Consultation Paper on Revisions to the ITS on supervisory reporting (Commission Implementing Regulation (EU) 2024/3117) - Module on FINREP

1 Background and rationale

1. In accordance with CRR Article 430 (3)(4), the reporting on financial information (Finrep) applies to credit institutions required to prepare their consolidated financial statements in accordance with International Financial Reporting Standards (IFRS) as endorsed by the EU, as well as to credit institutions required by supervisors to use IFRS endorsed by the EU for the determination of own funds and to investment firms subject to Article 4 of Regulation (EC) 1606/2002. The EBA originally chose to base the reporting of financial information (Finrep) on accounting standards to achieve efficient regulation by aligning supervisory reporting of financial information with accounting standards. Therefore, Finrep needs to be reviewed whenever the underlying international accounting standards adopted in accordance with Article 6(2) of Regulation (EC) 1606/2002 are updated.
2. In April 2024, the International Accounting Standards Board (IASB) issued ‘IFRS 18 - Presentation and Disclosure in Financial Statements’, which supersedes the accounting standard ‘IAS 1 -Presentation of financial statements’. IFRS 18 introduces a defined structure for the statement of profit or loss, where the items are classified into three new main categories (operating, investing and financing) with the aim of increasing comparability and transparency of entities’ performance reporting. The new IFRS 18 standard has been endorsed by Commission Regulation (EU) 2026/338, and it will be applicable for reporting periods beginning on or after 1 January 2027.
3. Following the issuance of IFRS 18, changes are therefore required to the existing Finrep reporting templates and related instructions for IFRS reporters to harmonise Finrep with IFRS 18 and avoiding different/double reporting requirements with institutions’ public financial statements.
4. While Finrep reporting remains aligned as much as possible with the relevant accounting standards, in accordance with CRR Article 430(5), ITS also requires the necessary information to obtain a comprehensive view of the risk profile of institutions’ activities and a view of systemic risks posed by institutions to the financial sector or the real economy. As a result of that, some parts of the Finrep framework need to be reviewed to address evolving supervisory needs, including monitoring emerging risks, and incorporating improvements in reporting templates and instructions based on the experience with data quality and feedback received by the stakeholders through the single rulebook Q&A mechanism.
5. In summary, this Consultation Paper proposes amendments of Finrep reporting due to the IFRS 18 implementation, as well as other changes driven by the evolving supervisory data needs in accordance with CRR Article 430(5) and by the Commission’s goal of reducing costs associated with reporting requirements.
6. The first reporting reference date is expected to be 30 September 2027. However, a shorter consultation process with an earlier first reporting reference date is planned for the Finrep templates mainly affected by the IFRS 18 implementation (i.e. F 02.00, F 16.01, F 16.02, F 16.03, F 16.04, F 16.04.1, F 16.05, F 16.06, F 16.07, F 45.03, F 20.03). Indeed, the endorsed version of IFRS 18 has the same first application date of IASB’s IFRS 18 (i.e. 1 January 2027). Consequently, it is important that the publication of the final version of the IFRS 18-mainly affected templates occurs enough months in advance before the IFRS 18’s first date of application, to avoid any double/different reporting requirements with the institutions’ public financial statements. The enforcement of the temporary use of these templates until they are formally adopted by the EU Commission will be set out in an EBA Decision, which will also specify the first reference and remittance dates and the related technical package (Data Point Model, Taxonomy, validation rules) of these templates.    

