Response to consultation on draft Implementing Technical Standards on Pillar 3 data hub
Question 1: Do you agree with the proposed IT solutions that would support the implementation of the P3DH to Large and Other institutions? If not, please explain the reasons why.
Submissions and definition of “module”
Regarding the submission process, it is requested on the draft ITS to provide each module in XBRL-csv format. One single .zip file shall be submitted per module.
Respondents need further clarification on the definition of “module” in the context of the Pillar 3 Data Hub. This definition should be specified by the EBA in the final ITS.
A list containing the disclosures templates constituting each “module” or a descriptive nomenclature is necessary for proper understanding.
More generally, institutions expect additional detailed instructions and formal examples.
Process for empty templates / data points
For empty templates / data points, the draft ITS mentions that “Empty templates / data points shall be explained in the accompanying narratives.”
Would it be possible to provide more clarification on that topic? Respondents would need to understand where such accompanying narrative should be inserted. We understood during the Public Hearing that empty templates shall be provided only in the csv file not in the pdf. Would this narrative be inserted into the csv file within a dedicated section? Or would this narrative be explained in the pdf report? The concrete process foreseen by the EBA needs to be expressed and defined precisely in the final ITS.
In addition, providing a narrative for each empty data points appears to be constraining and cumbersome as the number of empty data points may be high (due for example to the non-use of a specific approach within an institution). Thus, such narratives should be limited to empty templates.
First application date
The first application of the P3DH is set to end of June 2025 in the draft ITS. This first application date is very close to the first remittance of Supervisory Reporting and Disclosures under ITS CRR3.
Dealing with such huge and structuring implementation projects in parallel would be very burdensome for institutions.
In addition, considering the degree of maturity of the solution established and the issues which arise from the Pilot exercise (significant pending questions regarding the access to EUCLID portal, IT security potential breaches, availability and compatibility of the downloaded module of connection, etc.…), respondents ask for the postponement of the first P3DH implementation date.
Furthermore, in regard of the Pilot Exercise, we would support to await the formal conclusions of the EBA as far as the exercise is still ongoing at the date of remittance of our answer.
End of June 2025 should serve to EBA and institutions as a first pilot test but should not be an official ‘Go live’.
Responsibility of the EBA regarding the information published within EBA website
While respondents agree that the ownership of the data and the responsibility for their accuracy remain with the institutions that produce the data, the EBA shall be responsible for disclosures made on the EBA website are identical to those submitted by institutions, as stated in paragraph 34 of the consultation paper. Indeed, institutions no longer have control of the data hub tools (transcription of the information received in accordance with the standards of the EBA's public website) or of the EBA's public website (questioning on the level of security). They are concerned about the risk of discrepancies between the information transmitted and the information posted on the EBA website due to technical problems where the files could not be downloaded and about their inability to carry out remedial actions.
Besides, the EBA intends to transform information submitted by institutions and to provide data visualization and graphs in addition to the original files submitted by institutions. Respondents would like to recall that institutions could not be responsible for any transformation of the data they initially submitted. The scope of their responsibility is limited to the sole data that have been submitted to the EBA for Pillar 3 information purposes.
Therefore, respondents encourage the EBA to make clear on the EBA public website that, the EBA is responsible not only for any transformed data that have been added to the official information submitted by institutions, but also for the data submitted by institutions and posted on its website.
Question 2: Would you agree with the specification to provide the information on remuneration policies separately? If not, please explain the reasons why.
Please refer to answers to question 1.
Question 3: Would you agree with the proposal on the collection of contact points information, including the suggested monthly frequency?
Regarding the frequency for new template dedicated to contacts, respondents have a strong preference for an annual remittance. Respondents feel that adding such new remittance on a monthly basis and producing such template twelve a time per year brought additional burden without added value. Flexibility should be granted regarding this process. In addition to an annual remittance, the possibility to report with a lower frequency in case of a change occurring during the year should be given.
Number of points of contacts
It has been understood that at least 3 points of contacts shall be filled within the new template proposed by the EBA. Would it be possible to specify this requirement in the final ITS?
Additionally, what would be the maximum number of points of contact?
Question 4: Would you have any comments or suggestions on the most adequate profile of the contact persons within the institution?
The most adequate profile of the contact persons within the institution in case of any question and / or technical problems are the persons in charge of the production of the templates and disclosures. So, it is up to these persons to act as an internal link with the other teams, especially the IT teams.
Processes regarding the delegation of permissions to submission systems are already put in place by national competent authorities. Therefore, respondents suggest capitalizing on the existing sign-off processes and delegating to the national competent authorities the authorisations and follow-up of the contact persons to be.