Question ID:
Legal Act:
Directive 2013/36/EU (CRD)
Other issues
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Not applicable
Disclose name of institution / entity:
Name of institution / submitter:
Federation of European Accountants (FEE)
Country of incorporation / residence:
Type of submitter:
Industry association
Subject Matter:
Country of transaction, scope of disclosures and intragroup transactions

It is expected that transactions will be attributed to the country of the unit of the group that is party to the transaction. How should intra-group cross-border transactions and consolidation adjustments be treated? How should the impact of associates and joint ventures on the reported figures be dealt with?

Background on the question:

Generally, FEE supports the use of internationally accepted standards when it comes to definitions of items of financial statements. IFRS 8 13 Operating Segments provides guidance on how an entity should identify its operating and reportable segments. Therefore we propose that the same accounting policies should be applied in the context of regulatory reporting.

Date of submission:
Published as Final Q&A:
Final Answer:

Recital 52 of Directive 2013.36/EU sets out the principle that increased transparency regarding the activities of institutions should be seen as an important element of the corporate responsibility of institutions towards stakeholders and society. In accordance with this principle and Article 89, institutions are required to disclose information on a consolidated basis 13 as set out in Q&A 1248  - this is the prudential scope of consolidation, or where so prescribed by the Member State, a more extensive scope of consolidation, i.e. the accounting scope.

Against that background, it can be considered best practice to disclose country by country reporting before adjustments for intra-group cross-border transactions and other consolidated adjustments, accompanied by appropriate information to explain their impact.

To the extent that associates and joint ventures are included in the scope of consolidation (be it the regulatory scope of consolidation or a more extensive scope required by Member States), related information should be included in the disclosure of country-by-country reporting.

Final Q&A
Answer prepared by:
Answer prepared by the EBA.
Note to Q&A:

Update 26.03.2021: This Q&A has not yet been reviewed by the EBA in the light of the changes introduced to Directive 2013/36/EU (CRD).

Update 28.10.2021: This Q&A has been reviewed in the light of the changes introduced to Directive 2013/36/EU (CRD) and continues to be relevant.