IFRS 18 FINREP Reporting: The Interim Templates Banks Can File Early

ByOfficer

For annual reporting periods beginning on or after 1 January 2027, IFRS reporters must apply IFRS 18 unless they adopt it earlier. On the supervisory-reporting side, the affected population is the institutions inside FINREP’s IFRS scope under Article 430(3) or (4) of the Capital Requirements Regulation (CRR), not every bank that happens to use IFRS for some purpose. IFRS 18 rewrites the structure of the statement of profit or loss, and the version of that statement institutions send to their supervisor lives inside FINREP. On 8 July 2026 the European Banking Authority published an Opinion that tells competent authorities how to handle the months when the public accounts already follow IFRS 18 but the FINREP templates have not yet caught up.

The practical question for IFRS 18 FINREP reporting is narrow and awkward: what do you file for supervisory purposes between the day IFRS 18 first applies to your financial statements and the day the amended FINREP standards become mandatory? Those two dates differ, and a roadmap reference date is a different thing entirely from a legal application date. The public accounts move first, from the start of each entity’s first annual reporting period beginning on or after 1 January 2027. The amended ITS on FINREP are currently expected to apply from the end of September 2027, once the European Commission adopts the final draft the EBA plans to submit by the end of 2026. IFRS 18 is primarily a presentation and disclosure standard rather than a measurement one, but the mismatch is still real: for roughly nine months a bank’s published profit-or-loss structure and its binding FINREP template would not line up unless it uses the interim option.

The EBA’s answer is to advise competent authorities to let institutions close that gap early, on a voluntary basis, using a set of IFRS 18-aligned FINREP templates that already exist in draft. This article walks through what the Opinion permits, the dates that frame the transition, the technical package that makes early filing possible, and the checks a reporting team can start on now.

Related reading: FINREP Reporting Explained

The dates that define the transition

This is a deadline-driven change, and the calendar is the fastest way to see why the Opinion exists. The operative dates, drawn from the EBA press release, the Final Report, and the underlying instruments, are:

  • 13 February 2026: Commission Regulation (EU) 2026/338 endorses IFRS 18 in the European Union (published in the Official Journal on 16 February 2026).
  • 10 May 2026: the EBA public consultation on the FINREP templates and instructions most affected by IFRS 18 closed.
  • 8 July 2026: the EBA publishes the Opinion on the interim period, together with the Final Report (EBA/Rep/2026/18) on the draft amending ITS for FINREP.
  • 10 July 2026: the consultation on the remaining ITS amendments closes.
  • July 2026, or at the latest September 2026: the technical package for supervisory reporting version 4.4 (Phase 1) is planned for publication.
  • End of 2026: the EBA expects to submit the final draft amended ITS on FINREP to the European Commission.
  • 1 January 2027: IFRS 18 first applies to institutions’ financial statements, for annual reporting periods beginning on or after that date, unless an institution adopts it earlier.
  • End of September 2027: the amended ITS on FINREP are currently expected to become mandatory, closing the interim window.

Read that list top to bottom and the shape of the problem is clear. Endorsement and the accounting go-live sit at the front. The supervisory template change sits at the back. The Opinion is the bridge between them.

Why IFRS 18 reaches FINREP reporting at all

FINREP is the supervisory financial reporting framework that banks submit to their competent authorities. It is implemented through Commission Implementing Regulation (EU) 2024/3117 of 29 November 2024, which applies from 28 June 2025; Commission Implementing Regulation (EU) 2021/451, the previous reporting ITS, was repealed with effect from 31 December 2025. The EBA develops those uniform reporting formats and the accompanying IT solutions under the mandate in Article 430(7) of the Capital Requirements Regulation.

Because FINREP reports financial information, it tracks the accounting rules underneath it. The statement of profit or loss that a bank presents in its published accounts feeds the profit-or-loss template in FINREP, known as F 02.00. When the accounting standard behind that statement changes, the FINREP template has to change with it, or supervisors end up comparing figures built on two different presentation bases. IFRS 18 was endorsed for EU use through Commission Regulation (EU) 2026/338 of 13 February 2026 and replaces IAS 1, so the profit-or-loss structure that F 02.00 mirrors is being rebuilt. That is the whole reason the EBA has drafted amending ITS for FINREP in the first place.

A common misreading here is to treat FINREP as a fixed form that only the EBA touches on its own schedule. The template moves whenever the accounting it reflects moves, and IFRS 18 is one of the larger such moves in a decade. The link runs from the standard, to the amended ITS, to the DPM and taxonomy, to the file a reporting team eventually submits.

What the EBA Opinion actually permits

The Opinion is guidance addressed to competent authorities, issued under Article 29(1)(a) of Regulation (EU) No 1093/2010, the EBA’s founding regulation. It advises those authorities to allow institutions to use a set of IFRS 18-aligned FINREP templates on a voluntary basis during the interim period. Those templates have been developed as part of the draft amended ITS on FINREP and reflect the feedback received during the consultation that closed on 10 May 2026.

Two words in that sentence carry most of the weight: voluntary, and allow. The Opinion sets out a permission that a supervisor can extend to institutions that want to file the new-format templates ahead of their mandatory application. It creates no new reporting obligation and leaves the FINREP switch date where it is. An institution that prefers to keep filing the existing FINREP profit-or-loss format through the interim period stays fully compliant, and the mandatory change still arrives with the amended ITS.

This is the point most likely to be garbled in an internal summary. An Opinion that “allows early use of IFRS 18 FINREP templates” can be read, wrongly, as an instruction to adopt them from January 2027. The modality matters for how a reporting team plans its build. Treat the interim templates as an option that needs your competent authority to open the door, and that you then choose to walk through, rather than a hard requirement landing on a fixed date.

Who decides whether the door opens depends on who supervises you. For significant institutions under the Single Supervisory Mechanism, the competent authority is the European Central Bank. For less significant institutions, it is the national competent authority, such as the CSSF in Luxembourg or BaFin in Germany. The EBA’s advice is directed at all of them, but the operational green light for early filing is a supervisory decision at your level, not an automatic EU-wide switch.

The gap the Opinion is closing

Strip away the template numbers and the transition is a timing mismatch. For an institution whose annual reporting period begins on 1 January 2027, the financial statements for that period present profit or loss under IFRS 18; institutions with a different financial-year start date move when their first annual period beginning on or after 1 January 2027 starts. Until the amended ITS apply, the binding FINREP profit-or-loss template still reflects the IAS 1 presentation. Without an accepted interim option, an institution in that window may need to maintain a mapping from its IFRS 18 financial-statement presentation to the legally applicable FINREP template for each affected reference date, and the required submission and reconciliation process should be confirmed with the competent authority.

That mapping burden is exactly the operational friction the EBA set out to avoid. Maintaining a parallel mapping between the IFRS 18 presentation and the legacy FINREP structure means extra validation passes and more chances for the market number and the supervisory number to drift apart on a line where they should agree. Accepting IFRS 18-aligned interim templates may reduce that parallel mapping work, but it does not eliminate all differences between published financial statements and FINREP, and any simplification claim should be tied to the EBA Opinion’s own wording rather than assumed.

For reporting teams that have lived through a FINREP taxonomy change, the appeal is obvious. The pain of a transition is rarely the new template itself. It is the period where old and new run side by side and every discrepancy has to be explained. The Opinion shrinks that period for any institution whose supervisor lets it opt in.

The version 4.4 technical package is the real enabler

Permission alone does not let anyone file anything. A FINREP submission needs a Data Point Model, validation rules, and an XBRL taxonomy that the supervisor’s collection system will accept. The revised FINREP templates reflecting IFRS 18 are being packaged into the technical package for supervisory reporting version 4.4, described by the EBA as Phase 1; the EBA’s own Final Report labels the reshaped F 02.00 template itself “final draft version 4.4”. That package sets out the DPM, validation rules, and XBRL taxonomy required for institutions that choose to submit information using the new templates. The EBA plans to publish the final version in July 2026, or at the latest by September 2026.

The two-phase structure is worth pinning down. Phase 1 delivers the machinery for voluntary early submission during the interim period. Phase 2 follows once the amended ITS are adopted and enter into force, at which point the templates are integrated into version 4.4 as the mandatory framework.