1.1 Simplification and proportionality

7. One of the main drivers of the Finrep review is simplification and proportionality to contribute to the overall objective of reducing institutions’ reporting costs.
8. The simplification proposal set out in Finrep aims at striking a right balance between keeping information that are essential for conducting an effective supervision and deleting information that are deemed highly complex and granular by the industry.
9. Keeping this objective in mind, the simplification proposal set out in Finrep has been developed based on different inputs: i) the list of templates considered as less relevant for day-to-day use as identified under Recommendation 14 of the EBA Study of the cost of compliance with supervisory reporting requirements (Report eba/rep/2021/15)^[1]; (ii) feedback received from the Competent Authorities (CAs) and the EBA Staff using the data; (iii) data on the ‘usage’ of the templates provided by the ECB/SSM; (iv) feedback received by the industry in response to the last summer’s ECB stock-take .
10. Based on these inputs, the proposed simplification measures are modulated in accordance with the relevance of the information and move in different directions: i) reduction of data points and templates, ii) frequency and scope adjustments, iii) introduction of greater proportionality, notably for SNCIs, iv) integration and streamlining of separate data collections (in particular, EU-wide stress testing) into Finrep. More in detail, the proposed simplification measures are the following:
11. deleting templates that are mostly unused by supervisors, or the content of which mostly overlaps with other reporting requirements avoiding requesting duplicate information from institutions. In particular, the proposal envisages the deletion of the following templates:
    • template F 06.01 ‘Breakdown of loans and advances other than held for trading, trading or held for sale assets to non-financial corporations by NACE codes’ (and the corresponding template F 20.07.01 ’Geographical breakdown by residence of the counterparty of loans and advances other than held for trading to non-financial corporations by NACE codes’) since the information on the breakdown by NACE codes will be covered by the ESG reporting framework;
    • templates F 11.3, F 11.03.1 on non-derivative hedging instruments information under IFRS and NGAAP, considering its low usage at SSM level;
    • template F 13.2.1 ‘Collateral obtained by taking possession during the period [held at the reference date]’, considering the less supervisory relevance of this information in comparison with the information on collateral stock included in template F 13.03.1;
    • template F 21 ‘tangible and intangible assets: assets subject to operating lease’, whose information subject to a threshold is moved in template F 42 ‘Tangible and intangible assets: carrying amount by measurement method’, with an annual frequency.
    • template F 23.01 ‘Loans and advances: Number of instruments’, considering the low usage at SSM level;
    • template F 23.03 ‘Loans and advances collateralised by immovable property: Breakdown by LTV ratios’, given that similar information is already required in template F 18.02 ‘Commercial Real Estate (CRE) loans and in the new proposed collateral template F 37.00;
    • template F 23.05 ‘Loans and advances: Collateral received and financial guarantees received’, given that similar information is required in templates F 13, F 18 and in the new proposed collateral templates F 37 and F 48;
    • template F 23.06 ‘Loans and advances: Accumulated partial write-offs’ considering its low usage at SSM level;
    • template F 24.02 ‘Loans and advances: Flow of impairments and accumulated negative changes in fair value due to credit risk on non-performing exposures’, given that most of non-performing exposures are generally classified in stage 3 under IFRS 9, for which the information is reported in the template F 12.01 ‘Movements in allowances and provisions for credit losses’.
    • template F 24.03 ‘Loans and advances: Write-offs of non-performing exposures during the period on write-offs during the period’, considering the low usage at SSM level; however the information on debt forgiveness is moved in template F 24.01 ‘Loans and advances: Inflows and outflows of non-performing exposures’.
    • template F 25.03 ‘Collateral obtained by taking possession classified as Property Plant and Equipment (PP&E)’.  The information on the stock of the collateral obtained classified as PP&E is moved in template F 25.02 ‘Collateral obtained by taking possession: Type of collateral obtained’.
    • template F 30.02 ‘Breakdown of interests in unconsolidated structured entities by nature of the activities’, considering its low usage at SSM level, its inclusion in the list of least used template of the the EBA Study of the cost of compliance, and the maintenance of basic information on interests in unconsolidated structured entities in template F 30.01;
    • template F 31.02 ‘Related parties: expenses and income generated by transactions with’, considering its low usage at SSM level, its inclusion in the list of least used template of the the EBA Study of the cost of compliance, and the maintenance of basic information on amounts payable to and amounts receivable from related parties in template F 31.01;
    • template F 40.02 ‘Group structure: "instrument-by-instrument" and other control relationships’ considering its low usage at SSM level and its inclusion in the list of least used template of the the EBA Study of the cost of compliance;
    • template F 41.02 ‘Use of the Fair Value Option’ considering its low usage at SSM level.
    • template F 43.00 ‘Provisions’ considering its low usage at SSM level and the inclusion of similar information in institutions’ public financial statements, although the accounting scope of consolidation may differ from the prudential one. However, the information on provisions for pending legal issues and tax litigation and other type of provisions relevant for the calculation of own fund requirements for operational risk are moved in ad-hoc rows of template F 02 ’Statement of profit or loss’;
    • templates F 44.01 ‘Components of net defined benefit plan assets and liabilities’ and F 44.02 ‘Movements in defined benefit obligations’, considering their inclusion in the list of least used template of the the EBA Study of the cost of compliance and the fact that the information can be easily obtained by the institutions’ public financial statements. Indeed, the information corresponds to the requirements of IAS 19, and it has an annual frequency like the institutions’ public financial statements, although the accounting scope of consolidation may differ from the prudential one;
    • template F 45.01 ‘Gains or losses on financial assets and liabilities designated at fair value through profit or loss by accounting portfolio’ considering that the information is mostly covered by template F 16.05 ‘Gains or losses on financial assets and liabilities designated at fair value through profit or loss by instrument.
    • template F 47.00 ‘Average duration and recovery periods’ considering its low usage at SSM level.
12. restructuring and dropping some details, especially in NPL templates, with the aim of avoiding requesting similar information in different Finrep templates, while focusing more on the supervisory needs:

• templates F 07.01 and F 07.02 on ‘financial assets subject to impairment that are past due’ are revamped by focusing only on the essential information on loans and advances (rows 0120, 0170, 0180 and rows from 0200 to 0310) and dropping the information on debt securities, given that the information on past due breakdown of template F 18.00  may be used as ‘proxy’ of the information of templates F 07;
• in templates F 09.01.1 and F 09.01 on off-balance sheet exposures, the information on non-performing exposures is dropped considering that similar information is available in template F 18.00;
• in template F 15.00 ‘Derecognition and financial liabilities associated with transferred financial assets’, the breakdown is simplified by focusing only on the accounting portfolios;
• in templates F 22.01 and F 22.02 on ‘fee and commission income and expenses and the assets involved in the services provided’, the breakdowns are simplified by eliminating some details per specific fee and commission categories;
• in templates F 23.02 ‘Loans and advances: Additional information on gross carrying amounts’ and F 23.04 ‘Loans and advances: Additional information on accumulated impairments and accumulated negative changes in fair value due to credit risk’,  the information on loans measured at cost or at amortised cost is dropped since it should mostly overlap with the information of the total  of loans and advances also reported in these templates.
• in template F 24.01 ‘Loans and advances: Inflows and outflows of non-performing exposures’, some detail information (of which rows) within the inflows and outflows is dropped.
• in the template F 25.01 ‘Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E): Inflows and outflows’, the information  on ‘time passed since recognition in balance sheet’ is dropped, while it is kept for the stock of collateral obtained by taking possession in template F 25.02 ‘Collateral obtained by taking possession: Type of collateral obtained’.
• in template F 26.00 ‘Forbearance management and quality of forbearance’, the detail information on 'Gross carrying amount of non-performing forborne loans and advances that failed to meet the non-performing exit criteria' is dropped;
• in template F 30.01 ‘Interests in unconsolidated structured entities’, the information on fair value of liquidity support drawn is dropped since the information is similar to the one on liquidity support drawn reported in the same template;
• in template 41.01 ‘Fair value hierarchy: financial instruments at amortised cost’, the granularity of information on the level 3 fair value is reduced by requiring the values only for debt securities measured at amortised cost or cost. On the other hand, the frequency of this template is increased from annual to quarterly, as specified below under the paragraph on ‘other adjustments’ to Finrep.

13. reducing the frequencies where the information is still considered as relevant for supervisors, but it is not generally used in day-to-day supervisions. In particular:

• the frequency of template F 13.3.1 ‘Collateral obtained by taking possession accumulated’ is reduced from quarter to semi-annual, considering the generally low variability of this information;
• the frequency of template 15 ‘Derecognition and financial liabilities associated with transferred financial assets’ is reduced from quarter to annual;
• the frequency of templates 17 ‘Reconciliation between Accounting and CRR scope of consolidation: Balance Sheet’ is reduced from quarterly to semi-annual;
• the frequency of template 30.01 ‘Off-balance sheet activities: Interests in unconsolidated structured entities’ is reduced to from semi-annual to annual;
• the frequency of template F 31.01 ‘Related parties: amounts payable to and amounts receivable from’ is reduced from semi-annual to annual;
• the frequency of the information on assets subject to operating lease moved in template F 42 is reduced from quarterly to annual.

14. increasing proportionality for reporting of information on derivatives (templates F 10 and F 11) and on geographical breakdowns (templates F 20), given that the information is extensively used for supervisory analysis, but the templates are generally deemed highly complex and burdensome by the industry:

• in templates F 10 and 11 on derivatives, the introduction of proportionality for small and non-complex institutions (SNCI) aims at alleviating their reporting costs linked to the granularity of the information requested. The relative threshold for SNCI is built on the basis of the one provided by the CRR (Article 4 (145)(e)) to facilitate the monitoring by institutions;
• in templates F 20 on geographical breakdown, the introduction of an additional layer of proportionality to group all exposures lower than 1% towards countries under the z-axis ‘Other countries’. A specific question is included in this consultation to know whether the proposal may effectively help alleviate institutions’ reporting costs.

15. introducing a ‘core and supplement approach’, as suggested by the 2021 EBA Cost of Compliance report. In accordance with this approach, the templates currently included in Part 1 of Finrep with the exceptions of templates F 15 and 17 and including templates F 20 and F 22 are proposed to be the ‘core part’ (applicable to all institutions), and the rest of the templates in Parts 2, 3 and 4 with the exceptions of templates F 20 and F 22 and including templates F 15 and 17 are proposed to be reported by institutions other than SNCI (‘supplement part’).
16. integrating other reporting in Finrep and discontinuing ad-hoc data collection. Specifically, data points to meet the EU-wide stress testing data needs would be added, notably in templates F 16.03 on gains or losses on trading financial activities, F 16.08 on other administrative expenses, F 44.04 on staff expenses and including new templates F 49.01, F 49.02 and F 50.00 for credit risk and market risk stress test purposes respectively. The proposed changes are further explained in the separate CP on stress test data needs. Moreover, the inclusion of the information on ‘overlays’ in template F 12.01 allows to get information relevant for supervision as further explained in the paragraph below on ‘Other adjustments’ and at the same time it will allow to discontinue a corresponding ECB ad-hoc data collection to significant institutions. In addition, the adjustments to the columns of template F 44.04 on staff expenses allow to be aligned with the respective Pillar 3 disclosures information and, at the same time, a corresponding ECB ad-hoc data collections to significant institutions will be discontinued.
17. revamping the structure of the templates and related instructions with the aim of helping users read and navigate across templates, legal references and instructions. Notably, after this public consultation, the templates and the related instructions will be grouped into modules in relation to the different topics. The new index will include all the relevant information (core/supplement, frequency, proportionality) for each template and an ad-hoc Excel file will include all the legal references per template, row, column to facilitate the identification of the relevant information. The instructions will be reshaped by renumbering and putting the paragraphs in the right order in line with the templates. Indeed, in this consultation, the instructions to new templates have been put in the end in order not to change the numbers of the existing paragraphs and  the references in the columns and rows of all the templates.

