KFI Reporting in Denmark: Branch Accounts Due in 15 Working Days
KFI reporting is how a branch of a foreign bank in Denmark sends Finanstilsynet its own quarterly accounts: income statement, balance sheet, lending by sector and industry, and a half-yearly credit-quality split. Finanstilsynet titles the return “regnskabsoplysninger for filialer af udenlandske pengeinstitutter” (accounting information for branches of foreign banks), and its August 2026 deadline list gives it 15 working days after each quarter-end. That is a shorter window than any fixed-date quarterly return listed for the same branches.
The file set in force applies from the period Finanstilsynet labels 202543. Its guidance is dated 11 September 2025, and it removed two tabs that branches had filed every quarter until then: the 20 largest exposures (Kre) and the 10 largest debt and guarantee obligations (GG). What remains is eight tabs, a published control overview, and an XML file submitted through FIONA Online, the reporting system Finanstilsynet shares with Danmarks Nationalbank.
Related reading: KGFS Reporting in Denmark: New Home Loans to High-Debt Borrowers
Filing summary
| Item | Rule and source |
|---|---|
| Reporting population | Branches of foreign credit institutions in Denmark (guidance, Indledning); the KFI page names the filers as “udenlandske pengeinstitutter”. No size threshold or exemption appears in any KFI document. The KbSb tab is marked “Indberettes kun af pengeinstitutter” (banks only). Detail in the scope section below. Sources: KFI page; KFI guidance, 11 September 2025. |
| Receiving authority | Finanstilsynet, through FIONA Online, the system it runs jointly with Danmarks Nationalbank. Source: KFI page. |
| Frequency and reference period | Quarterly. Seven tabs are marked K (quarterly); KbSb is marked H and is reported with the half-year and year-end submissions. The guidance also says one NoBs specification is reported annually only. Source: guidance, tab table and NoBs and KbSb notes. |
| Deadline rule | 15 working days after quarter-end. The KFI entry carries no longer fourth-quarter period. Source: Finanstilsynet deadline list, August 2026. |
| Submission channel and format | FIONA Online: direct entry, paste from Excel, or a file in the format defined for the report. Finanstilsynet publishes an XSD and an XML example for the 202543 file set. The KFI page and guidance state no file-naming rule. Sources: Hvad er FIONA Online?; KFI page. |
| Governing version, application and finality | Final and current: the file set “gældende fra perioden 202543 og frem”, guidance dated 11 September 2025, control list “Gældende fra 202543”. The 202541 to 202542, 202042 and 201803 sets, and the set used up to period 201712, remain on the page as superseded versions. Source: KFI page, last updated 15 September 2025. |
Legal basis for KFI: Finanstilsynet guidance and the enabling provision no KFI document names
KFI is a national return outside the EBA reporting framework, and no EU regulation prescribes its templates. Finanstilsynet issues the guidance (“Vejledning til regnskabsindberetning for KFI (filialer af udenlandske kreditinstitutter)”), the template workbook, the control list and the XML schema, and the return is collected through FIONA Online.
The KFI guidance contains cross-references to two historical Danish instruments. Its accounting instructions cite provisions of executive order no. 281 of 26 March 2014 on financial reports, while NoRe and MFD cite chapter 3 of executive order no. 1202 of 15 November 2017 on third-party payments. Both instruments have since been superseded. The current accounting order is BEK no. 658 of 23 May 2025, as amended, including by BEK no. 345 of 25 February 2026, and the current third-party-payments order is BEK no. 679 of 24 July 2026, effective from 4 August 2026. The section references reproduced in the KFI guidance therefore describe the KFI instructions’ historical cross-references and should not be treated as citations to the current Danish legislation.