The EBA’s reporting-framework roadmap currently lists a first reference date of March 2027 for the FINREP IFRS 18 module under framework 4.4 Phase 1, the earliest reference date an early-adopting institution could realistically target. If the DPM and taxonomy are not in your reporting tool, the competent authority’s permission is academic.

Teams sometimes park technical-package publications as a back-office concern for the reporting software vendor. For a voluntary early adoption, the package timing is a governance question. It determines whether you can realistically be ready to file IFRS 18-aligned FINREP for a Q1 or half-year 2027 reference date, and it feeds directly into the same EBA validation rules for supervisory reporting that will reject a package built against the wrong taxonomy version.

What changes inside the profit-or-loss statement

IFRS 18 replaces IAS 1 and primarily changes presentation and disclosure; recognition and measurement requirements for specific transactions remain in the other applicable IFRS Accounting Standards. Income and expenses are classified into five categories: operating, investing, financing, income taxes and discontinued operations, three of which (operating, investing and financing) are new. The standard introduces two required subtotals that were not mandated before: operating profit or loss, and profit or loss before financing and income taxes, though the latter is not presented if an institution classifies income and expenses from all financing liabilities in the operating category (IFRS 18.73), an accounting-policy choice particularly relevant to entities such as banks that provide financing to customers as a main business activity. It also brings management-defined performance measures into the audited financial statements, disclosed in a single note with a required reconciliation to the most directly comparable IFRS subtotal.

For banks specifically, IFRS 18 carries dedicated classification guidance for entities whose main business activity is investing in assets or providing financing to customers. That guidance shapes where items such as interest and dividend income sit in the new categories, and it is the reason a bank’s income statement does not simply re-label its existing lines. The FINREP F 02.00 template picks up the operating categories and the operating profit or loss subtotal, but not both new IFRS 18 subtotals unchanged: the Final Report disables the IFRS 18.73 accounting-policy choice for FINREP purposes across the board, so every reporter classifies financing-liability items in the operating category and F 02.00 never carries the profit or loss before financing and income taxes line. In its place, F 02.00 adds a FINREP-specific operating and investing profit or loss subtotal that has no direct IFRS 18 equivalent. Reporting teams mapping the template should expect that substitution rather than a like-for-like copy of the two IFRS 18 subtotals.

The honest framing for a reporting team is that this is a mapping project first and a measurement project barely at all. The same underlying figures land in a restructured layout with new subtotals and new category boundaries. The exposure sits in the mapping itself: a line ends up in the wrong category, or a management-defined measure is disclosed inconsistently between the accounts and the return.

Where this sits in the reporting-framework roadmap

It is easy to file the IFRS 18 FINREP work under the wrong release. The EBA’s framework 4.3 package covers third-country branch reporting and AMLA risk-assessment data collection, and it does not change the COREP or FINREP profit-or-loss content. The IFRS 18 FINREP amendments sit in framework 4.4 Phase 1, alongside the resolution-planning, AMLA-eligibility and Pillar 3 disclosure changes the EBA has grouped for the same December 2026 to March 2027 reference-date window; the CRR3/CRD6 Step 2 reporting enhancements are a separate, later Phase 2 tranche expected from September 2027. Getting the version right matters because your reporting tool loads a specific taxonomy per framework release, and a control that references “the 4.3 FINREP change” will send people looking in the wrong package.

If you are mapping the moving parts across releases, our note on the EBA 4.3 DPM changes for COREP and FINREP sets out what actually sits in that earlier package, and the broader EBA supervisory reporting simplification work explains the direction the IFRS 18 Opinion is pulling in. The through-line across all of them is the EBA working to cut parallel-format burden across the reporting cycle.

Management-defined performance measures and the ESMA overlap

One under-discussed consequence of IFRS 18 is that certain management-defined performance measures move inside the audited financial statements, with a required note reconciling each of them to the most directly comparable IFRS subtotal. Banks have long disclosed alternative performance measures in their results presentations and management reports, where the ESMA Guidelines on Alternative Performance Measures apply. IFRS 18 changes where some of those measures live and how they must be reconciled, so the boundary between an APM governed by ESMA’s guidelines and an MPM governed by IFRS 18 is one a bank’s finance and reporting functions should map deliberately.

