The Biggest Reporting Overhaul Since DPM 1.0

The current supervisory reporting framework—built on ITS for COREP and FINREP, stress testing, and supervisory benchmarking—was architected in the mid-2010s and refined incrementally through CRR2, CRD IV amendments, and ad-hoc supervisor requests. Institutions today face a fragmented landscape: regular supervisory reporting (COREP/FINREP) on one quarterly/annual cycle, stress testing (annual) with overlapping data requirements, and supervisory benchmarking (ad-hoc) pulling the same underlying exposures through separate channels.

The EBA's April 2026 consultation proposes to tear this apart and rebuild it. The revised ITS on supervisory reporting and supervisory benchmarking reporting will: remove "nice to have" data points, integrate stress testing and benchmarking reporting into the regular framework, strengthen proportionality for smaller institutions, align with IFRS 18 changes to FINREP, incorporate ESG risk into prudential reporting, and harmonise with DPM 2.0 (Data Point Model version 2.0) infrastructure standards and the JBRC (Joint Bank Reporting Committee) technical specifications.

This is not a tweak. It is a fundamental redesign of how supervisory data flows from banks to the regulator. For large institutions, it is a material systems project. For SNCIs, it is a potential simplification—or a pitfall if they do not actively shape the definitions of "core" vs. "supplement" requirements during the consultation window.

Consultation closes 10 July 2026: This window is critical. The EBA is actively seeking feedback on the scope, feasibility, and technical specifications. Institutions that remain silent cede the design to other voices. Those that respond with detailed impact analysis and implementation concerns will shape the final standard.

What's Actually Changing: Five Pillars of Simplification

1. Removal of "Nice to Have" Data Points (16% Direct Reduction in ITS)

Under current ITS, supervisors request data on many exposures and risk metrics that are intellectually interesting but operationally duplicative. For example, many COREP templates require counterparty exposure breakdowns by regulatory classification (e.g., central governments, credit institutions, corporates, etc.) alongside separate breakdowns by geographic location and industry sector. This creates three views of the same underlying exposure universe with minimal additional regulatory insight.

The revised ITS proposes to retire one of these three views and keep only the most policy-relevant one. The result: approximately 16% direct reduction in the number of mandatory COREP/FINREP data points. This is conservative—it excludes the additional ~34% reduction in data points achieved through integration of stress testing and benchmarking reporting (see below).

The implication: if your reporting infrastructure is built to produce 100 data points per reporting cycle, the revised ITS will require roughly 84 points. Sounds good—but the devil lies in identifying which 16% goes away. The EBA will specify this in the final revised ITS; institutions need to begin mapping their current templates against the proposal now, so they understand which templates will be retired, which will be simplified, and which will remain materially unchanged.

2. Strengthened Proportionality: "Core Plus Supplement" Model for SNCIs

SNCIs currently report approximately 49% of total supervisory reporting requirements across the framework despite representing a much smaller systemic risk footprint. This is because the current framework treats all institutions nearly identically, with exemptions only for very small operations.

The revised proposal introduces a clearer "core plus supplement" model. All institutions report a streamlined core set of templates (prudential capital ratios, large exposures, liquidity metrics, core credit risk data). SNCIs report this core set. Supplementary reporting on detailed counterparty risk analytics, stress testing extensions, and granular portfolio data is triggered only when institutions exceed materiality thresholds or where supervisors determine it is necessary for their specific risk profile.

For SNCIs, this could represent an 18% reduction in reported data points from current levels. For example, an SNCI with retail-focused lending might exit detailed wholesale counterparty reporting and instead submit a simplified large exposures report. A small regional bank might exit derivative-specific FRTB reporting and CVA risk templates entirely, submitting only a high-level summary.

But this depends critically on how "core" and "supplement" are defined. If the final ITS defines core templates too broadly (pulling in all COREP templates, including niche ones), SNCIs gain little. The consultation window is where SNCIs need to advocate: "Here is our actual business model. Here are the templates we genuinely cannot populate due to immateriality or absence of the underlying risk. Here is the cost of populating a template we don't need." The EBA listens to this kind of feedback.

