Validation rule V89101_S (with {tK_19.02.a, c*, default: null, interval: false}: {(r0040, r0090)} <= 0) of the Pillar 3 template EU OR2: it appears that the two rows “1b. Interest and lease expense” and “2b. Fee and commission expense” have to be reported with the negative sign or as zero. We guess that these two rows should be reported as positive or zero, because of the following reasons:
It is already known, by definition, that they are “expenses”.
This validation rule is not extended to the row “2d. Other operating expense”.
Considering the DPM 4.2, which will enter into force from Q1 2026, the Validation Rules v903192_s (with {tC_16.02, c0070, default: null, interval: false}: {(r0010, r0110, r0200, r0220, r0260, r0310, r0340, r0370, r0420)} >= 0) and v903193_s (with {tC_16.02, default: null, interval: false}: {(r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0120, r0130, r0140, r0150, r0160, r0170, r0180, r0190, r0210, r0230, r0240, r0250, r0270, r0290, r0300, r0320, r0330, r0350, r0360), (c0010, c0030, c0050)} >= 0) of the CoRep template C16.02 appear to require that all the expenses related items have to be reported with positive sign or as zero.
Considering the mapping tool provided within the EBA Consultation Paper of February 2024 on OpRisk disclosure (file “mapping_tool_for_crr_3-step1-oprisk_tc.xlsx”), for the part related to the Pillar 3 template EU OR2, a direct link was reported to the related cells of the CoRep template C16.02, which were required to be positive by the Validation Rules reported at the previous point.
In the Quantitative Impact Study (QIS), performed semi-annually by the Basel Committee, the sheet “OpRisk” requires reporting the items “Interest expenses (including financial and operational lease)”, “Fee and commission expenses”, and “Other operating expenses (except for financial and operational lease)” with a positive sign or as zero.
Validation rule V89104_S (with {tK_19.02.b, c0050, default: null, interval: false}: {r0190-0200} <= 0) of the Pillar 3 template EU OR2: it appears that the items “6b. Reduction in BI due to excluded divested activities” and “6c. Impact in BI of mergers/acquisitions” have to be lower than or equal to zero. We guess that the items “6b. Reduction in BI due to excluded divested activities” and “6c. Impact in BI of mergers/acquisitions” should be reported as zero or positive for the following reasons:
It is already known, by definition, that item 6b is a “reduction”.
Item 6c, i.e., the impact of an M&A operation, is generally positive.
Considering the DPM 4.2, which will enter into force from Q1 2026, there are no Validation Rules that require reporting the columns 0020 (“of which: adjustments due to merge/acquisition of entities or activities”) and 0030 (“(Adjustments due to disposal of entities or activities)”) with a negative sign or as zero.
Considering the mapping tool provided within the EBA Consultation Paper of February 2024 on OpRisk disclosure (file “mapping_tool_for_crr_3-step1-oprisk_tc.xlsx”), for the part related to the Pillar 3 template EU OR2, a direct link was reported to the related cells of the CoRep template C16.01, where the item 6b has to be “'={C 16.01, r0020, c0030}” (“Business indicator” / “(Adjustments due to disposal of entities or activities)”) and the item 6c has to be “={C 16.01, r0020, c0020}” (“Business indicator” / “of which: adjustments due to merge/acquisition of entities or activities”). Considering the previous point, no Validation Rules are coming from the CoRep template C16.01.
In the Quantitative Impact Study (QIS), performed semi-annually by the Basel Committee, in the sheet “OpRisk,” the item “Reduction in BI due to excluded divested activities” is reported with a positive sign or as zero.
- Legal act: Regulation (EU) No 575/2013 (CRR)
- COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
