Question ID
2025_7659
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
ITS on Supervisory Reporting – Reporting Framework 4.2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
ITS on Supervisory Reporting – Reporting Framework 4.2
Type of submitter
Credit institution
Subject matter
FINREP Validation rules v23845_h, v23846_h, v23847_h
Question

Could the EBA clarify the rationale for excluding rows 0015, 0185, and 0365 from the new validation rules for template F 12.01.a?
This change creates inconsistencies with cross-template validation rules such as:

  • v6030_m: {tF_12.01.a, r0010, c0100} - {tF_12.01.a, r0015, c0100} = {tF_04.03.1, r0180, c0050} + {tF_04.04.1, r0140, c0050}
  • v6033_m: {tF_12.01.a, r0180, c0100} - {tF_12.01.a, r0185, c0100} = {tF_04.03.1, r0180, c0060} + {tF_04.04.1, r0140, c0060}
  • v6036_m: {tF_12.01.a, r0360, c0100} - {tF_12.01.a, r0365, c0100} = {tF_04.03.1, r0180, c0070} + {tF_04.04.1, r0140, c0070}

These rules assume that rows 0010, 0180, and 0360 include “Cash balances at central banks and other demand deposits.”


Additionally, the items “of which: collectively measured allowances” and “of which: individually measured allowances” will no longer consider these balances because the related rules (v5054_m, v5055_m, v5056_m) reference rows 0010, 0180, and 0360 only.

Could the EBA confirm whether this exclusion is intentional and, if so, provide guidance on how to reconcile these templates and validation rules?

Background on the question

The previous validation rules v5554_h, v5555_h, and v5556_h applicable to template F 12.01.a have been replaced by new rules v23845_h, v23846_h, and v23847_h.
The new rules are defined as follows:

  • v23845_h: {r0010} = {r0020} + {r0080}
  • v23846_h: {r0180} = {r0190} + {r0250}
  • v23847_h: {r0360} = {r0370} + {r0430}

Unlike the previous rules, these do not include rows 0015, 0185, and 0365 (“Cash balances at central banks and other demand deposits”).

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 targeted update ('hotfix') of the technical package for reporting framework version 4.2. in January 2026.

Status
Rejected question