Neither the KFI page nor the guidance names the statutory provision that obliges a branch to file. The closest general rule identified is § 198(1) of the Financial Business Act (lov om finansiel virksomhed, consolidated as LBK no. 432 of 16 April 2026): “finansielle virksomheder og finansielle holdingvirksomheder” must make regular accounting reports to Finanstilsynet on forms and guidance Finanstilsynet prepares, submitted electronically. That provision addresses financial undertakings and financial holding undertakings. For branches of credit institutions that hold an authorisation corresponding to a Danish bank licence in a country outside the EU with which the Union has no agreement on the financial area, executive order no. 1616 of 13 November 2020 supplies the link: its § 13(4) requires the branch to make accounting reports to Finanstilsynet on the forms and guidance Finanstilsynet sets under § 198, and its § 15 lets Finanstilsynet grant exemptions from that duty. From 1 January 2027, executive order no. 1009 of 2 July 2025 replaces that order and carries the same duty in § 15(4), with the exemption power in § 17.
For branches of institutions authorised in another EU Member State or in a country with such an agreement, § 1(4) of the Act applies a listed set of provisions that includes § 347(1) and leaves out § 198. The second sentence of § 347(1) extends the duty to give Finanstilsynet the information it needs for its supervision to foreign credit institutions operating in Denmark through a branch, in accordance with directive provisions. No KFI document cites any of these provisions.
At EU level, host-state reporting by branches of credit institutions authorised in other Member States rests on Article 40 of the Capital Requirements Directive (Directive 2013/36/EU). Branches of third-country institutions fall under the CRD VI regime covered in the changes section. Article 40 lets host authorities require credit institutions with branches in their territory to report periodically on their activities there, for information or statistical purposes, for assessing whether a branch is significant under Article 51(1), or for supervisory purposes under that chapter. Article 40 is a permission. KFI’s content, frequency and format come entirely from Finanstilsynet’s documents.
The KRGS connection explains much of the drafting. The Res and Bal instructions in the KFI guidance repeat, almost word for word, the Res and Bal instructions in Finanstilsynet’s guidance for KRGS, the solo accounting return filed by Danish banks, mortgage banks, investment firms, certain investment management companies and financial holding companies. A branch does not file KRGS. The KRGS guidance lists the five entity types it applies to, and branches of foreign institutions are not among them.
Who must report KFI: branches of foreign credit institutions, with a banks-only tab
The scope sentence in the guidance is short: it applies to branches of foreign credit institutions in Denmark (“filialer af udenlandske kreditinstitutter i Danmark”). Finanstilsynet’s index of FIONA returns lists KFI under the heading “Filial af udenlandsk kreditinstitut”, together with KGFS, KSERV and KSIFI.
Three points decide the filing answer for a particular branch.
- Banks versus other credit institutions. The guidance says “kreditinstitutter”. The KFI page title and its “Indsendes af” line say “pengeinstitutter” (banks). The KbSb template adds “Indberettes kun af pengeinstitutter”, which only does work if some KFI filers are not banks. None of the KFI documents reconciles the wording, so a branch of a foreign mortgage credit institution has an open scope question to put to Finanstilsynet.
- EU/EEA head office or third-country head office. No KFI document distinguishes between them. Both are “filialer af udenlandske kreditinstitutter” on the guidance’s wording.
- One branch or several places of business. For a credit institution with its head office in another Member State, Article 38 CRD treats any number of places of business in the same Member State as a single branch. On that rule, several Danish offices of an EU bank produce one KFI file.
No size threshold, de minimis exemption or waiver appears in the KFI page, the guidance, the template or the control list. For third-country branches, the executive order covered in the legal basis section lets Finanstilsynet grant exemptions from the accounting-reporting duty. The return also has no consolidation level to choose: the guidance contains no consolidation section, and every tab describes the branch itself. That differs from KRGS and KRGC, where the KRGS guidance sets consolidation rules by reference to chapter 12 of the Financial Business Act.