This is more an accounting-policy and disclosure question than a FINREP field-mapping one, and the detail sits with the auditors and the group accounting team. From the supervisory reporting angle, do not assume that a management-defined performance measure is a FINREP data point. IFRS 18 requires qualifying measures to be disclosed in a single note and reconciled to the most directly comparable IFRS subtotal; any FINREP treatment must be confirmed from the final amended templates and instructions. The interaction is set out further in our guide to the ESMA APM Guidelines and IFRS 18, and it is worth reading early, before the first IFRS 18 reporting cycle begins.

What reporting teams can do in the second half of 2026

The Opinion gives reporting teams a concrete decision to prepare for rather than a filing to make today. A sensible sequence through the rest of 2026 looks like this. First, establish your competent authority’s stance: the EBA advises supervisors to allow the interim templates, but whether and how your supervisor operationalises that is the gating fact for any early-filing plan. Second, track the version 4.4 Phase 1 technical package and put its July-to-September 2026 publication on the reporting change calendar, because the DPM, validation rules, and taxonomy are what make early submission possible. Third, start the F 02.00 mapping now, working from the draft templates in the Final Report, so that the category and subtotal changes are understood before the taxonomy lands.

I have seen reporting teams underestimate how much of a FINREP transition is a mapping exercise on the profit-or-loss template, F 02.00, where a single line moving between categories cascades into validation breaks downstream. Doing that mapping against the draft templates during 2026, while the numbers are still hypothetical, is far cheaper than discovering the breaks against a live Q1 2027 reference date. Fourth, keep the group accounting and disclosure teams in the loop on management-defined performance measures, since the FINREP figures need to stay consistent with the restructured accounts.

The remaining FINREP amendments are still subject to finalisation and Commission adoption; reporting teams should track the final draft ITS and final technical package rather than treating consultation text, which closed on 10 July 2026, as fixed. What is still live for reporting teams is the operational readiness work: the supervisor’s decision, the package timing, and the internal mapping. None of that requires waiting for the mandatory 2027 date to begin.

Frequently Asked Questions

Does the EBA Opinion make IFRS 18 FINREP reporting mandatory from January 2027?

No. The Opinion advises competent authorities to allow institutions to use the IFRS 18-aligned FINREP templates on a voluntary basis during the interim period. The mandatory switch arrives only when the amended ITS on FINREP apply, currently expected around the end of September 2027. An institution can keep filing the existing FINREP profit-or-loss format through the interim window and remain compliant.

Which FINREP template is most affected by IFRS 18?

The statement of profit or loss template, F 02.00, is the one redrawn to carry the new IFRS 18 categories, along with the related instructions, though it does not pick up both new IFRS 18 subtotals unchanged: FINREP adds the operating profit or loss subtotal but replaces the profit or loss before financing and income taxes subtotal with its own operating and investing profit or loss line. IFRS 18 changes the structure of the income statement, so the FINREP template that mirrors it has to be rebuilt. The templates and instructions are published as separate annex files accompanying the Opinion, labelled Annex III and Annex IV for the templates and Annex V for the instructions, rather than as annexes to the Final Report itself.

What is the interim period, exactly?

It is the span between the first application of IFRS 18 to a bank’s financial statements, for accounting periods beginning on or after 1 January 2027, and the first application of the amending FINREP ITS, currently expected around the end of September 2027. During this window the audited accounts already use IFRS 18 while the binding FINREP template still reflects the IAS 1 presentation, which is the mismatch the Opinion addresses.

Do we need the version 4.4 technical package to file the new templates?

Yes. Voluntary early submission depends on the Data Point Model, validation rules, and XBRL taxonomy in the version 4.4 (Phase 1) technical package, which the EBA plans to publish in July 2026 or at the latest by September 2026. Without that package loaded in your reporting system, the competent authority’s permission to file early cannot be acted on in practice.

Is this part of EBA framework 4.3 or 4.4?

Framework 4.4. Framework 4.3 covers third-country branch reporting and AMLA risk-assessment data collection and does not change the COREP or FINREP profit-or-loss content. The IFRS 18 FINREP amendments are sequenced into version 4.4 Phase 1, so any internal control or documentation should point to the 4.4 release, where the change actually sits.

Does IFRS 18 change how banks measure profit?

