Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Annexes III, IV and V, validation rules
Disclose name of institution / entity:
Type of submitter:
Consultancy firm
Subject Matter:
EBA validations APPEAR to be relevant to IFRS and GAAP though they only include a GAAP template (F 04.06)

Can you confirm that these validations are out of scope for IFRS and, if so, why in the EBA validations list their severity is marked as "Blocking for IFRS"?

Background on the question:

Our understanding is that these validations should be applied to IFRS with the F 04.06 element removed. Our implementation excludes the validations entirely for IFRS.v1377_m:
{F 05.00, r080,c010} = {F 04.01, r130,c010} + {F 04.02, r130,c010} + {F 04.03, r130,c030} + {F 04.04, r080,c060} + {F 04.04, r220,c060} + {F 04.06, r130,c010} + {F 01.01, r030,c010}

{F 05.00, r080,c020} = {F 04.01, r140,c010} + {F 04.02, r140,c010} + {F 04.03, r140,c030} + {F 04.04, r090,c060} + {F 04.04, r230,c060} + {F 04.06, r140,c010}

{F 05.00, r080,c030} = {F 04.01, r150,c010}+ F 04.02, r150,c010} + {F 04.03, r150,c030}+F 04.04, r240,c060} + {F 04.06, r150,c010} + {F 01.01, r040,c010}

{F 05.00, r080,c040} = {F 04.01, r160,c010} + {F 04.02, r160,c010} + {F 04.03, r160,c030} + {F 04.04, r110,c060} + {F 04.04, r250,c060} + {F 04.06, r160,c010}

{F 05.00, r080,c050} = {F 04.01, r170,c010} + {F 04.02, r170,c010} + {F 04.03, r170,c030} + {F 04.04, r120,c060} + {F 04.04, r260,c060} + {F 04.06, r170,c010}

{F 05.00, r080,c060} = {F 04.01, r180,c010} + {F 04.02, r180,c010} + {F 04.03, r180,c030}F 04.04, r130,c060} + {F 04.04, r270,c060}+F 04.06, r180,c010}

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

As stated in the sheet ‘explanation’ of EBA’s list of validation rules, ‘blocking for IFRS’ validation rules are those fully applicable to IFRS reporting institutions but not necessarily to reporting institutions following other accounting standards, namely reporting institutions applying national GAAP.

Validation rules v1377_m to v1382_m were originally intended to be designed to be applicable simultaneously both for institutions applying IFRS and those applying national GAAPs in their FINREP reports in accordance with Annexes III, IV and V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting). However, those validation rules do not take into account all portfolios relevant under nGAAPs and are therefore likely to fail for many nGAAP reporters. The severity status ‘blocking for IFRS’ implies that institutions applying IFRS must comply with the mentioned validation rules – otherwise the submitted data would be incorrect or incomplete – while institutions applying nGAAP may not fulfil them even if the submitted data is accurate and complete.


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