EBA Reporting Simplification ITS: Postponed to December 2027

The first reference date for the EBA reporting simplification ITS has moved to December 2027. On 6 November 2026 the European Banking Authority (EBA) said it will publish the final report on the draft Implementing Technical Standards (ITS) amending Commission Implementing Regulation (EU) 2024/3117, the ITS on supervisory reporting, in December 2026 and submit it to the European Commission for adoption. The consultation the EBA opened on 10 April 2026 had proposed application from September 2027. Selected reporting areas move further out: the release names liquidity, asset encumbrance, supervisory benchmarking and ESG reporting among the areas deferred until December 2028.

For COREP and FINREP teams the release resets the build calendar, with the data point model, taxonomies and validation rules due in early 2027 and at least a one-year implementation period before application. It also identifies four transition arrangements: optional IFRS 18-aligned interim FINREP templates under EBA/Op/2026/07; FRTB reporting in existing COREP templates using the EBA’s guidance; continued operational-risk loss reporting in existing templates, restricted to data unaffected by the new taxonomy; and continued use of the 2026 benchmarking ITS for credit risk and IFRS 9.

Related reading: EBA Supervisory Reporting Simplification: What to Flag

EBA reporting simplification ITS: the revised calendar

Two gaps in that calendar matter for planning. The release does not say whether the one-year implementation period runs from the final report, from the technical package or from publication of the adopted regulation in the Official Journal. Article 15(1) of Regulation (EU) No 1093/2010 normally gives the Commission three months from receipt of draft ITS to decide on adoption, with a possible one-month extension. If the draft ITS is received in December 2026, the ordinary decision window would run into March 2027, potentially April if extended. The actual receipt date and adoption outcome remain unknown.

The second gap is remittance. The stress-testing module gets its own remittance timelines and frequencies. For the other templates, if the amended ITS keeps the quarterly remittance dates in Article 3(1)(b) of Regulation (EU) 2024/3117, data for the December 2027 reference date would be due on 11 February 2028.

The EBA’s reporting framework 4.4 page had not caught up when fetched on 7 November 2026. It still listed 09/2027 as the expected first reference date for the phase 2 ITS amendments that carry the simplification package. The 6 November release is the later statement.

What the final package is set to contain

The package is still being finalised. The release sets its direction; template-level detail arrives with the December 2026 final report.

• Simpler templates: more proportionality, clarified instructions, lower reporting frequencies and closer alignment with disclosure requirements, with less collateral, stress-testing and ESG reporting and the removal of selected reporting thresholds.
• Credit risk and IFRS 9 benchmarking reporting integrated into the supervisory reporting framework, with IFRS 9 reporting requirements substantially simplified and a stronger focus on consolidated-level reporting.
• Simplified granular operational risk loss reporting, with simplified data fields and clearer instructions.
• A dedicated stress-testing reporting module with separate remittance timelines and frequencies and fewer data points.

The April release estimated that the proposals would cut data points across EU harmonised reporting by around 50%, despite new IFRS 18, ESG and FRTB requirements. The November release gives no updated figure, and the nine consultation modules remain the consulted version until the final report replaces them. Until the amending regulation is adopted and its new requirements apply, Regulation (EU) 2024/3117 as it stands is the binding text.

The 6 November release does not identify the thresholds selected for removal or state how the associated reporting scope would change. Article 4(3) of Regulation (EU) 2024/3117 applies a two-consecutive-reference-date entry test and a three-consecutive-reference-date exit test only to the reporting thresholds specifically listed in that paragraph (Article 5(2) and (3), Article 6(2) and (3), Articles 11 and 12, Article 15(2) to (5) and Articles 17 to 20). Other institutional scope conditions and threshold exceptions follow different rules. The effect of removing any particular threshold cannot be established until the final amendments identify it.

IFRS 18 and FRTB: the 2027 workarounds run longer

The release tells institutions and competent authorities to keep following the EBA Opinion on IFRS 18 reporting (EBA/Op/2026/07, 8 July 2026). The Opinion advises competent authorities to give institutions the option, but not the obligation, to report profit or loss from January 2027 in revised IFRS 18-aligned FINREP templates, carried in the release 4.4 phase 1 technical package under interim codes such as F 02.01 and F 16.01.1, with the frequencies, reference dates and remittance dates of Articles 2, 3, 11 and 12 of Regulation (EU) 2024/3117.

The Opinion expected the amending ITS to first apply at the end of September 2027. Its paragraph 16, however, defines the interim period as running until the first application date of the amending ITS, so on my reading the later date lengthens the window for the interim templates. The November release gives no separate IFRS 18 date. Our guide to the IFRS 18 FINREP interim templates maps the twelve interim codes.