1.2 Rationale and content of reporting changes topic by topic

1.2.1 IFRS 18: implementation in Finrep

IFRS 18: new banks’ structure of statement of profit or loss 

18. In April 2024, the IASB issued the accounting standard IFRS 18 'Presentation and Disclosure in Financial Statements', which replaces IAS 1 with a focus on the Statement of profit or loss. The new standard has been endorsed by Commission Regulation (EU) 2026/338 and it will apply for reporting periods beginning on or after 1 January 2027. The aim of the new standard is to increase comparability of the financial performance of similar entities, especially in relation to the definition of 'operating profit or loss’.
19. IFRS 18 introduces a defined structure for the statement of profit or loss, which is composed of five categories, three of which are new – operating, investing, financing, and of mandatory subtotals. IFRS 18 sets out detailed requirements for entities to classify the items among these categories.
20. IFRS 18 takes into account the specific characteristics of entities whose main business activities are providing financing to customers and/or investing in assets (retail and investment banks) by requiring classifying additional income and expenses in the ‘Operating category’ that would otherwise be classified in the investing or financing categories.
21. Following the new standard, each bank shall assess, based on its specific facts and circumstances, whether its investments in financial or non-financial assets represent its main business activities or not and it shall classify accordingly the income and expenses in the three new categories (operating, investing and financing).
22. The operating category shall include all the income and expenses related to the main business activities of the institution.
23. The investing category includes income and expenses relating to investments in assets that are not considered as  main business activities, as well as the results of associates, joint ventures and unconsolidated subsidiaries accounted for using the equity method (IFRS 18.55(a)).
24. The financing category includes income and expenses from liabilities arising from transactions that do not involve only the raising of finance (IFRS 18.59(b); IFRS 18.61; IFRS 18.B53-B54), like interest expenses on lease liabilities, the increase in the discounted amount of a provision arising from the passage of time, net interest expense (income) on a net defined benefit liability (asset) applying IAS 19.
25. Regarding the income and expenses from cash and cash equivalents and from liabilities arising from transactions that involve only the raising of finance, IFRS 18 allows banks to classify them outside the operating category, provided that these income and expenses do not relate to the bank’s main business activity of providing financing to customers. However, in case of a retail and investment bank which also invests in financial assets   as main business activity, all income and expenses from cash and cash equivalents and from financing liabilities are presumably classified   in the operating category.
26. IFRS 18 provides also guidance for the classification of income and expenses arising from hybrid contracts, income and expenses arising from derecognition and changes in classification, foreign exchange differences, and gains or losses on derivatives and hedging instruments. In such circumstances, the general principle is the classification of the income and expenses in the same category of the income and expenses to which they refer. For banks, this implies that most of these items should be classified in the operating category.
27. IFRS 18 eventually provides for two new mandatory subtotals on the face of Statement of profit or loss: ‘operating profit or loss’ and ‘profit or loss before financing and income taxes’.  However, the latter shall not be presented if a bank chooses to classify income and expenses from all financing liabilities in the operating category (IFRS 18.73 and IFRS 18.BC189). Additional items and subtotals can be included if such presentations are necessary for a primary financial statement to provide a ‘useful structured summary’ of the institution’s income and expenses (IFRS 18.24).