The August 2026 deadline list places five national FIONA returns under the branch heading: AMLCTF (quarterly), KFI, KGFS (quarterly), KSERV (half-yearly) and KSIFI (annual). The same heading lists three EBA modules sent through the separate e-Reg system: FINREP9 (formerly KFRC, quarterly, first e-Reg reference date 31 March 2026), COREPOF limited to templates C 00.01 and C 15.00 (annual, first reference date 31 December 2026) and PSDFRP (half-yearly). The list does not say which branch types each EBA module applies to. Our KSERV guide to the twice-yearly NPL transfer return covers one of the other FIONA returns on that list.
What the KFI report contains: eight tabs
The 202543 guidance lists eight tabs. For reporting units and field-level specifications, use the current 202543 template workbook and XML schema published by Finanstilsynet.
| Tab | Content | Frequency |
|---|---|---|
| Res | Income statement and statement of comprehensive income | Quarterly |
| Bal | Balance sheet | Quarterly |
| NoEf | Contingent liabilities and other commitments | Quarterly |
| NoBs | Balance-sheet note on sale-and-repurchase and purchase-and-resale transactions | Quarterly (one specification annual only) |
| UnSb | Loans, guarantee debtors, impairments and losses by sector and industry | Quarterly |
| KbSb | Credit quality by sector and industry (banks only) | Half-yearly |
| NoRe | Income note: MiFID II third-party payments within fees and commissions | Quarterly |
| MFD | MiFID II third-party payments received by distributors, per counterparty | Quarterly |
Source: KFI guidance, 11 September 2025, tab table; KFI 202543 template.
Res and Bal
Res runs from interest income (Rind) to the result for the period (ReS) across 14 numbered lines and four subtotals, followed by a comprehensive-income block (TiPR, TiX, TiTot). Two instructions carry most of the classification risk. Line 13, “Resultat af aktiviteter under afvikling”, takes the result of assets held temporarily and of discontinued activities that form a separate part of the branch. The guidance sends value adjustments on temporarily acquired assets under the guidance’s cross-reference to § 34 of the historical 2014 accounting order to line 11 (“Nedskrivninger på udlån m.v.”) and keeps them out of line 13.
The guidance does not say whether Res amounts run quarter-only or year-to-date. NoRe is the only tab whose columns separate “Beløb for kvartalet” from “Beløb år til dato”.
Bal has 19 asset lines and a liability side split into debt (lines 1 to 9), provisions (10 to 14), subordinated capital (15) and equity (16 to 20). Land and buildings (AgbTot) break into investment property (Aie), domicile property (Ade) and leased domicile property (AdeL). The guidance requires leased domicile property at cost, without the revaluation that applies to owned domicile property, citing a cross-reference to § 65(2) of the historical 2014 accounting order. The equity section carries five more items than the bilag 3 format of that order. The guidance names separate lines for accumulated currency translation of foreign units, accumulated value adjustments on cash-flow hedges and accumulated revaluation of held-to-maturity assets to fair value, and sends other equity adjustments under its cross-reference to § 79 of the historical 2014 accounting order to “Øvrige værdireguleringer”.
NoEf and NoBs
NoEf splits guarantees into financial guarantees, loss guarantees for mortgage loans, registration and conversion guarantees and other contingent liabilities, then reports irrevocable credit commitments. A provision on an unused credit line is expensed like a provision on a guarantee, under “Nedskrivninger på udlån m.v.”, but the liability side differs: it sits in “Andre hensatte forpligtelser”, while guarantee provisions sit in “Hensættelser til tab på garantier”.
NoBs shows how much of asset lines 4 and 5 (loans at fair value and at amortised cost) are reverse repos, and how much of liability line 2 (deposits and other debt) are repos. The tab table marks NoBs quarterly, but the text states that the specification of assets sold under genuine sale-and-repurchase transactions is reported annually only.
