Question ID
2026_8018
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
None
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph
None
Type of submitter
Consultancy firm
Subject matter
Inconsistencies in DPM 4.4
Question

Overlapping numbering of rows/columns detected in report sections of the (Draft) taxonomy on what, as per the ITS/Annotated Tables, are one report. Will this be aligned?

Background on the question

While analyzing DPM 4.4 for FINDIS (Financial Disclosures), we have observed that (amongst others) reports K22.02.a (EU CR2a) and K22.02.b (EU CR2a) have a column c0010 in the taxonomy. However, in the Template EU CR2a "Changes in the stock of non-performing loans and advances and related net accumulated recoveries", K22.02.b are shown next to the columns of K22.02.a. As a result, we would like to ask if any updates on DPM 4.4 are foreseen to align all documents in terms of row/column numbering (and as a result also the validations using these rows/columns)?

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. The objective of the Q&A tool is not to answer questions that put into doubt the correctness of the legal framework, seek a modification of the legal framework or would require such a modification in order to address the question. Specifically, the template EU CR2a 'Changes in the stock of non-performing loans and advances and related net accumulated recoveries'  of Annex I to Regulation (EU) 2024-3172 is split into two tables K 22.02a and K 22.02b for technical reasons due to the modelling in the DPM.

Status
Rejected question