How to match the re-translated opening balance (in current year) with closing balance (from prior year) on F 46 when the constant USD value is being converted to EURO in two different reporting periods with different FX rate? If the same prior year converted value in EURO is stated in opening balance (before restatement row 10), then how and which row does the FX translation impact shall be reflected?

On Template 46, opening balance (current period - row30) and opening balance (before restatement row 10) never matches the prior year due to the functional currency is anchored in USD in the entity's Financial Statement which is converted to EUR only for FINREP Reporting purposes in Template 46 at the reporting date’s fx rate. This means that although the USD numbers as per the financial statements (closing of prior year and opening balance of the current year) does not change, but the equivalent EUR converted figures changes due to the different exchange rate at two different reporting periods. 

ECB requested to open a Q&A to receive the accurate guidance on how to address the issue.

In template F 46.00, opening balance (before restatement row 0010) shall match the prior period closing balance.

Any foreign exchange difference cannot be considered as an “error” or a “change in the accounting policies” as per the definitions of accounting standards. Therefore, rows 0020 or 0030 of template F46 should not be used. Instead, it should be considered as a movement of the year and reported in one of the rows from 0050 to 0200, depending on the items.