On what basis should the buffers section (columns 410 to 480) be reported?
The ITS instructions do not specify if this section is on a transitional or full impact basis and whether the buffers should be reported under local rules or contributions to the group buffers.
Relevant entities shall report in columns 410 to 480 of templates C 06.01 and C 06.02 of Annex II of Regulation (EU) 680/2014 (ITS on Supervisory reporting) the capital buffers in accordance with the national transposition measures of Directive 2013/36/EU (CRD IV) and of Regulation (EU) 575/2013 (CRR), including any transitional provisions provided for therein. Likewise, the reported amounts represent the contributions of each entity to group capital buffers, and are based on provisions applicable to determine the buffer requirements for the consolidated situation of a group.