The European Banking Federation (EBF), the European Association of Co-operative Banks (EACB), the European Association of Public Banks (EAPB) and the European Savings and Retail Banking Group (ESBG), representing the entirety of the European banking industry, have individually submitted responses to the EBA consultation on the feasibility of an integrated reporting system for regulatory reporting. The banking associations stress how critical it is to improve the efficiency of reporting in Europe. The banking industry has been calling for the creation of an integrated and standardized framework for data reporting in order to improve the quality of data while reducing the reporting burden for the industry without reducing the information content for authorities.
The banking associations welcome the work done by the EBA, in coordination with all other relevant authorities, towards the assessment of the feasibility of such integrated reporting system for collecting statistical, resolution and prudential data. Banks in Europe are strongly committed to working together and to working with all authorities to turn this vision into reality ensuring the new system is feasible for both authorities and industry. While dialogue takes place towards identifying the most suitable way forward, we encourage the EBA to continue giving proportionality the required relevance in the discussion.
An efficient solution needs to be built around the following principles:
- Define Once: using a single data dictionary with all the data definitions.
- Report Once: enhancing reusability and interoperability of the data.
- Share Information: amongst the authorities instead of asking several times for data that has been already provided.
- Enhanced Governance: including the advice of the industry as the main stakeholder in every new data request.
Furthermore, the banking industry calls authorities to target as first concrete action the establishment of the Joint Committee, with involvement of the industry, to begin steering the main aspects of the integrated reporting system. A timely and proper functioning of the Joint Committee is key to move the project forward and start assessing all technical aspects with the development of a single EU data reporting dictionary. This is the cornerstone of an integrated and standardized EU framework, and therefore the top priority. Any further step should also aim to provide a long-term timeline to facilitate the assessment of the impact of the proposal.
The industry appreciates the complexity and long-term perspective of such an ambitious project. At the same time, we believe it is time to put all efforts to work towards a streamlined system.
For more info on the topic, read our our comments on the EBA DP on a Feasibility Study of an Integrated Reporting System under Article 430c CRR.