The additional column C015 “Code” to template C 67.00 contains ambiguity in the Annex IV guidance under the ITS to be implemented at Mar-20: 1.2.8.015 “This code is a row identifier and shall be unique for each row in the template”. It is unclear what identifiers are required in column C015.
The annotated template released in DPM 2.9.1 under ‘Changes compared to previous version phase 2.9.1’ for COREP states that “Metric = (si289) Entity code [si]”. However the guidance does not specify what this entity code is required to be, and the cell appears to require a free-text value (si289 does not appear to be included in the list of values in the 2.9.1 release documentation).
In final ITS 2019/01 “Final Report on Draft Implementing Standards amending Implementing Regulation (EU) No 680/2014 with regard to COREP” and the associated Annex IV “Instructions for completing the additional monitoring tools template of Annex XVIII” a new column is added to C 67.00 (C015 “Code”) – what values are required to be populated in this column?
Given the presence of the sequentially numbered “Row” and “ID” columns as well as the R020 LEI code in template C 67.00, each row is already uniquely identified. There is nothing in the Annex IV guidance to suggest what code is required to be reported in the new column C015.
There is a similarly named column in the new Annex XXV LCR C 77.00 “Perimeter of consolidation” template, with the accompanying Annex XXIV guidance “This code is a row identifier and shall be unique for each row in the table. Code assigned to the entity within the scope of consolidation.”
While the final ITS 2019/01 text states that this column has been deleted from C 77.00 (p43, amendments to the proposals), the column is still present in the published Annex XXV tracked changes version.
The column “Code” exists in other parts of the Implementing Regulation (EU) No 680/2014 (e.g. C 06.02, F 40.01, F 40.02 and C 27.00 to C 31.00) and shall be reported in a similar manner. The actual composition of the code depends on the national reporting system. The code shall be unique and used consistently across the templates and across time.