XBRL taxonomy requires the "total” of all currencies plus a breakdown for each "significant currency". This lead us to the following questions: 1) What is the definition of “total”? 2) Has the reporting currency itself (which will be in any case greater than 5%) to be reported separately as “significant currency”?

Unfortunately the instructions does not give any guidance on this issue.

(i) Article 415(1) CRR requires institutions to report items in a single currency regardless of their actual denomination. The important point is that the total reported should cover all items referred to in Titles II and III and their components regardless of the currency of an individual item. The reporting of items denominated in the reporting currency under Article 415(1) plus items denominated in a currency different to the reporting currency subject to reporting under Article 415(2) plus items denominated in a currency different to the reporting currency not subject to reporting under Article 415(2) provides for the reporting of all items regardless of the currency of an individual item.

(ii) Article 415(2) provides for the reporting of items denominated in a currency different from the reporting currency under Article 415(1). Article 415(2) therefore does not provide for the reporting of items denominated in the reporting currency under Article 415(1). From a prudential perspective it can be important to require the separate reporting of items denominated in the reporting currency since such items can often be significant for liquidity purposes. Indeed Article 4(5) of Delegated Regulation (EU) 2015/61 requires credit institutions to calculate and monitor their liquidity coverage ratio separately for liabilities in the reporting currency. In accordance with Article 104(1)(j) of Directive 2013/36/EU (CRD IV) which empowers competent authorities to impose on an institution-specific basis, including in accordance with Article 103 CRD IV, additional or more frequent reporting requirements, including reporting on capital and liquidity positions, the competent authorities may consider requiring separate reporting of items denominated in the reporting currency.

DISCLAIMER

This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate General of the Commission (Directorate General for Financial Stability, Financial services and Capital Markets Union) has prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.