Could you please confirm what the first reporting reference date for the sovereign exposures template (C 33.00) for institutions
i. who report on a calendar year basis (i.e. accounting reference date 31 Dec)
ii. whose accounting reference date deviates from the calendar year (say 31 March) and are permitted to apply Article 2(3) of Regulation (EU) No 680/2014
The Draft Final Report EBA/ITS/2017/01 (Version 2) which was published on 7 April 2017 states that the reporting reference date will be 31 March 2018 (see last sentence on p4). Further, paragraph 8 in this Final Report states that the template should be reported with a semi-annual frequency. The above implies that all institutions subject to C33 reporting will have their first reporting reference date on 31 March 2018 and after that on 30 September. Countering this, Article 2(1)(c) of Regulation (EU) No 680/2014, states that institutions shall submit information for semi-annual reporting on 30 June and 31 December. Provision is made under Article 2(3) for reporting reference dates to be altered where institutions are permitted by national laws to report their financial information based on their accounting year-end which deviates from the calendar year. In these circumstances, the reporting reference dates may be adjusted so that reporting is done every three, six or twelve months from their accounting year-end, respectively. This would imply that for institutions whose accounting reference dates are on a calendar year basis, their first reporting reference date will be 30 June 2018 and not 31 March 2018. Furthermore, for institutions whose accounting reference dates deviate from the calendar year and on say 31 March, their first reporting reference date will be 31 March 2018 in accordance with Article 2(1)(c) of Regulation (EU) No 680/2014. Their next reporting reference date will be on 30 September.
In Accordance with Article 5 (b) (3) of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), template C 33.00 of Annex I to the ITS on Supervisory Reporting has to be reported on a semi-annual basis. Semi-annual reporting is submitted for the reference dates 30 June and 31 December as explained in Article 2 of the ITS on Supervisory Reporting and the remittance dates for these submissions are 11 August und 11 February as prescribed in Article 3 thereof.
For institutions submitting financial information based on their accounting year-end which deviates from the calendar year, Article 2, paragraph 3 of the ITS on Supervisory Reporting allows for an adjustment of the reporting reference dates. This only refers to reporting of financial information in Articles 9, 10 and 11 of the ITS on Supervisory Reporting, but not to the reporting of own funds and own funds requirements in Article 5 which is the legal basis for the reporting of template C 33.00 of Annex I. Therefore the first reference date for template C 33.00 is 30 June 2018 and the first remittance date is 11 August 2018. Institutions with a deviating accounting year-end are not allowed to adjust the reporting reference dates of template C 33.00 accordingly.