Question ID
2023_6717
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex V
Type of submitter
Credit institution
Subject matter
Finrep Templates 44.03 and 44.04
Question

In template 44.3 Staff expenses by type of benefits , in row 0050 Severance payments are requested. For the whole template the following validation rule applies: v3988_s: {F 44.03} >= 0 (for all rows and with severity level error). This is suggesting severance payments can never be a negative amount, which we believe is not always the case (as a result of reviewing HR restructuring provisions as well as discounting effects of long term employee benefits. The same applies for template 44.04 other staff expense except remuneration (r0030 / c0010), where the amounts reported in 44.3 r0050/c0010 are reported, too. A positive amount reported in this item leads to the violation of the rules v8106_m and  v8364_s. Can you please amend the Validation rule by excluding the items 44.3 r0050/c0010 and 44.4 r0030/c0010 from these rules?

Background on the question

In Table Staff expenses by type of benefits (44.3) in the item “Severance Payments” (r0050/c0010) need to be reported payments relating to the early termination of a contract and this item shall include termination benefits as defined in IAS 19.8.

IAS 19.8 includes - among others - other long-term employee benefits and termination benefits, which are employee benefits provided in exchange for the termination of an employee’s employment.

As of 31 December 2022 the item above is an income,  as it includes:

(i) HR restructuring  provision review (+15€/m)

(ii) update of related discounting of HR liability relating to long term employee benefits (+15 €/m).

The income reported in item “Severance Payments” violates the below mentioned validation rules related to items in table 44.3 r0050/c0010 and in table 44.4 r0030/c0010 :

v8106_m

v8364_s

v3988_s

As from our point of view the effects of HR restructuring  provision review and the update of related discounting of HR liability relating to long term employee benefits fall under the definition of  IAS19.8, we ask to allow in the items in table 44.3 r0050/c0010 and in table 44.4 r0030/c0010 not only a negative but also a positive sign.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the matter it refers to has already been identified and will be considered for a forthcoming release of the respective validation rules.

Status
Rejected question