For market risk, the release points to the EBA’s consideration on the application of the FRTB from 1 January 2027, published in August 2026. The August EBA paper expected revised market-risk reporting templates in the second half of 2027. That forecast must now be read alongside the EBA’s later 6 November announcement setting December 2027 as the general first reference date. Until the revised market-risk templates apply, the EBA advises institutions to reflect the FRTB framework as modified by Commission Delegated Regulation (EU) 2026/1221, applicable from 1 January 2027, in the currently applicable templates. The final ITS must confirm the market-risk module’s specific first reference date.

Institutions applying the overall multiplier of Article 495v CRR report CRR2 standardised and internal-model requirements in C 18.00 to C 24.00, FRTB alternative standardised approach figures in C 91.00 excluding the overall multiplier, and only the CRR2 risk-weighted exposure amount after the multiplier in C 02.00. Other institutions report only FRTB-based own funds requirements.

If market risk follows the general December 2027 date, that template guidance covers the March, June and September 2027 quarters. The August EBA paper’s conditional wording pre-dates publication of Commission Delegated Regulation (EU) 2026/1221 on 11 September 2026. The act entered into force on 12 September 2026 and applies from 1 January 2027; the reporting treatment and multiplier conditions are discussed in our article on the EBA FRTB no-action letter and the multiplier eligibility test.

Operational risk losses and benchmarking stay on the current basis

For operational risk, institutions should keep reporting the existing loss templates, with the data limited to what the new granular operational risk taxonomy does not affect. In the current COREP instructions those templates are C 17.01 (losses and recoveries by business line and loss event type in the last year) and C 17.02 (operational risk: detailed information on the largest loss events in the last year). The operational risk-loss taxonomy has since been enacted in Commission Delegated Regulation (EU) 2026/1167, published on 3 September 2026 and in force since 23 September 2026 (the twentieth day after publication, under its Article 40). Under Article 23(1) and (2), institutions subject to the operational risk loss-data requirements must classify each relevant loss event into a single Level 1 event type and a single Level 2 category, and assign all applicable attributes. These loss-data recording requirements are distinct from the forthcoming revised COREP reporting templates.

The 6 November release does not provide a field-by-field mapping. However, paragraph 17 of the April 2026 EBA consultation’s operational-risk module (EBA/CP/2026/07, Module 3) expressly proposes retaining the current templates and reporting only the data points the new taxonomy does not affect, that is information on Level 1 event types, without the new Level 2 categories. The EBA has therefore identified the intended classification boundary, although the consultation is not itself a binding field-level instruction. The applicable EBA decision and competent-authority instructions must determine the final interim reporting treatment.

For credit risk and IFRS 9 benchmarking, institutions covered by the exercise should continue using the 2026 ITS on supervisory benchmarking reporting, which the EBA lists as in force with an application date of 1 September 2026. This cuts across an earlier signal: the EBA’s July 2026 consultation on the 2027 market risk benchmarking exercise (EBA/CP/2026/11) proposed removing the credit risk and IFRS 9 templates from Implementing Regulation (EU) 2016/2070 because those components were migrating into the supervisory reporting ITS. With supervisory benchmarking deferred to December 2028, the instruction keeps those two parts on the 2026 ITS.

Market risk benchmarking stays outside that migration, and under Regulation (EU) 2016/2070, because it relies on hypothetical instruments and portfolios that the supervisory reporting framework does not contain. The EBA has proposed moving the 2027 market risk exercise to the second half of 2027.

National data requests: what supervisors committed to

Members of the EBA Board of Supervisors have committed to reducing overlapping national and supervisory data requests where equivalent information is already collected through the EBA reporting framework. The commitment carries an explicit caveat that supervisors may need other data for their tasks, and the release names no national return to be withdrawn.

Three deliverables follow: guidelines on making and designing supervisory and resolution data requests by the end of 2026, an EU-wide public repository of those requests in Q1 2027, and further proposals on reporting change management in the first half of 2027. The refinements since the consultation drew on industry workshops and on the Reporting Contact Group of the Joint Bank Reporting Committee, covered in our article on the JBRC Reporting Contact Group call for members.