Proposed changes to the Finrep templates

28. The Finrep statement of profit or loss is reshaped with the aim of minimizing the impact of the IFRS 18 implementation by requesting, to the extent possible, the same level of information as today, while ensuring a standardised presentation for all banks. To this end the main business activities of an investment and retail bank are considered as benchmark for reshaping the statement of profit or loss, in line with the IFRS 18 Illustrative Example II-4 ‘Statement of profit or loss for an entity that is an investment and retail bank that invests in financial assets as a main business activity and provides financing to customers as a main business activity’ (IFRS 18, IE 13).
29. Following the benchmark model of a retail and investment bank, the income and expenses related to investments in subsidiaries, joint ventures and associates, investments properties and other non-financial assets (different from property, plant and equipment) are moved in the investing category.
30. In the operating category, the content and the labels of some items are reviewed to clarify that they only include income and expenses related to the main business activities of an investment and retail bank.
31. In the investing category, the income or expenses are grouped in the following new items: i) ‘Income or (-) expenses on investments in subsidiaries, joint ventures and associates’; ii) ‘Income or (-) expenses on investment properties and other non-financial assets’, and iii) ‘Income or expenses on investing financial assets’. The first two items mainly bundle income and expenses moved from the operating category, while the latter is added to deal with any (rare) situation where a bank only provides financing to customers but it does not invest in financial assets as main business activities.
32. In the financing category, the new item of ‘Income or (-) expenses on non-operating liabilities’ shall include income and expenses arising from liabilities that are not related to the bank’s main business activities.
33. Regarding the IFRS 18 other requirements on derivatives and hedge accounting, foreign exchange differences, hybrid contracts, derecognition and change in use, most of the related income and expenses should refer to items in the bank’s operating category. For this reason, the existing relevant rows of template F 02.00 are kept under the operating category. This approach aims at ensuring continuity with the past. However, should these income and expenses refer to items outside the operating category, Finrep instructions specify that banks shall report these income and expenses in new residual rows (i.e. ‘other income or expenses on investing non-financial assets’; ‘income or expenses on investing financial assets and on any related financial instruments’; ‘income or expense on non-operating liabilities’) created under the new categories of investing or financing, as appropriate.
34. A similar approach is adopted to deal with any situation where banks’ main business activities deviate from those of an investment and retail bank used as a benchmark for reshaping template F 02.00. For example, if a bank assesses that its investments in non-financial assets (like commodities or carbon credits) are part of its main business activities, the related income and expenses shall be included in the residual items of ‘Other operating income/expense’. Furthermore, in case where a bank only provides financing to customers and it  does not invest in financial assets as a main business activity, the income and expenses related to the investment in financial assets will be presented in the residual row of ‘income or expenses on investing financial assets and on any related financial instruments’ under the investing category, rather than in the specific rows of the operating category.
35. Regarding the subtotals of template F 02.00, in addition to the inclusion of the IFRS 18 mandatory subtotal of ‘Operating profit or loss’, the existing ‘Total operating income, net’ is replaced by ‘Net intermediate income’, and the subtotal ‘Operating and investing profit or loss’ is added to provide a ‘useful structured summary’ of the institution’s income and expenses.
36. Templates F 16 and F 45 are also reviewed to reflect the changes of IFRS 18. Specifically, columns for the new categories of operating, investing and financing are added to allow banks to report the same level of information as today, regardless of where the information is presented in the statement of profit or loss. The aim is to keep the same level of granularity as today, regardless of the banks’ assessment of main business activities. Therefore, even when the information is aggregated and presented in the new residual items of the template F 02, institutions shall keep reporting the details of the information as today in templates F 16 and F 45.
37. As per article CRR 430(9), Finrep also includes templates and instructions for reporting financial information under national Generally Accepted Accounting Principles (GAAP) in accordance with Directive 86/635/EC (BAD).  The changes to the Finrep framework stemming from IFRS 18 do not have any major impact for NGAAP reporters based on BAD (‘non-IFRS compatible). Therefore, NGAAP reporters non-IFRS-compatible will continue to present the information on income and expenses as today, in accordance with the provisions of the applicable Banking Accounting Directive (BAD).
38. The following table shows a reconciliation between the current rows of Finrep template F 02.00 with the rows of the proposed Finrep template F 02.00 due to the IFRS 18 implementation to facilitate the reading of the changes.
     

1.2.2 Collateral additional information

39. In the context of the regular Credit Risk Supervisory Review and Evaluation Process (SREP), supervisors have further investigated the role of collateral as credit risk mitigator and they have identified a lack of comparability and consistency in the collateral data collected, as well as differences in recovery rates across institutions and across member states, mainly due to differences in jurisdiction frameworks, prudential requirements, valuation and accounting practices.
40. The proposal for changes to the ITS aims at strengthening supervisors’ ability to assess and monitor the quality of collateral, enabling a more focused benchmarking and identifying any institutions’ weak risk management practices related to collateral.
41. To this purpose, the amended reporting requirements envisage the following elements:

• enhanced definition of ‘maximum amount of the collateral that can be considered’;
• separation of the information on collateral and guarantee received between performing and non-performing exposures;
• enhanced information on LTV for commercial real estate (CRE) loans;
• new information on real estate collateral and guarantees received, with a breakdown by past-due days buckets of relevant non-performing exposures and a breakdown by type of real estates, information on the weighted average of haircuts applied to the collateral value and a breakdown by valuation methods used for collaterals received.