UnSb: lending by sector and DB25 industry
UnSb splits loans and guarantee debtors across public authorities, ten industry groups and private customers. Its four columns are the period-end stock of loans plus guarantee debtors plus impairments and provisions, the impairments and provisions expensed in the period, accumulated impairments and provisions at period-end, and amounts finally lost (written off) in the period.
The industry split follows the branch code registered on the exposure. Where an exposure carries several codes, the branch picks the most significant one by working out how much of the exposure falls under each code, and the guidance says the chosen code must match every other report the branch makes to Finanstilsynet. Industry grouping follows Danmarks Statistik’s DB25 standard, which took effect on 1 January 2025, and Bilag 3 maps each of the ten groups to DB25 and NACE code ranges. Where the branch’s own classification of impairments does not fit Finanstilsynet’s industry grouping, the guidance asks for its best estimate.
One mapping detail catches automated feeds. The same industry rows carry different group codes on the two sector tabs: construction is BAg on UnSb and BA on KbSb, and other industries are ErhOvr on UnSb and Ovr on KbSb. A single lookup table keyed on UnSb codes will mislabel KbSb rows.
KbSb: four credit-quality categories
KbSb distributes the branch’s total exposures by sector and industry across four credit-quality categories. The guidance uses grades 3, 2a, 2b, 2c and 1, and reports 3 and 2a together.
| Column | Grade | Meaning in the guidance |
|---|---|---|
| NoB | 2a/3 | Normal or undoubtedly good credit quality |
| FbSv | 2b | Does not meet 2a, but no significant signs of weakness |
| VSv | 2c | Significant signs of weakness, no indication of credit impairment |
| OIV | 1 | Objective indication of credit impairment (OIK) |
The exposure measure is loans plus guarantee debtors plus unused credit facilities, before impairments and provisions, with no deduction for collateral. Grade 1 applies whenever there is an indication of credit impairment, whether the exposure sits in stage 1, 2 or 3. The guidance adds that where an exposure is marked by thin information or a complex, opaque corporate structure, the branch must consider a lower grade, and it allows parts of an exposure to carry different grades when only that part is weak and cannot bring the whole exposure into difficulty.
Classification follows credit quality, whatever the unsecured share. The guidance gives its own example:
| Loan | Gross exposure | Unsecured share | Grade reported |
|---|---|---|---|
| 1 | 100 | 10 | 2c |
| 2 | 100 | 50 | 2c |
Both loans are reported at 100 in category 2c despite the different loss risk (guidance, KbSb section).
NoRe and MFD: MiFID II third-party payments
NoRe reports, within fees and commissions, the distribution, marketing and brokerage commissions received and retained under MiFID II, for the quarter and year to date. MFD breaks the same commissions down in repeating rows, one per counterparty, for example at UCITS sub-fund or share-class level. Each row identifies the counterparty by ISIN where it has one, otherwise by LEI or CVR number. The MFD amount covers the year to date and is measured on a cash-flow basis.
KFI reporting deadlines and reference dates: 15 working days after every quarter-end
KFI reference dates are the four calendar quarter-ends. Finanstilsynet’s deadline list describes KFI as “Kvartalsindberetning” with the deadline “15 arbejdsdage efter kvartals udløb”, 15 working days after the end of the quarter. Each quarter is therefore due three working weeks after its last day.
- Reference dates: 31 March, 30 June, 30 September and 31 December.
- Deadline: 15 working days after each reference date.
- KbSb: included with the half-year (30 June) and year-end (31 December) submissions.
- Current file set: applies from period 202543 onwards.
Two contrasts on the same list matter for planning. Other returns under the branch heading (AMLCTF, KGFS and the e-Reg FINREP9 module) use the fixed quarterly dates of 11 February, 12 May, 11 August and 11 November, so KFI for a quarter falls due well before them. And several returns elsewhere on the list, such as KSOS for banks, run on 20 working days with 30 for the fourth quarter. The KFI entry has no such extension, so the year-end file runs on the same 15 working days as the other three quarters.
