- Question ID
 - 
            2023_6888
 - Legal act
 - Regulation (EU) No 575/2013 (CRR)
 - Topic
 - Transparency and Pillar 3
 - Article
 - 
            449a
 - COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
 - Not applicable
 - Article/Paragraph
 - 
            449a of CRR
 - Type of submitter
 - 
            Credit institution
 - Subject matter
 - 
            Pillar 3 reporting obligations
 - Question
 - 
            
Within the Pillar III disclosures, there are specific sectors that have a handful of dominant companies (3 or less) where the financial institutions have to disclose data for these specific NACEs separately. Would the above Eurostat-confidentiality rules stand within the Pillar III disclosures?
 - Background on the question
 - 
            
In line with the Pillar III reporting obligations, the financial institutions are disclosing company-related information in a tabular format according to the specific sector.
Nevertheless, a Eurostat publication on Statistical Disclosure Control (a chapter from the European Business Statistics Manual) notes that “it is always required that the value in the table represents at least 3 observations. Values based on 1 or 2 observations are confidential.”
Moreover, the publication also states that “in business statistics, the distribution of the target variable is often skewed: there are only a few big companies and also within a particular cell, 1 or 2 companies might be dominant. This would make it easy to disclose the information on the dominant company with a high level of accuracy. For this reason also, cells with dominant companies are confidential.” The Eurostat report provides a table with confidentiality rules that needs to be conform with when publishing company-related data (refer to attached document).
 - Submission date
 - Rejected publishing date
 - 
            
 - Rationale for rejection
 - 
            
This question has been rejected because the issue it deals with is already addressed in Article 432 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 (Capital Requirements Regulation or CRR2). The Eurostat regulations are not applicable to Pillar 3 disclosures framework.
For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'.
 - Status
 - 
            Rejected question