42. The definition of ‘maximum amount of the collateral that can be considered’ is improved to clarify that institutions shall refer to the latest available collateral value that is used for the purpose of impairment calculation, after the application of any haircut by them, and in accordance with the applicable accounting framework, as well as with any applicable guidance issued by the relevant Competent Authority. This enhanced definition is included in the instructions to Finrep reporting and it should foster consistency in the collateral valuation and then increase the reliability of data reported by institutions.
43. Template F 13.01 ‘Breakdown of collateral and guarantees by loans and advances other than held for trading’ is split into two templates (F 13.01.1 and F 13.01.2) to distinguish the information between performing and non-performing exposures. This separation addresses the issue of current limited data available for non-performing exposures, for whom a more granular analysis of collateral received is particularly important for the calculation of impairment and of recovery rates.
44. In template F 18.02 ‘Commercial Real Estate (CRE) loans and additional information on loans secured by immovable property’, the information on ‘loans for which LTV ratio is not available or cannot be calculated’ is added to distinguish these cases from loans where the LTV is below 60%. Indeed, supervisors have observed that some institutions do not have the LTV data readily available yet for the reporting dates, and in case any LTV data is not available/cannot be calculated, the current structure of the template suggests that for this part of the loan portfolio the LTV is below 60% which might be false.
45. The information on real estate collateral and guarantees received is included in two new templates: F 37.00 ‘Additional information on real estate collateral and financial guarantees received on non-performing loans’ with semi-annual frequency, and F 48.00 ‘Breakdown of real estate collateral received by type of valuation and by type of valuer- non-performing loans’ with annual frequency.
46. These new templates provide further insights into the quality of real estate collateral and guarantee received on non-performing exposures and a comprehensive view on the coverage of different types of real estate collaterals. Specifically, in template F 37.00, the request of more granular information on different types of real estate collaterals and its breakdown by past-due days buckets of related non-performing exposures will allow supervisors to obtain information on the different levels of collateral liquidity and identify the collateral that is potentially not recoverable anymore. In addition, the information on the weighted average of haircuts applied by institutions, broken-down by type of real estate collaterals helps identify any discrepancies between the level of haircuts and their recovery rates. Template F 48.00 completes the analysis of collateral by providing further insights into the valuation methods applied and the types of valuer (internal or external) used for the real estate collateral valuation.
47. Proportionality is implicit in the new reporting requirements that are triggered by the lending activities in the real estate sector carried out by institutions. In addition, the new information on real estate collateral and guarantees received is proposed to be reported by institutions other than small and non-complex institutions to limit the reporting efforts for the latter.

1.2.3 Information on other financial corporations 

48. Non-Bank Financial Intermediation comprises various financial sectors including both regulated and unregulated entities, such as asset management companies and investment funds, non-bank investment firms, pension funds, insurance companies, and other financial intermediaries.
49. Banks and non-bank financial intermediaries (NBFI) are closely interlinked, with increasing tendency across many instruments (e.g. debt securities, equity instruments, loans, deposits, derivatives) that might be a source of vulnerability in times of turmoil.
50. As of December 2023, EBA estimates the asset exposure of banks towards NBFI at 9.2% of total assets (EUR 2.5 trillion), while the liability exposure of banks towards NBFI funding at 10.3% of total assets (EUR 2.8 trillion). This is also reflected in off-balance sheet exposures, with undrawn loan commitments, financial guarantees and other commitments extended to NBFIs amounted to 6.4% of all EU/EEA banks off-balance-sheet items, while those received from NBFIs amounted to 9% of all EU/EEA banks off-balance-sheet items^[2].
51. In 2024, the European Commission conducted a consultation on risks and vulnerabilities posed by NBFI and the adequacy of the related macroprudential policies. The results of this consultation were published in March 2025^[3]. Regarding the interlinking between banks and NBFI, several respondents to this consultation stressed the importance of effective supervision and data sharing to monitoring emerging risks from interconnectedness. Some national and EU public authorities suggested that greater transparency and data collection on NBFI-bank interactions is needed to monitor emerging risks effectively.
52. The current reporting data on banks’ exposures towards NBFI and their granularity are very limited and further requests of data by the Commission to the European Supervisory Authorities (ESAs) are expected to properly monitor the phenomenon in the upcoming years.
53. Against this background, new reporting requirements are introduced in Finrep. Nevertheless, simplification and proportionality are considered in developing the new templates by focusing only on the information that is strictly necessary for supervisory purposes.
54. In particular, the three new templates include minimum information on banks’ financial assets, financial liabilities and off-balance sheet items towards ‘other financial corporations’, broken-down by type of subsectors and by classes of instruments. In addition, the information on the exposures towards those financial corporations that are primarily involved in private credit activities, such as private credit funds or business development companies (BDCs) is included.
55. In order to facilitate the implementation of the new templates and alleviate the related reporting efforts for institutions, the breakdown by subsectors of ‘Other financial corporations’ is based on the current definition of ‘Other financial corporations’ included in the IT solutions to the ITS on reporting (Annex V, Part 1, par 42(d)), while the breakdown by classes of instruments is largely based on the information currently reported in the templates F 04 ‘Breakdown of financial assets by instrument and by counterparty sector’, F 08 ‘Breakdown of financial liabilities’ and F 09 ‘Loan commitments, financial guarantees and other commitments’.  .
56. The new templates are proposed to be requested with the same quarterly frequency of the existing templates F 04, F 08 and F 09. Proportionality is considered by requiring these new templates to institutions other than small and non-complex institutions, when their financial assets towards ‘other financial corporations’ exceed the threshold of 5% of their total financial assets. The threshold of 5% has been calibrated considering the bank’s reporting data as of December 2024 and it would allow to cover almost the total institutions’ exposures to NBFI, excluding smaller banks and banks with limited exposures to NBFI.