Finanstilsynet labels periods with a six-digit code and does not decode it on the KFI page. The same list refers to an ESG period “202522” filed in FIONA ahead of that return’s first e-Reg reference date of 30 June 2026, which fits a reading of year, frequency digit and period number. On that reading, 202543 is the quarter ending 30 September 2025, which matches a guidance document dated 11 September 2025. The deadline list does not define “arbejdsdage” further, so the date for any quarter depends on the Danish holiday calendar that year.
Submission of KFI: FIONA Online and the 202543 XML file set
KFI goes to Finanstilsynet through FIONA Online, which Finanstilsynet describes as Danmarks Nationalbank’s and Finanstilsynet’s shared web-based reporting system. A filer can enter data directly, copy it from an Excel sheet or upload a reporting file in the format defined for each report type. Access requires a user created for each company the person reports for and a Microsoft Azure AD licence; after the invitation, the user sets up sign-in with the Microsoft Authenticator app or an SMS code.
For the file route, Finanstilsynet publishes an XSD and an XML example alongside the 202543 template. KFI is a national XML return defined by its own schema; the XBRL filing rules the FIONA help page points to are the EBA’s and EIOPA’s, for taxonomy-based returns. The KFI documents publish no file-naming convention. Our KOFS guide to Danish own funds returns covers the EBA returns that left FIONA for e-Reg.
Corrections follow one sentence in the guidance: where the branch changes reported material, it reports the changes to Finanstilsynet via FIONA Online as soon as possible (“snarest muligt”). FIONA also shows error lists for submitted reports. Technical questions go to the FIONA service desk at Danmarks Nationalbank (fiona@nationalbanken.dk).
One labelling slip on the KFI page is worth knowing before downloading. The 202543 block labels the two guidance links “(xlxs)”, but both files are PDFs. The template links in the same block carry the same label and are Excel workbooks.
Official filing resources
| Resource | Version and status |
|---|---|
| KFI reporting page | Holds all file sets; last updated 15 September 2025 |
| KFI guidance (without tracked changes) | Dated 11 September 2025; applies from 202543 |
| KFI template workbook | 202543 version; eight tabs |
| KFI control list (kontroloversigt) | Control overview for the 202543 file set; check the workbook directly before automating |
| KFI XSD | 202543 version |
| KFI XML example | 202543 version |
| Deadline list (indberetningsfrister) | August 2026 edition; KFI entry at 15 working days |
| FIONA Online access and help | Submission methods and sign-in |
| KFI guidance no. 1 of 17 December 2024 | Superseded; governed periods 202541 to 202542 |
Validation of KFI: the 202543 control list
Finanstilsynet publishes a control overview for the 202543 KFI file set. The detailed control identifiers, formulas and statuses should be checked directly against the current KFI_fejl_202543.xlsx workbook before they are implemented in an automated validation process.
Danmarks Nationalbank’s own reporting guidance for its payment statistics, also collected through FIONA, describes format controls on receipt, objective controls with a tolerance (bagatelgrænse) so that rounding does not trigger errors, and analytical controls reviewed by staff. That description belongs to Nationalbanken’s statistics. Nothing in the KFI guidance carries Nationalbanken’s tolerance rule over to Finanstilsynet’s KFI checks.
Caveats for KFI filers: overlaps, rating scales and leftover structure
No proportionality regime, waiver, national discretion or transitional provision appears in the KFI documents. Five interactions and gaps remain for filers.
The first is the KRGS lineage. Because the KFI Res and Bal text copies the KRGS guidance, a branch can read the KRGS guidance for context on shared line items. It cannot borrow KRGS frequencies, tabs or deadlines. KRGS has its own frequency table by entity type and many tabs KFI does not have, and KFI’s 15-working-day rule appears nowhere in KRGS.
The second is what the guidance leaves unsaid. It sets no sign convention, no rounding rule and no basis for translating amounts booked in other currencies. A branch that keeps its books in its head office’s currency has to fix those conventions itself and apply them the same way every quarter.
