Question ID
2015_2406
Legal act
Directive 2013/36/EU (CRD)
Topic
Supervisory reporting - Supervisory Benchmarking
Article
78
Paragraph
2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
Article/Paragraph
Article 1, Annex III
Type of submitter
Credit institution
Subject matter
Levels of reporting
Question

Please clarify whether this reporting exercise requires also the submission of data at sub-consolidated level, apart from consolidated and solo level.

Background on the question

In accordance to guidance received so far, we would be required to submit data at individual entity as much as at consolidated level; it remains nevertheless unclear to us as to whether we would also have to submit data at 1cTeilkonzern 1d-level", sub-consolidated level.

Submission date
Final answer

The reporting requirements to the competent authority apply at the same level as own funds requirements and the Draft ITS on Supervisory Reporting for Institutions for benchmarking the internal approaches (ITS on benchmarking) is based on Article 78 of the Directive 2013/36/EU (CRD IV). Hence, if an institution is required to calculate own funds requirements at a sub-consolidated level, reporting requirements will also be applicable. A check against own funds reporting requirements as specified in Regulation (EU) No. 680/2014 - ITS on reporting could be performed to establish whether or not benchmarking reporting requirements apply (template C 08.01 of Annex I of the ITS on reporting for credit risk internal approaches and template C 24.00 for market risk internal approaches).

DISCLAIMER:

The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal, which may differ from the text of the draft ITS to which this Q&A relates.

Status
Archive
Answer prepared by
Answer prepared by the EBA.
Note to Q&A

Update 26.03.2021: This Q&A has been archived in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking.