Is the instruction in Annex 13 to item 2.6 (C 84.00, r0180, c0030) correct?

The instruction in Annex 13 to item 2.6 of template 84 {C 84.00, r0180, c0030} prescribes that the amount to be reported in this field should match the amount of item 2.5 of reporting template C 81.00 and that the amount of item 2.5.3.1 of reporting template C 81.00 should be excluded of this.

Based on the Taxonomy, {C 84.00, r0180, c0030} should equal {C 81.00, r0230, c0100} because both fields refer to the exact same DataPointID (458912). This is not a published validation rule, but given the fact that both fields refer to the same DataPointID, per definition, those fields should be equal.

Reporting according to the instructions of Annex 13, in case there are operational deposits to financial customers, automatically leads to an error compared to the Taxonomy. Excluding the amount of operational deposits (conform instructions) leads to a lower amount on {C 84.00, r0180, c0030} compared to the amount on {C 81.00, r0230, c0100}. Therefore, the instruction of Annex 13 seems inconsistent with the Taxonomy.

We ask the EBA to clarify on this matter and confirm whether the instruction in Annex 13 is correct or not.

This Q&A has been rejected in 2021 as the EBA was already aware of this problem and promised to solve this in reporting framework 3.2. However the changes have not been implemented in DPM 3.2 and banks are now applying various manual workarounds to report template C84 adequately.