The third is credit grading. Bilag 2 of the guidance sets detailed criteria for grading private, corporate and investment customers, with corporate examples tied to solvency bands, and states that it is not to be read as guidance for drafting a bank’s credit policy. A branch whose head office grades on its own scale has to translate that scale into the five grades and four columns of KbSb.
The fourth is leftover structure from the removed tabs. The 202543 guidance keeps Bilag 1, a list of country codes that served the Kre tab, and its table of contents still reads “Bilag 1. Landekoder på Kre”. None of the instructions for the eight remaining tabs refers to it.
The last concerns older quarters. The KFI page keeps the earlier file sets, but none of the documents says which file set a correction to a pre-202543 quarter should use. Our article on CRD6 third-country branch authorisation and the 11 January 2027 deadline covers the separate authorisation track that third-country branches face under CRD VI.
Changes to KFI: the 202543 tab cut and the CRD VI branch regime
The KFI page shows five generations of file sets. Comparing the three most recent guidance documents gives a clear change history.
| File set | Guidance | What changed |
|---|---|---|
| 202042 onwards | Guidance no. 1 of 2 July 2020 | Ten tabs, including Kre (20 largest exposures) and GG (10 largest debt and guarantee obligations); industry grouping on DB07 |
| 202541 to 202542 | Guidance no. 1 of 17 December 2024 | Ten tabs; industry grouping moved to DB25, in force 1 January 2025 |
| 202543 onwards | Guidance dated 11 September 2025 | Kre and GG removed, leaving eight tabs; the other eight template sheets unchanged from 202541 |
The removed Kre tab ranked the 20 largest exposures on exposure value after impairments and provisions and after the credit risk mitigation and exemptions in Articles 387 to 403 of the CRR, leaving out exposures to jointly owned data centres and to credit institutions supervised in the EU. GG listed creditor, amount and maturity for the ten largest debt and guarantee obligations.
Around KFI, Finanstilsynet is moving Danish EBA, EIOPA and ESMA returns from FIONA to its new e-Reg system on a module-by-module timetable. Its transition page says that returns not listed there continue to be filed as today, with FIONA still used for national returns, and KFI is not on the list.
The larger change is EU-wide and affects only branches whose head office is outside the EU and the EEA. Directive (EU) 2024/1619 (CRD VI) rewrites the third-country branch regime. Its Article 2 requires Member States to apply the amendments in Article 1, points (9) and (13), which include the new third-country branch chapter, from 11 January 2027, but Articles 48k and 48l on reporting from 11 January 2026. Article 48l(2) requires class 1 third-country branches to report at least twice a year and class 2 branches at least annually. The EBA’s page on the resulting implementing technical standards records them as Commission Implementing Regulation (EU) 2026/1757, in force, with an application date of 28 March 2027. Our analysis of EBA reporting framework 4.3 and its TCB templates covers the template side.
Article 48k(3) keeps room for national reporting: it lets a competent authority impose additional reporting requirements on third-country branches where it needs more information. Executive order no. 1009 of 2 July 2025, which applies to third-country branches from 1 January 2027, keeps their duty to make accounting reports on the forms and guidance Finanstilsynet sets under § 198 of the Financial Business Act. None of the sources reviewed here says whether Finanstilsynet will keep KFI unchanged for third-country branches once the EU templates apply, change it, or replace it.
Frequently Asked Questions
Can the branch grade KbSb exposures on its head office’s internal rating scale?
Bilag 2 says banks do not have to use its principles and may start from their own rating systems if those can be translated into Finanstilsynet’s categories, or use parts of the principles where that gives a fairer basis. It also says any departure from the bilag should be discussed with Finanstilsynet before the classification is reported, including where an institution uses a different scale or a different definition of, for example, customers with normal credit quality.
A corporate customer has an objective indication of credit impairment but the impairment model shows no loss. Which grade applies?
Grade 1 still applies: Bilag 2 gives grade 1 to corporate customers with OIK under the accounting rules whether or not the institution expects a loss in the most likely impairment scenario. The starting point is stage 3, but the bilag allows the customer to sit in the weak part of stage 2 where the OIK does not stem from significant breach of contract or likelihood of bankruptcy and the impairment calculation shows no loss in the most likely scenario. The KbSb grade stays 1 either way.
Can a guarantee from the borrower’s parent company keep a customer out of grade 1?
For corporate customers, the guidance allows guarantees from other companies in the same group or from the ultimate owners to be taken into account when assessing whether OIK has occurred, in line with the accounting rules, and Bilag 2 adds guarantees from the state or municipalities. For private customers, Bilag 2 says guarantees cannot be taken into account in that assessment.
Do loans to other banks appear in UnSb or KbSb?
No. The KbSb instructions exclude exposures to central banks, credit institutions and jointly owned data centres, and Bilag 3 note 2 excludes central banks and credit institutions from industry group 2.8 (finance and insurance) used by UnSb. Within the KFI tabs, lending to credit institutions and central banks shows up on Bal asset line 3, “Tilgodehavender hos kreditinstitutter og centralbanker”.
Where does a loan to a municipality-owned utility go in UnSb?
Under its industry. The guidance defines public authorities as the state, Danish regions and municipalities or equivalent authorities abroad, and it places public enterprises that produce on market terms under their business activity, following DB25, regardless of public ownership. Only public enterprises that do not produce on market terms are reported by ownership.
Do reverse repos count in the KbSb exposure total?
No. The guidance excludes reverse repurchase transactions from the KbSb exposure measure, while loans that are pledged as collateral (“udlån, der belånes”) stay in. Reverse repos instead appear in NoBs, as the part of asset lines 4 and 5 that consists of purchase-and-resale transactions.
The branch restated a balance-sheet line after filing. Can the correction wait for the next quarter’s file?
The guidance asks for changes to reported material to be reported via FIONA Online as soon as possible. It sets no materiality threshold and no separate correction deadline, so it gives no basis for holding a known correction until the next quarter.
Related Articles
- KGFS Reporting in Denmark: New Home Loans to High-Debt Borrowers: the quarterly FIONA return on high debt-to-income home lending, listed under the same branch heading as KFI.
- KSERV Reporting in Denmark: The Twice-Yearly NPL Transfer Return: who reports transfers of non-performing loans to credit purchasers, and the 11 February and 11 August deadlines.
- KOFS Reporting in Denmark: Own Funds Returns and Deadlines: Danish own funds reporting and the move of EBA returns from FIONA to e-Reg.
- EBA Reporting Framework 4.3: TCB and AMLA Reporting From 2027: the EBA package that carries the third-country branch templates.
- CRD6 Third-Country Branch Authorisation: The 11 January 2027 Deadline: authorisation, classification and capital endowment for third-country branches under CRD VI.
- FINREP Reporting Explained: What You Actually Need to Know: the EBA financial reporting framework behind the FINREP9 module.
Key Takeaways
- Sequence each quarter with KFI first: its working-day clock runs out before the fixed-date returns filed under the same branch heading.
- Decommission the Kre and GG extracts for periods from 202543, and keep them only if Finanstilsynet confirms that corrections to older quarters use the old file set.
- Fix one DB25 industry code per exposure in the source system, since UnSb must agree with every other Finanstilsynet return that carries an industry code.
- Build the XML from the template and XSD, and check the control workbook directly before automating checks.
- Third-country branches: track Finanstilsynet’s position on KFI ahead of Implementing Regulation (EU) 2026/1757 applying from 28 March 2027.
