EBA Reporting Framework 4.4: Five DPM Changes to Map

ByRegReportingDesk

The EBA published a draft technical package for version 4.4 of its reporting and disclosure framework on 24 July 2026, and the comment window is short: feedback on the package and the accompanying glossary closes on 24 August 2026. This early release of the EBA reporting framework 4.4 is a feedback-stage view of the Data Point Model (DPM), validation rules and XBRL taxonomies ahead of the final package in September 2026.

The value of an early draft is planning lead time. The package sets out five new reporting requirements with no single go-live date: two land on 31 December 2026, two on 31 March 2027, and the Pillar 3 ESG item carries a later date for smaller institutions. Mapping which change touches which return, and when, is the work to do now, while the draft is open to comment.

Related reading: our walkthrough of the EBA 4.3 DPM changes for COREP and FINREP covers how the previous release reshaped the same taxonomy that 4.4 now extends.

The dates that anchor the 4.4 build

The calendar comes first. The publication and feedback dates are procedural dates, while the implementation dates below are the EBA’s expected first reference dates for the draft phase 1 package and remain subject to finalisation and adoption of the relevant legal acts:

  • 24 July 2026 – draft 4.4 technical package published (phase 1).
  • 24 August 2026 – feedback closes on the draft package and the new glossary, via the EBA feedback form.
  • September 2026 – final phase 1 technical package published, reflecting stakeholder review.
  • 31 December 2026 – first reference date for the Pillar 3 ESG disclosure amendments (31 December 2027 for small and non-complex institutions), the resolution planning and MREL technical amendments, and the AMLA-eligibility templates.
  • 31 March 2027 – first reference date for the IFRS 18-aligned FINREP templates and the FRTB-related disclosure templates.

One caveat before building: this is a draft provided for information only. The final September package can move detail in response to comments and add elements the draft leaves out, so the current taxonomy is a planning input that can still change.

What phase 1 of the 4.4 package covers

The draft release is phase 1 of 4.4, carrying the DPM, validation rules and XBRL taxonomies for the five requirements listed in the dates above: the Pillar 3 disclosure ITS amendments, the IFRS 18-aligned FINREP templates, the FRTB-related disclosure templates, the resolution and MREL technical amendments, and the AMLA-eligibility templates. Each is detailed below.

Two items are held back for the final package: the EBA notes that the AML-eligibility validation rules and the revised AMLA risk assessment 2027 data collection templates are not in this draft and will follow in September. A team mapping the AMLA-eligibility templates now should expect to revisit the validation logic later.

Pillar 3 ESG disclosures and the small-institution date

The ESG item sits on the disclosure side of the framework, in the Pillar 3 ITS. It comes from the EBA final draft ITS of 22 June 2026 (EBA/ITS/2026/02), which amends Commission Implementing Regulation (EU) 2024/3172 as regards disclosures on ESG risks, equity exposures and the aggregate exposure to shadow banking entities. The first reference date is 31 December 2026, with a one-year deferral to 31 December 2027 for small and non-complex institutions.

That split date is easy to flatten in a project plan. A group that treats 31 December 2026 as the single ESG go-live will over-scope its smaller subsidiaries, while one that reads the deferral too broadly may miss the earlier date for its larger entities. The CRR definition of a small and non-complex institution decides which date applies, so the classification drives the build. Our guide to the CRR3 Pillar 3 ESG, equity and shadow banking disclosure ITS sets out the template scope in detail.

IFRS 18 in FINREP is voluntary first, mandatory later

The IFRS 18-aligned FINREP templates carry a first reference date of 31 March 2027, which reads alongside the EBA Opinion of 8 July 2026 (EBA/Op/2026/07). IFRS 18 was endorsed in the EU by Commission Regulation (EU) 2026/338 and replaces IAS 1. Each company must apply it no later than the start of its first financial year beginning on or after 1 January 2027; the amended FINREP ITS reflecting IFRS 18 are currently expected to apply only from the end of September 2027.

The 31 March 2027 first reference date applies to voluntary submission only, not mandatory compliance. The Opinion advises competent authorities to allow institutions to use the IFRS 18-aligned templates voluntarily during the interim period. An institution may use that interim route only where its competent authority permits it; otherwise, it must follow the applicable FINREP requirements until the amended ITS applies. The 4.4 phase 1 package provides the DPM, validation rules and taxonomy for institutions using the permitted voluntary templates, while mandatory application is currently expected from the end of September 2027 after adoption and entry into force of the amended ITS. Our note on the EBA Opinion on IFRS 18 in supervisory financial reporting explains the interim mechanics.

FRTB disclosures, resolution and AMLA-eligibility

The FRTB item sits on the disclosure side, separate from the COREP market-risk return. The package integrates FRTB-related disclosure templates into the DPM with a first reference date of 31 March 2027, and the EBA states that the draft reflects the impact of the third FRTB Delegated Act on disclosures, with further detail to follow. That distinction matters for how teams assign the work; see our overview of FRTB market risk reporting under CRR3 for the reporting-side picture.

The resolution item includes technical amendments to the DPM and taxonomy for resolution planning, MREL decisions and Pillar 3 disclosure templates, with an expected first reference date of 31 December 2026. The corrections identified in the EBA’s 9 April 2026 DPM known-issues list relate to resolution-planning and Pillar 3 disclosure templates. The AMLA-eligibility reporting applies only to obliged entities identified as ‘provisionally eligible’ for AMLA’s direct supervision process; the EBA templates carry a first reference date of 31 December 2026. The package adds the DPM and taxonomy for that reporting, while the matching validation rules are deferred to the final package.