IFRS 18 replaces IAS 1, but its changes are to presentation and disclosure rather than measurement; recognition and measurement requirements for specific transactions remain in the other applicable IFRS Accounting Standards. Income and expenses are classified into five categories, operating, investing, financing, income taxes and discontinued operations, three of which are new, with required subtotals, and certain management-defined performance measures move into the audited statements. The underlying figures are calculated much as before, which is why the FINREP work is best treated as a mapping and structure exercise on F 02.00.

What is the legal basis for the Opinion?

The Opinion is issued under Article 29(1)(a) of Regulation (EU) No 1093/2010, which expressly includes providing opinions to competent authorities as part of the EBA’s common-supervisory-culture mandate. The FINREP framework it relates to is implemented through Commission Implementing Regulation (EU) 2024/3117 under the mandate in Article 430(7) of the Capital Requirements Regulation.

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Key Takeaways

  • The EBA published an Opinion on 8 July 2026 letting institutions voluntarily file IFRS 18-aligned FINREP templates during the interim period, subject to their competent authority allowing it.
  • IFRS 18 applies to financial statements from 1 January 2027 unless adopted earlier, while the amended FINREP ITS are currently expected to become mandatory around the end of September 2027, creating a roughly nine-month gap.
  • The Opinion is voluntary guidance to supervisors and does not switch FINREP to IFRS 18 early or add a new obligation.
  • Early filing depends on the version 4.4 (Phase 1) technical package, with its DPM, validation rules, and XBRL taxonomy, planned for July 2026 or at the latest September 2026.
  • The profit-or-loss template F 02.00 is redrawn for the new IFRS 18 categories and picks up one of the two new IFRS 18 subtotals, substituting a FINREP-only subtotal for the other; the change is largely presentation and mapping rather than measurement.
  • The IFRS 18 FINREP amendments belong to framework 4.4 Phase 1, not framework 4.3, which covers third-country branch reporting and AMLA risk-assessment data collection.
  • IFRS 18 was endorsed in the EU by Commission Regulation (EU) 2026/338, and FINREP is implemented through Commission Implementing Regulation (EU) 2024/3117.

Sources and References

  • EBA press release, “The EBA issues Opinion on the implementation of IFRS 18 in supervisory financial reporting to support consistency with IFRS requirements”, 8 July 2026: eba.europa.eu (links to the Opinion, the Final Report on the draft ITS, and the FINREP templates and instructions in the accompanying Annex III, IV and V files).
  • EBA, Final Report, “Draft Implementing Technical Standards on the implementation of IFRS 18 in supervisory financial reporting (FINREP) under Article 430(7) of Regulation (EU) No 575/2013” (EBA/Rep/2026/18), 8 July 2026: eba.europa.eu (PDF).
  • Commission Regulation (EU) 2026/338 of 13 February 2026 endorsing IFRS 18 in the EU: EUR-Lex.
  • Commission Implementing Regulation (EU) 2024/3117 of 29 November 2024 on supervisory reporting of institutions (the ITS being amended for FINREP): EUR-Lex.
  • Regulation (EU) No 1093/2010 establishing the European Banking Authority (Article 29 on common supervisory culture, the legal basis for the Opinion): EUR-Lex.
  • EBA consultation module on FINREP (part of the revised ITS on supervisory reporting): eba.europa.eu.
  • EBA reporting framework 4.4 roadmap page, listing the FINREP IFRS 18 module’s expected first reference date under Phase 1: eba.europa.eu.
  • EBA reporting framework 4.3 roadmap page, listing the third-country-branch and AMLA risk-assessment modules: eba.europa.eu.

Getting ahead of the September 2027 switch

The IFRS 18 FINREP change is one of the rare reporting transitions where the EBA has handed institutions a way to make their own lives easier, provided they act on it. The Opinion works in the banks’ favour: it offers a route around the parallel-mapping burden for anyone whose supervisor opens the door. The teams that benefit will be the ones that used the second half of 2026 to settle their competent authority’s position, load the version 4.4 Phase 1 package as soon as it publishes, and map F 02.00 against the draft templates while the stakes were still low. The mandatory date arrives in 2027 whatever a bank does. The preparation window is now.

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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