Sources and References
- Finanstilsynet, KFI: regnskabsoplysninger for filialer af udenlandske pengeinstitutter (reporting page): Finanstilsynet web page
- Finanstilsynet, Vejledning til regnskabsindberetning for KFI (filialer af udenlandske kreditinstitutter), 11 September 2025: PDF
- Finanstilsynet, KFI template workbook 202543: XLSX
- Finanstilsynet, KFI control list 202543 (KFI_fejl_202543): XLSX
- Finanstilsynet, KFI XSD and XML example 202543: XSD, XML
- Finanstilsynet, KFI guidance no. 1 of 17 December 2024 (superseded, periods 202541 to 202542): PDF; KFI template 202541: XLSX
- Finanstilsynet, KFI guidance no. 1 of 2 July 2020 (superseded, from period 202042): PDF
- Finanstilsynet, Indberetningsfrister for elektronisk indberetning, August 2026: PDF
- Finanstilsynet, Indberetninger til FIONA Online: Finanstilsynet web page
- Finanstilsynet, Hvad er FIONA Online?: Finanstilsynet web page
- Finanstilsynet, Disse indberetninger flyttes til e-Reg: Finanstilsynet web page
- Finanstilsynet, KRGC og KRGS: Regnskabsindberetninger: Finanstilsynet web page; KRGS guidance, 10 April 2026: PDF
- Lov om finansiel virksomhed, LBK no. 432 of 16 April 2026, §§ 1(4), 198 and 347(1): retsinformation.dk/eli/lta/2026/432
- Bekendtgørelse om filialer af kreditinstitutter, der er meddelt tilladelse i et land udenfor Den Europæiske Union, som Unionen ikke har indgået aftale med på det finansielle område, BEK no. 1616 of 13 November 2020, §§ 13 and 15, as amended by BEK no. 1008 of 2 July 2025: retsinformation.dk/eli/lta/2020/1616; retsinformation.dk/eli/lta/2025/1008
- Replacement order from 1 January 2027: BEK no. 1009 of 2 July 2025, §§ 15, 17 and 22: retsinformation.dk/eli/lta/2025/1009
- Current accounting legislation: Bekendtgørelse om finansielle rapporter for kreditinstitutter og fondsmæglerselskaber m.fl., BEK no. 658 of 23 May 2025, as amended: retsinformation.dk/eli/lta/2025/658. The KFI guidance itself still links to historical BEK no. 281 of 26 March 2014: retsinformation.dk/eli/lta/2014/281
- Amending order: Bekendtgørelse om ændring af bekendtgørelse om finansielle rapporter for kreditinstitutter og fondsmæglerselskaber m.fl., BEK no. 345 of 25 February 2026: retsinformation.dk/eli/lta/2026/345
- Current third-party-payments legislation: Bekendtgørelse om tredjepartsbetalinger m.v., BEK no. 679 of 24 July 2026, in force 4 August 2026: retsinformation.dk/eli/lta/2026/679. The KFI guidance itself still cites historical BEK no. 1202 of 15 November 2017: retsinformation.dk/eli/lta/2017/1202
- Directive 2013/36/EU (CRD), Articles 38 and 40: EUR-Lex
- Directive (EU) 2024/1619 (CRD VI), Article 1 (Articles 48k and 48l CRD) and Article 2: EUR-Lex
- EBA, Implementing Technical Standards on the supervisory reporting of third country branches: eba.europa.eu; Commission Implementing Regulation (EU) 2026/1757: EUR-Lex
- Danmarks Nationalbank, reporting guidance for payment statistics (Nets and Mastercard), section on the general control process in FIONA: PDF
Preparing the Next KFI Quarter on the 202543 File Set
For each quarter, use the current 202543 KFI file set and submit it through FIONA Online within 15 working days of quarter-end. KbSb is reported with the half-year and year-end submissions. Use the current template workbook and XML schema for the applicable reporting units and field-level specifications. Check the file against the published KFI control workbook before upload, and settle any open scope question with Finanstilsynet before that fifteenth working day.
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.