Why the COREP own funds overhaul is not in this release

A reasonable assumption is that a 4.4 package changes COREP alongside FINREP. Phase 1 does not. The supervisory reporting amendments to COREP own funds, large exposures and leverage, plus liquidity monitoring, asset encumbrance, benchmarking and IFRS 9 templates and new initial margin model reporting, sit in phase 2 (labelled 4.4.1 on the EBA reporting frameworks page). That phase carries the rest of the topics from the 10 April 2026 consultation on major simplification of supervisory reporting.

The line to hold is between disclosure and supervisory reporting. Phase 1 delivers the Pillar 3 disclosure amendments plus the IFRS 18 FINREP templates; the COREP-side simplification wave is a separate, later track. Reading the two as one cycle risks misallocating build capacity: the EBA currently gives phase 2 an expected first reference date of September 2027 for the main supervisory-reporting changes and IMMA reporting, while the DORA technical amendments carry an expected first reference date of December 2027. These are expected framework dates, not final legal application dates. Our summary of the EBA supervisory reporting simplification consultation tracks the phase 2 scope.

DPM 2.0, the glossary conversion and validation rules

The 4.4 draft continues the transition to DPM 2.0 set out in the EBA implementation plan of June 2024, and ships a new version of the conversion file between the DPM 1.0 and DPM 2.0 glossaries. The EBA seeks comment on the glossary as well, which is why the two are consulted together. Teams still mapping against DPM 1.0 concepts should test the updated conversion file before the final release.

Validation rules follow their own cadence. The EBA publishes an updated validation rules package roughly two months before a release first reference date, and small validation rules packages every quarter. A draft taxonomy that validates cleanly today can still pick up rule changes before December 2026. The EBA DPM known issues list is the place to track corrections between releases.

Frequently Asked Questions

Is the 24 July 2026 package a legal instrument banks must implement now?

No. It is a draft technical package provided for information and implementation planning. The current binding disclosure instrument is Commission Implementing Regulation (EU) 2024/3172, as amended. The EBA’s June 2026 disclosure ITS is a final draft submitted to the European Commission and is not yet binding; its amendments would become binding only through a Commission implementing regulation adopted and published in the Official Journal. The technical package translates the relevant legal requirements and draft amendments into DPM, taxonomy and validation rules.

Do all five 4.4 changes go live on the same date?

No. The Pillar 3 ESG amendments, the resolution and MREL amendments and the AMLA-eligibility templates carry a first reference date of 31 December 2026. The IFRS 18 FINREP and FRTB disclosure templates carry 31 March 2027. Small and non-complex institutions get 31 December 2027 for the ESG disclosures.

Are the IFRS 18 FINREP templates mandatory from 31 March 2027?

Not at that stage. The EBA Opinion of 8 July 2026 advises competent authorities to permit voluntary use during the interim period. Mandatory application of the amended FINREP ITS is expected from end September 2027, in phase 2.

Does the 4.4 phase 1 package change COREP own funds or large exposures?

No. The COREP own funds, large exposures and leverage amendments, together with liquidity, asset encumbrance, benchmarking, IFRS 9 and initial margin model reporting, are assigned to phase 2 (4.4.1), which follows the 10 April 2026 simplification consultation.

What is missing from the draft that will appear in the final package?

The EBA states that the AML-eligibility validation rules and the revised AMLA risk assessment 2027 data collection templates are not yet included, and will be added in the final package.

Key Takeaways

  • The EBA published the draft 4.4 technical package on 24 July 2026; feedback on the package and the new glossary closes on 24 August 2026, with the final phase 1 package due in September 2026.
  • Phase 1 carries five changes: Pillar 3 ESG disclosures, IFRS 18 FINREP templates, FRTB-related disclosures, resolution and MREL technical amendments, and AMLA-eligibility templates.
  • First reference dates differ: 31 December 2026 for ESG (31 December 2027 for small and non-complex institutions), resolution and AMLA-eligibility; 31 March 2027 for IFRS 18 FINREP and FRTB disclosures.
  • The IFRS 18-aligned FINREP templates are for voluntary interim use where the competent authority permits it, per the EBA Opinion of 8 July 2026; mandatory application of the amended ITS is expected from end September 2027.
  • COREP own funds, large exposures, leverage, liquidity and initial margin model reporting are phase 2 (4.4.1) items tied to the 10 April 2026 simplification consultation, outside this phase 1 release.
  • AML-eligibility validation rules and the revised AMLA risk assessment 2027 templates are deferred to the September final package; the package continues the DPM 2.0 transition with a new glossary conversion file.

Sources and References

Mapping the 4.4 draft into your reporting calendar

The most useful thing to do with the 4.4 draft is turn it into a dated map: which of the five changes hits which return, on which first reference date, and which entities each date applies to. The draft is open until 24 August 2026, so any template that does not reconcile to a bank’s own reading of the underlying ITS is a feedback point as much as a build item. Fixing the disclosure-versus-reporting split and the ESG small-institution date now avoids re-scoping when the final package lands.

Last updated: July 2026

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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