We appreciate the idea to collect feedback at an early stage of development, before consulting on the detailed ITSs that will specify the technical solutions on which the P3DH will be based.
We support the overall goal of facilitating access, usability and comparability of prudential information and contributing to a holistic EU data strategy which strives to improve efficiency of reporting across financial sectors. However, we see that several aspects of the upcoming P3DH remain unclear or difficult to grasp from the point of view of their practical implications.
For instance, the “validation” process for the Pillar 3 data derived from supervisory reporting (i.e. for smaller banks) is unclear, while it should be fully spelled out what is deemed to be public and what is supervisory information.
Moreover, the “validation” process needs clarification also for large banks that would have to submit their Pillar 3 to EBA for the EBA to centralise the publication. Regarding the concept of a “technical acceptance” by the institutions before the data will be externally published by the EBA via the EBA EDAP, this would mean extra workload. The institutions already approve the delivered files in the P3DH before the EBA transfers them internally from the P3DH to the EBA EDAP. Therefore, the EBA should be responsible for this internal transfer and the publication in the EBA EDAP (technical process within the EBA). Another example is the written attestation. There should still be the possibility to publish it within the Pillar 3 report.
Some members also noted a technical issue (in terms of mapping, available technical solutions etc.) in the transition to a mandatory XBRL format – although this may be dependent on Member State.
Finally, the hub would also create a wider information platform that may require a lot more explanatory efforts from institutions vis à vis a potentially higher number of stakeholders.