1.2.4 Information on crypto-assets

57. Since 2024, supervisors have raised the need of data on digital transformation to properly monitor the relevant emerging risks for institutions, specifically regarding investments in crypto-assets.
58. Although there is not a legal or commonly accepted definition of crypto-assets, the latter  commonly refer to instruments characterized by the use of ‘blockchain technology’ including, for example, Bitcoin, Ethereum, stablecoin, asset token, utility token. This technology can support various rights and obligations of the holder that are reflected in different possible accounting treatments of crypto-assets in the financial statements.
59. The IFRS Interpretations Committee (IFRS IC) has given some directions for the accounting treatments of those crypto-assets that meet the following conditions^[4]:

• they are digital or virtual currencies recorded on a distributed ledger that uses cryptography for security;
• they are not issued by a jurisdictional authority or other parties;
• they do not give rise to a contract between the holder and another party.

60. For this type of crypto-assets, the IFRS IC excludes the possibility of considering them as cash or cash equivalent or as financial instruments but believes that they meet the definition of an intangible asset. Therefore, the entities can apply the accounting standard IAS 38 ‘Intangible assets’ or in case of crypto-assets held for sale in the ordinary course of business, the accounting standard IAS 2 ‘Inventories’.
61. Regarding other types of crypto-assets, in lack of a specific accounting standard, the guidance included in IAS 8 ‘Basis of preparation of financial statements’ should be followed and an analysis of the underlying rights and obligations linked to the holding of the crypto-assets is needed to determine the appropriate accounting treatment. For example, some stablecoins might meet the definition of a ‘financial asset’ if they give the holder a right to receive cash or other financial assets, and so they should be accounted for under IFRS 9, while ‘utility tokens’ that give the holder a right to access to future goods or services might meet the definition of an intangible asset of IAS 38.​
62. Against this background,  basic information on the institutions’ level of activities in crypto-assets is included in Finrep, while considering the overarching principle of simplification and proportionality In particular, new rows are added in templates in F 22.01 ‘Fee and commission income and expenses by activity’ and in F 22.02 ‘Amount of assets involved in the services provided’ for the crypto-assets services as defined in Regulation (EU) 2023/1114 on markets in crypto-assets (MICAR). A new template F 38 ‘Information on crypto-assets’ is proposed to add to cover information on the different accounting portfolios where the crypto-assets can be allocated.
63. In the new template, crypto-assets are classified into the following three categories:

• Electronic money token (EMT) as defined by the Regulation (EU) 2023/1114 on markets in crypto-assets (MICAR);
• Asset-referenced token (ART) as defined by the Regulation (EU) 2023/1114 on markets in crypto-assets (MICAR);
• Other crypto-assets, different from EMT and ART, like stablecoins not compliant with MICAR and crypto-assets out of the scope of MICAR, such as ‘utility token’ and ‘security token’ when they qualify as financial instruments as defined in the Directive 2014/65/EU (Mifid).

64. The template also includes information on crypto-assets compliant with IFRS-IC definition and on derivatives with underlying crypto-assets, to give a complete picture of the institution’s exposures to crypto-assets.
65. Proportionality is implicit in the new reporting requirements that are triggered by the activities in crypto-assets carried out by institutions. In addition, the new template is proposed to be reported by institutions other than small and non-complex institutions, with a semi-annual frequency.

1.2.5 Other adjustments

66. Other adjustments to the templates and related instructions are driven by different needs:

• regularly update of the reporting requirements when the underlying legal framework changes;
• experience in using financial information for supervision purposes;
• experience with data quality and feedback from institutions compiling data.
• incorporation of guidance and clarifications coming from Q&As published on the EBA website where relevant for a more complete and seamless application of the single rulebook;

