Pillar 3 data hub

The following institutions are in scope of the first implementation of the P3DH:

• Large institutions at the highest level of consolidation in the EEA (including stand-alone institutions and including financial holding companies and mixed financial holding companies supervised under Directive 2013/36/EU);
• Large subsidiaries, subject to the reduced number of Pillar 3 requirements as established under Article 13;
• Other institutions at the highest level of consolidation in the EEA (including stand-alone institutions).

The institutions to be onboarded have been identified by the EBA, together with the relevant Competent Authority, based on Articles 6 and 13 of the CRR and the master data available in the EBA system.

Pursuant to Articles 6 and 13 of the CRR, institutions classified as “other” under the CRR that are not at the highest level of consolidation in the EEA are not required to comply with the obligations set out in Part Eight of the CRR, either at individual or consolidated level.

The classification of the different institutions follows the categorization / definitions under Article 4 of the CRR (large institution; small and non-complex institution; other institution for those that do not fall in any of the other categories).

In case an institution believes being in scope of the first implementation but has not received the EBA letter launching the onboarding process, it shall contact the EBA via the helpdesk support.

The first implementation of the P3DH will solely consider large and other institutions required to disclose Pillar 3 information under the CRR provisions. Institutions disclosing Pillar 3 information on a purely voluntary basis will not be considered at this stage. Following the first implementation, the EBA will reassess how these specific cases could be treated and whether the respective disclosures could be done via the P3DH. 

Voluntary Pillar 3 disclosures in addition to the minimum requirements under the CRR (i.e., institutions required to disclosure Pillar 3 information) will be accepted in the P3DH. This refers to Pillar 3 quantitative and qualitative information. The submission of Pillar 3 information prepared on a voluntary basis shall follow the general rules for the mandatory submission of information (i.e., quantitative information to be submitted in XBRL-csv format and included in the PDF report; qualitative information to be submitted in the PDF report). 

The onboarding timeline is fully aligned with the final draft ITS on IT solutions as transitional provisions[1] were put in place for reference dates June, September and December 2025. 
 

During the transitional period established in the final draft ITS (reference dates June, September and December 2025), institutions should keep complying with their disclosure obligations as they were doing until now without delay. The later submission of the Pillar 3 information corresponding to these reference dates to the P3DH will take place according to the timeline spelled out in this document, and without causing any delay in the compliance with Pillar 3 disclosure obligations during 2025.  

Once the onboarding process is completed and the institution is under conditions to submit the information to the EBA, the reports for the past reference dates covered by the transitional arrangements shall be submitted to the EBA for publication in the data hub. While no limit date is set for this submission, reports already made public by the institution are expected to be submitted without undue delay and reports not yet published should follow the timeline envisaged for the steady state. 

The submission dates of information to the EBA shall follow the specifications under Article 4 of the final draft ITS, i.e. required information shall be provided to the EBA on the same day on which institutions publish their financial statements or financial reports for the corresponding period, where applicable, or as soon as possible thereafter. Information required under Article 450 of the CRR shall be submitted separately from the remaining information no later than two months after the date on which institutions publish their financial statements for the corresponding year. Information on contact persons shall be submitted annually, by 31 January.

While no mandatory or indicative limit dates for submission are put in place, there are some expectations as regards the submission of information to the EBA, as indicated in the final report on the final draft ITS:

• Year-end Pillar 3 reports (reference date December): by end-June, with the exception of the remuneration policies information that would be expected by end-August;
• Year-end Pillar 3 reports (reference date different from December): by “reference date + 6 months”, with the exception of the remuneration policies information that would be expected by the end of “reference date + 8 months”;
• Quarterly Pillar 3 reports: by “reference date + 4 months”;
• Semi-annual Pillar 3 reports: by “reference date + 4 months”.

In order to support institutions and users of information to navigate through the list of Pillar 3 disclosure requirements and identify their disclosure obligations, a comprehensive file[1] was published by the EBA last year containing the following information:

• List of templates / tables, with indication of the respective relevant Article under the CRR;
• Disclosure obligations by type of institution, including the templates that they need to disclose and  the frequency of required disclosures for: large institutions (listed and G-SII); large institutions (listed and no G-SII); large institutions (not listed); other institutions (listed); other institutions (not listed); SNCIs (listed); and SNCIs (not listed).

In addition to this, the EBA publishes regularly the technical package  to facilitate the implementation by the reporting  entities.  Pillar 3 templates are included in the technical package 4.1. While the final version of this package is expected to be published by end May / beginning June, a draft version can be consulted here.