The EACB welcomes the EBA’s initiative to carry out an holistic review of the reporting framework. We acknowledge the significant work carried out by the EBA in seeking practical ways to reduce unnecessary burden for institutions, and support the objective to achieve a more balanced supervisory reporting framework. The ITS is also one of the first concrete regulatory products on prudential simplification, giving to it an additional relevance.
In our feedback, we stress the relevance of ensuring stability of the framework. Frequent changes to reporting requirements require adaptations to IT systems, validation processes, internal controls, governance arrangements, and major adjustments should only be implemented when requirements are operationally clear.
We also see the necessity to postpone the implementation date of certain requirements that are not sufficiently mature, clarify ambiguous definitions and instructions, ensure consistency with other reporting frameworks, and avoid introducing new recurring reporting obligations. On a final point, particular attention should be paid to the practical design of proportionate reporting, in particular for SNCIs and LSIs, for which some of the proposed changes may not lead to meaningful burden reduction.
We encourage the EBA in continuing its work on simplification of reporting and, more generally, of the prudential framework.