67. Regarding the adjustments due to changes of the underlying legal framework, in template F 01.01 ‘Assets’, goodwill is now reported separately from the ‘intangible assets’ in accordance with the provisions of IFRS 18.
68. In templates F 03 ‘Statement of comprehensive income’ and F 46 ‘Statement of changes in equity’, information on equity instruments measured at fair value through other comprehensive income is added to implement the amendments to IFRS 7, paragraphs 11A (f) and 11B (d) on disclosures of equity instruments measured at fair value through other comprehensive income. These amendments were issued by the IASB in May 2024 and endorsed by the European Commission in May 2025 with first application for reporting periods beginning on or after 1 January 2026. However, the first application date of these changes in Finrep will be aligned with the first reference date of the rest of Finrep package.
69. In the general instructions to Finrep (IT solutions – Annex V, Part 1, paragraph 5 (i)), the definition of ‘micro, small and medium-sized enterprises’ (‘SME’)’ is changed to consider the CRR3 definition that is also used in Corep. In addition, in the instructions to template F05.01 ‘Loans and advances other than held for trading, trading or held for sale assets by product’, the definition of ‘specialised lending’ is specified by including project finance, object finance, commodity finance and income-producing real estate (IPRE), in line with the amendments to the CRR article 147(8). Finally, in the instructions to templates F 09 on loan commitments, financial guarantees and other commitments, the legal references and the wording are adjusted to consider the CRR 3 amendments to Annex I and the CRR article 111 (4).
70. Regarding the changes linked to the experience in using Finrep for supervision purposes, in template F 12.01 ‘Movements in allowances and provisions for credit losses’, the information on overlays is added. Overlays are defined as post-model adjustments for the estimation of expected credit losses under IFRS 9. They became common practice during the Covid-19 crisis, and now they are extensively used to cover novel risks like energy supply, supply chains in general, environmental risks, inflation and geopolitical risks, not easily captured by IFRS 9 models. The introduction of minimum information on overlays in Finrep will therefore allow supervisors to better monitor the modelling aspects of IFRS 9 ECL calculation and their related impact on credit risk allowances, while considering the overarching principle of simplification.
71. In template F 18.00 ‘Non-performing exposures’, information on loans subject to public Guarantee Scheme (PGS) is added. The PGS became common practice during the Covid-19 crisis when the relevant data on PGS were also collected. After the Covid-19 pandemic, the data collection on PGS was stopped. Notwithstanding, some member states have started to set up PGS to face emerging risks, like those related to energy crisis and to the breakout of the Russian war. The introduction of essential information on loans subject to PGS in template F 18.00 aims at giving supervisors indications on the impact of these measures on the institutions’ lending activities and the related asset quality, while considering the overarching principle of simplification.
72. In templates F 40 on ‘Group structure’, the information on ‘type of code’ is enhanced by providing a hierarchy of pre-defined detailed code lists to be used when entities’ LEI codes are not available. The aim of this enhancement is to facilitate the integration with statistical reporting and ESCB/SSM datasets and improving the data quality.
73. In template F 41.01 ‘Fair value hierarchy: financial instruments at amortised cost’, information on the carrying amount of hedging derivatives in offsetting unrealized losses or gains on the hedged instruments is added. This information is particularly relevant in the context of current volatility in interest rates—both upward and downward movements where supervisors have a recurring need to monitor unrealised gains and losses. For this reason, the frequency of this template has been also increased from annual to quarterly.   
74. Finally, the following table summarize the Q&As published that are incorporated in the proposal of Finrep review and other adjustments related to the experience with data quality and feedback from institutions compiling data, notably the extra data quality checks (EGDQ) regularly published by ECB.

75. IFRS 18 has been endorsed by Commission Regulation (EU) 2026/338and it will be mandatory for public consolidated financial statements of institutions using the IFRS from the reporting periods beginning on or after 1 January 2027.
76. The timely implementation of IFRS 18 in Finrep would significantly reduce the risk of double or divergent reporting for IFRS institutions, as also highlighted by EFRAG in its endorsement advice to the EU Commission in May 2025: “For financial institutions, the costs to be incurred, both one-off and ongoing, depend entirely on the level and timing of potential harmonisation of the local regulatory requirements with those of IFRS 18. Financial institutions are subject to Finrep reporting requirements. Unless FINREP is harmonised with IFRS 18, they would be subject to different reporting requirements/double reporting requirements.
77. Considering the timing of the introduction of the changes to the overall Finrep reporting, a shorter one-month public consultation is provided for the templates and instructions mainly affected by the IFRS 18 implementation (i.e. F 02.00, F 16.01, F 16.02, F 16.03, F 16.04, F 16.04.1, F 16.05, F 16.06, F 16.07, F 45.02, F 45.03, F 20.03), with the aim of publishing the final version of these templates and related instructions over the summer 2026, although their formal adoption by the EU Commission will follow the whole ITS. This should reduce the risk of double or divergent reporting for institutions implementing IFRS 18 in their public consolidated financial statements from the reporting periods beginning on or after 1 January 2027.
78. An EBA decision will be published to specify the enforcement of the temporary use of these templates until the formal adoption by the EU Commission, together with clarifications on the first reference and remittance dates and the related technical package (DPM, taxonomies, validation rules) for the IFRS 18-mainly affected templates.

3 Accompanying documents

3.1 Draft cost-benefit analysis / impact assessment