Re-planning a COREP and FINREP build around the new dates

The EBA’s 12 October 2026 release of the 4.4 phase 1 package said a second phase, expected in early 2027, would set out the technical implementation of the simplification package, and the November release keeps early 2027 for the data point model, taxonomies and validation rules. The phase 1 artefacts already published, including the optional IFRS 18 FINREP module with a 31 March 2027 first reference date, are a separate build, set out in our EBA reporting framework 4.4 final package guide. The October release called the second phase 4.4.1; the November release uses no version number. Which templates, frequencies and thresholds change, and where each deferred area’s boundary falls, is left to the final report.

Frequently Asked Questions

Does the December 2028 deferral cover every liquidity template, including LCR and NSFR?

The release defers “selected reporting areas, including liquidity, asset encumbrance, supervisory benchmarking and ESG reporting” without breaking liquidity down by template, and the word “including” leaves open whether other areas are also deferred. The December 2026 final report is the document that will set the template-level scope.

Our competent authority asked for notification of the IFRS 18 choice by the end of 2026. Does the postponement move that date?

The 6 November release does not change it. Paragraph 21 of the Opinion has competent authorities receiving notifications from institutions in their jurisdiction and informing the EBA of the option chosen by the end of 2026. The form and timing of the institution’s own notification is set by its authority.

Are the release 4.4 phase 1 Pillar 3 amendments postponed as well?

The release concerns the ITS on supervisory reporting and does not mention them. The EBA’s framework 4.4 page lists the Pillar 3 ITS amendments on ESG, shadow banking and equity exposures separately, with an expected first reference date of December 2026 and December 2027 for SNCIs.

Related Articles

• EBA Supervisory Reporting Simplification: What to Flag: the April 2026 consultation and its originally proposed September 2027 application.
• EBA Reporting Framework 4.4 Final Package: The Phase 1 Build List: the phase 1 DPM, taxonomy and validation rules with each first reference date.
• ECB IFRS 18 Reporting Option: The 2027 FINREP Profit and Loss Choice: the ECB’s October 2026 announcement on the IAS 1 or IFRS 18 choice.
• EBA FRTB No-Action Letter: The 31 March 2027 Multiplier Eligibility Test: the trading book boundary no-action letter and the Article 495v multiplier.

Sources and References

• EBA press release, 6 November 2026, next steps on reporting simplification and extended timelines: eba.europa.eu
• EBA press release, 10 April 2026, simplification consultation: eba.europa.eu
• EBA consultation page, EBA/CP/2026/07, modules and responses: eba.europa.eu
• EBA/CP/2026/07 Module 3, operational risk losses reporting: eba.europa.eu (PDF)
• Commission Implementing Regulation (EU) 2024/3117, Articles 2, 3 and 4, consolidated version of 29 December 2025: EUR-Lex
• Regulation (EU) No 1093/2010, Article 15, consolidated version of 31 December 2025: EUR-Lex
• EBA Opinion EBA/Op/2026/07, 8 July 2026, IFRS 18 FINREP interim period: eba.europa.eu (PDF)
• EBA consideration on the application of the FRTB from 1 January 2027: eba.europa.eu (PDF)
• Commission Delegated Regulation (EU) 2026/1221, market risk relief measures and multipliers: EUR-Lex
• Commission Delegated Regulation (EU) 2026/1167, operational risk requirements and loss-event taxonomy: EUR-Lex
• EBA amended operational risk reporting instructions, Annex II (C 16.01 to C 17.02): eba.europa.eu (ZIP)
• EBA press release, 17 December 2025, operational risk reporting guidance: eba.europa.eu
• Regulation (EU) No 575/2013 (CRR): EUR-Lex
• Regulation (EU) 2024/1623 (CRR3), Article 317 CRR on the loss data set: EUR-Lex
• EBA Opinion EBA/Op/2026/04, 22 April 2026, operational risk RTS: eba.europa.eu (PDF)
• Commission Implementing Regulation (EU) 2016/2070, as amended for the 2026 benchmarking exercise by Commission Implementing Regulation (EU) 2026/1872: EUR-Lex
• EBA, ITS package for benchmarking exercises: eba.europa.eu
• EBA Consultation Paper EBA/CP/2026/11, 17 July 2026, 2027 market risk benchmarking: eba.europa.eu (PDF)
• EBA reporting framework 4.4 page: eba.europa.eu
• EBA press release, 12 October 2026, final technical package for release 4.4: eba.europa.eu

Next milestone: the EBA’s December 2026 final report

The next document that changes a build plan is the EBA’s final report on the draft ITS, due in December 2026, followed by the technical package in early 2027. The artefact to produce now is a 2027 template inventory that marks the IFRS 18 option, the FRTB template guidance, the restricted operational risk loss data and the 2026 benchmarking ITS against every reference date before December 2027.

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.