Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - Funding Plans
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
P 02.06
Disclose name of institution / entity:
Type of submitter:
Competent authority
Subject Matter:
The 3 largest material currencies in the structural currency mismatches tables (P 02.06) of funding plan report

According to the instructions for P 02.06, the table provides a breakdown of the 3 largest material currencies. The currency is material if it accounts for more than 5% of total liabilities, as per Art 415 (2) lit. b CRR. (We think the correct reference here is Art 415 (2) lit. a CRR.)

According to Art. 415 (2) lit. a) CRR,: an institution shall report separately to the competent authorities of the home Member State the items referred to in paragraph 1 in the currency below when it has:
(a) aggregate liabilities in a currency different from the reporting currency under paragraph 1 amounting to or exceeding 5 % of the institution's or the single liquidity subgroup's total liabilities

Does that mean that the reporting currency has to be reported?

If yes, how shall the reporting currency – take the Hungarian forint as example - be reported in the structural currency mismatches tables of funding plan report?

Background on the question:

Due to the fact that the reporting currency is excluded from art. 415(2a) the above guidance is not clear that the reporting currency (Hungarian forint) belongs to the 3 largest currencies or not.

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

Template P 02.06 of EBA/GL/2014/04 (Guideline on Funding Plans) refers to structural currency mismatches based on a breakdown of the three largest material currencies. In the instructions for template P 02.06 it is stated that one should “… provide a breakdown of your balance sheet by 3 largest material currencies.  Please note, we only expect firms to report a currency where it accounts for more than 5% of total liabilities, as per CRR Art 415 2 (b).” The instructions currently refer to Art. 415 2 lit. b CRR, but they should refer to Art. 415 (2) lit. a CRR.

Institutions shall identify all material currencies, including reporting currency, based on the threshold above.

The reporting currency – in this Q&A the case refers to Hungarian forint – should be reported in template P 02.06. That is, for an institution with Hungarian forint as the reporting currency and with 3 largest significant currencies in EUR, USD and GBP in accordance with Art. 415 (2) lit. a CRR, the institution is expected to report data in HUF, and two largest foreign currencies when they are significant as per Art 415 (2) lit. a CRR in P 02.06. This corresponds to the point a) in the proposed answer. Please note that, as template P 02.06 is a replicating table, this should be reported three times in the current example with data on each major currency denominated in the reporting currency.

Please see also Q&A 2015_2388 on application of threshold.

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