Given that the application date of Directive 2013/36/EU (CRD) / Regulation (EU) No 575/2013 (CRR) has now changed from 1 January 2014 to 31 December 2013 (see Directive 2013/36/EU, Article 162, Paragraph 1), what is the first reporting date / reporting period, specifically for the LCR and NSFR returns (Regulation (EU) No 575/2013, Part Six, Title II and Title III, respectively), but also for other returns such as COREP? Supplementary question: If the first reporting date is 31 December 2013, i.e. the first reporting period for the LCR return, for example, is December 2013, this would mean that most of the reporting period lies outside the application date of the legal provisions (CRD and CRR) underpinning the reporting. Do you see any legal complications in this fact?"

The first reporting date is relevant for planning purposes, both for the actual submission and the necessary preparatory work. Given the short timescales involved (especially if the first reporting date is in 2013), a speedy answer of the main question above would be much appreciated, even if this means that the supplementary question above is answered at a later time, or even not at all.

The first reporting date of 31 December 2013 has been amended by way of a corrigendum (published in the EU Official Journal on 2 August 2013) to 1 January 2014, unless otherwise specified either in Directive 2013/36/EU or Regulation (EU) No. 575/2013 (CRR), or in the relevant standards that the EBA is mandated to develop.

The rules applicable to the first reporting dates, reporting periods, and the respective remittance dates are set out in the Regulation (EU) No 680/2014 13 ITS on supervisory reporting of institutions (ITS). According to these provisions, institutions are required to report on a monthly basis from 31 March 2014 onwards, subject to the transitional provisions laid down in Article 18, paragraphs 2 and 3 of the ITS. Similarly, quarterly reporting of the stable funding data applies as of 1 January 2014 and shall commence as of 31 March 2014, subject to the transitional arrangements laid down in Article 18 paragraph 1 of the ITS.

*As of 1/8/2014 the content of this answer was modified to reflect the publication of the final ITS on supervisory reporting of institutions in the Official Journal of the European Union. As a result, the references to the ITS were updated and the disclaimer deleted. For reasons of transparency, revisions are highlighted in track changes.

The first reporting date of 31 December 2013 has been amended by way of a corrigendum (published in the EU Official Journal on 2 August 2013) to 1 January 2014, unless otherwise specified either in Directive 2013/36/EU or Regulation (EU) No. 575/2013 (CRR), or in a technical standard that the EBA is mandated to develop.

The EBA proposals for the first reporting dates, the reporting periods, and the respective remittance dates are set out in the draft ITS on Reporting published on the EBA website, which, as the formal adoption of the ITS falls on the European Commission, may still be subject to changes.

If the draft ITS is adopted as it stands, institutions would be required to report on a monthly basis from 31 March 2014 onwards, subject to the transitional provisions laid down in Article 18(4) and (7) of the draft ITS. Similarly, quarterly reporting of the stable funding data (where the EBA is also mandated under Article 415(3) of the CRR to prepare a draft ITS) applies as of 1 January 2014 and shall commence as of 31 March 2014, subject to the transitional arrangements laid down in Article 18(5) and (6) of the draft ITS.