Article 2(3) of the ITS on Supervisory Reporting allows the uniform reporting and remittance dates for reporting financial information (i.e. FINREP) to be adjusted where institutions are permitted by national laws to report their financial information based on their accounting year-end which deviates from the calendar year (this was also clarified in the response to Q&A 147). The supervisory reporting templates on Asset Encumbrance follow, from a methodological point of view, FINREP and the current ITS also includes some cross validation checks between certain data points in FINREP and the AE templates.
In this regard, can the same flexibility with the reporting and remittance dates (in Article 2(3) of the ITS on Supervisory Reporting) provided to institutions that have an accounting year-end which deviates from the calendar year in terms of reporting FINREP also be extended to the reporting of the Asset Encumbrance templates?
Some banks which report their financial information based on their accounting year-end which deviates from the calendar year have queried whether the same flexibility permitted under Article 2(3) of the ITS on Supervisory Reporting in terms of the reporting and remittance dates for FINREP should also be extended to the Asset Encumbrance templates. The asset encumbrance templates are based on accounting values (carrying amounts) in order to ensure the possibility of reconciling the reported figures with the balance sheet items (FINREP). In this regard, it makes sense that the same reporting and remittance dates applied to FINREP returns are also applied to the Asset Encumbrance templates
According to Article 2(3) of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), where reporting institutions are permitted by national laws to report their financial information based on their accounting year end which does not coincide with the calendar year, they may adjust their reporting reference dates accordingly.
This discretion to adjust the reporting reference dates is only available for financial information (FINREP, Annexes III, IV and V) and, thus, shall not be applied to other parts of the ITS on Supervisory Reporting such as own funds requirements (COREP, Annexes I and II) or assets encumbrance (Annexes XVI and XVII).