After reading through Annex V on FINREP (specifically Part 2.308), the reporting template and the relevant accounting standards (IAS 19.63, IAS.19.64, IAS.19.65, IAS.19.140(a) and importantly also the definition of net defined benefit liability (asset) at the start of IAS 19, we reach the conclusion that, row 0090 should contain the sum of all schemes in surplus (the net position should be applied on a scheme-by-scheme basis). Whereas row 0100 should contain the sum of all schemes in deficit (also following from Annex V Part 2.9, which indicates that this item includes the amount of net defined benefit liabilities). Therefore, net defined benefit liabilities and assets should be reported separately, and the “net” should be applied on a scheme-by-scheme basis. It appears that some banks are populating this row differently across the SSM. It would be useful if the FINREP instructions (and validation rules) could be updated to clarity what actual information is required in row 0090 of F44.01 for Net defined benefit assets [Carrying amount].