Question ID
2025_7567
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
PILLAR III ITS ARTICLE 26
Paragraph
3
Subparagraph
NA
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 650/2014 - ITS on disclosure by competent authorities
Article/Paragraph
PILLAR 3 - PREVIOUS PERIODS
Type of submitter
Other
Subject matter
Disclosure on more periods in one template
Question

In some reports of the Pillar 3 reporting obligations some cells are specifically asking for the amount of the previous periods to be declared :

For instance  : Report K6000 - EU OV1 – Overview of total risk exposure amounts : Column 0020 T-1

On those reports we are having some different interpreations with some of our clients regarding what is expected to be fed in column T-1.

Some of our client think that column T-1 should always refer to the end of the previous financial year, meaning that when reporting figures for Q2/Q3/Q4 2025 the figures reported in column 0020 should of report K6000 should remain unchanged and should always report the data of Q4/2024.

 

In our intepretation of the ITS, we understand that in case :

  • The Entity has to report a table on a quarterly frequency in this case the T-1 figures should always reflect the figures of the previous quarter, so for closing date Q2/2025 column 020 of K6000 should be populated with figures coming from Q1 2025, so for closing date Q3/2025 column 020 of K6000 should be populated with figures coming from Q2 2025, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q3 2025,
  • The Entity has to report a table on a Yearly frequency in this case the T-1 figures should always reflect the figures of the previous year, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q4 2024

Can you please indicate the correct expectation of EBA ?

 

Background on the question

Article 26
Disclosure period and frequency
1. Disclosure periods shall be defined as quarterly periods T, T-1, T-2, T-3 and T-4.
2. The rows or columns in the uniform disclosure formats referred to in the Annex Ind included in the IT solutions developed by the EBA shall be populated in accordance with the frequency of the disclosure laid down in Articles 433a, 433b and 433c of Regulation (EU) No 575/2013.
3. Institutions subject to the obligation to publish disclosures shall disclose information with the following frequency:
(a) institutions disclosing the information contained in the Annex I on a quarterly basis shall provide data for periods T, T-1, T-2, T-3 and T-4;
(b) institutions disclosing the information contained in the Annex I on a semi-annual basis shall provide data for periods T, T-2 and T-4;
(c) institutions disclosing the information contained in the Annex I on an annual basis shall provide data for periods T and T-4.
4. Institutions shall disclose the dates corresponding to the disclosure periods.
5. The disclosure of data for previous periods shall not be required where data are disclosed for the first time.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is already explained in Article 26 on ‘disclosure period and frequency’ of Commission Implementing Regulation (EU) 2024/3172.

For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'

Status
Rejected question