that is not on the sFEU list?

First check the current Kernhaushalte and Extrahaushalte references as well as the sFEU list. Absence from the sFEU list does not, by itself, determine the sector. If the relevant lists do not resolve the case, apply the ESA 2010 sector-classification criteria and raise the classification question with the Bundesbank where necessary.

Does the customer classification affect anything beyond statistics, or is it purely statistical?

It reaches supervision. The monthly balance sheet statistics doubles as supervisory financial information under section 4 of FinaRisikoV, so the same sector and branch classification that drives the statistical aggregates also sits inside the data supervisors read as the Vermoegensstatus. A classification error is therefore not confined to a single statistical series.

The Kundensystematik is updated twice a year. Which version applies to a given reference date?

The Kundensystematik is versioned and half-yearly, with the current edition dated 1 July 2026, but applicability cannot be reduced to the edition in force on the historical reference date. Rundschreiben 40/2025 requires correction reports submitted from 31 January 2026 for earlier reference dates to use NACE Rev. 2.1 and WZ 2025, while sFEU updates have their own application instructions in the relevant Bundesbank circular.

Related Articles

• AnaCredit Reporting in Germany: How the Bundesbank Kreditdatenstatistik collects loan-level data and where counterparty classification bites.
• Bank of England Form BT Monthly Reporting: A comparable national central-bank monthly statistical return, for teams filing across the UK and Germany.
• FINREP Reporting Explained: The supervisory financial reporting framework that sits alongside statistical returns in a bank’s data stack.
• COREP Reporting Explained: The prudential own-funds and capital reporting framework under the CRR.
• BCBS 239 Risk Data Aggregation: Why counterparty reference data and classification governance decide the quality of a bank’s reporting.

Key Takeaways

• Reporting Circular 57/2026 (21 September 2026) concerns the updated 2026 sFEU list; the new classifications apply from reporting month December 2026. The July 2026 Kundensystematik and the NACE Rev. 2.1 transition are separate references and should not be attributed to RS-57/2026.
• Sector classification follows ESA 2010 for the balance-sheet statistics required by ECB Regulation (EU) 2021/379 and affects monetary-statistics compilation. The minimum-reserve base is governed separately by Regulation (EU) 2021/378 and cannot be determined from the MFI sector boundary alone.
• Money market funds are MFIs (S.123); other investment funds are S.124. Classify by the money-market-fund definition, and let the legal wrapper follow it.
• The 2026 sFEU list identifies public market producers classified outside general government; the Bundesbank’s enriched version is dated 18 September 2026 and includes additions and deletions relative to the previous year 2025. General-government public units are covered separately by the Kernhaushalte and Extrahaushalte references.
• NACE Rev. 2.1 applies to reference dates from January 2026 under Rundschreiben 40/2025; the vacated Division 45 moves motor-vehicle trade to Divisions 46 and 47 and repair to Division 95.
• The Kreditnehmerstatistik (form 10205) must reconcile to the monthly balance sheet statistics. BISTA and AnaCredit reporting remain subject to the scope and classification rules governing each collection.
• BISTA is due the sixth business day after month-end and doubles as supervisory financial information under section 4 of FinaRisikoV.
• Apply Kundensystematik/NACE and public-sector-list versions according to the Bundesbank’s stated application rules, including the special NACE Rev. 2.1 rule for corrections to earlier reference dates; do not infer applicability solely from a file’s publication date.

Sources and References

• Deutsche Bundesbank, Reporting Circular RS-57, 21 September 2026 (PDF)
• Deutsche Bundesbank, Kundensystematik (customer classification) service page
• Deutsche Bundesbank, Bankenstatistik Kundensystematik, Statistische Sonderveroeffentlichung 2 (PDF)
• Deutsche Bundesbank, Application of the NACE Rev. 2.1 framework in bank statistical reporting
• Deutsche Bundesbank, Rundschreiben 40/2025, 25 July 2025 (NACE Rev. 2.1) (PDF)
• Deutsche Bundesbank, Monatliche Bilanzstatistik (monthly balance sheet statistics) service page
• Deutsche Bundesbank, Kreditnehmerstatistik (borrower statistics) service page
• Deutsche Bundesbank, Kreditdatenstatistik (AnaCredit) service page
• Regulation (EU) 2021/379 of the ECB on the balance sheet items of credit institutions and of the monetary financial institutions sector
• Regulation (EU) 2021/378 of the ECB on the application of minimum reserves (ECB/2021/1)
• Regulation (EU) No 549/2013 (European System of National and Regional Accounts, ESA 2010)

Next filing, not next edition

Treat the reclassification as a standing control on the counterparty master, verified before each return leaves rather than as a one-off project. The updated 2026 sFEU classifications apply from reporting month December 2026 per Bundesbank Rundschreiben 57/2026. Do not infer the application date from the 18 September file date of the Bundesbank-enriched list; the circular’s own instruction governs. Separately, NACE Rev. 2.1 applies to reporting dates after 1 January 2026, with the first affected month-end at 31 January 2026. The Kundensystematik is updated half-yearly; monitor the Bundesbank Kundensystematik page for the next published edition and its applicable reporting instructions.

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.