3. Integration of Stress Testing and Supervisory Benchmarking into Regular Reporting

This is the hidden win of the proposal. Historically, supervisors run annual stress tests and submit separate templates. They also conduct supervisory benchmarking to compare institutions' profitability, asset quality, and capital efficiency. Both processes require banks to extract and transform data separately from regular COREP/FINREP reporting.

The revised ITS proposes to integrate stress testing assumptions, scenarios, and outputs into the regular supervisory reporting framework. Similarly, supervisory benchmarking data (market risk metrics, profitability ratios, asset quality breakdowns) will be incorporated as extended modules within the core reporting templates rather than as separate ad-hoc collections.

The benefit: a single, integrated data submission that includes regular supervisory reporting plus stress testing plus benchmarking. Instead of three data extractions, one unified pull. No more parallel runs of overlapping calculations. No more supervisor requests for "can you re-run the stress test with updated market data?"—the stress testing framework is embedded in the regular reporting cycle.

The cost: institutions must integrate their stress testing infrastructure (typically siloed in risk teams) with their supervisory reporting systems (typically in finance/operations). This is not trivial. But the 12–15 month implementation timeline (April 2026 consultation close → September 2027 application) should allow most institutions to complete this integration.

4. IFRS 18 Alignment in FINREP Templates

IFRS 18 becomes effective for many institutions in January 2025. The new standard changes how interest income is recognised and presented in financial statements. FINREP (Financial Reporting templates) must align with IFRS 18 changes, requiring adjustments to template definitions and calculation methodologies.

For most banks, this is a known project already underway. The EBA's revised ITS codifies these changes into the supervisory reporting framework, ensuring that the interest income reported to supervisors aligns with audited financial statements.

5. ESG Risk Integration and FRTB/SA-CCR Alignment

The revised ITS also incorporate ESG risk data into prudential reporting (extending PILLAR II environmental and climate risk metrics into PILLAR I supervisory templates) and align fundamental review of the trading book (FRTB) and new counterparty credit risk (SA-CCR) calculations with the revised supervisory reporting framework.

These are technical but material changes that affect how trading desks and investment portfolios report market and credit risk. Institutions with significant trading activity need to map FRTB requirements against the revised templates early.

The SNCI Proportionality Story: What Really Changes

For Small and Non-Complex Institutions, the revised ITS represent a genuine simplification—if the definitions of "core" and "supplement" are written clearly. SNCIs today spend significant resources building and maintaining reporting infrastructure for templates that are immaterial to their risk profile. A regional bank with minimal trading activity nonetheless reports FRTB templates. A retail-focused lender nonetheless reports derivative CVA risk data. These are compliance costs with zero supervisory value.

The proposal aims to fix this. By moving to a core-plus-supplement model with clear materiality thresholds, SNCIs could reduce their reporting burden by 18–25% depending on their business mix.

But this requires SNCIs to engage actively during the consultation. The EBA will propose specific definitions of "core" and "supplement" in the revised ITS; SNCIs need to respond with: "Our business model does not include X, Y, Z risk. We cannot credibly populate these templates. We request that they be classified as supplement and triggered only if supervisors specifically request them." The SNCI working group within the EBA Banking Stakeholder Group is the mechanism for this feedback.

Key question for SNCIs: When the revised ITS are published (likely April/May 2026), which templates are immaterial to your business? In which templates does populating data require systems investment that is uneconomical for your scale? Document these now and raise them in your consultation response.

Stress Test and Benchmarking Integration — The Hidden Win

The integration of stress testing and supervisory benchmarking into regular reporting is not headline news, but it is consequential. Under the current regime, institutions run three separate but overlapping data operations:

  • Regular COREP/FINREP: Quarterly (or annual for some templates), submitted to the ECB or NCA, covers capital adequacy, liquidity, credit risk, market risk, operational risk, and counterparty risk.
  • Annual Supervisory Stress Testing: Submitted to the ECB in June, covers impact of adverse scenarios on capital ratios, liquidity positions, and profitability. Uses many of the same underlying exposures as COREP but repackaged for stress assumptions.
  • Supervisory Benchmarking (ad-hoc): Supervisors request profitability, asset quality, and efficiency metrics to compare institutions. Data overlaps significantly with FINREP but is pulled and formatted separately.

This creates data reconciliation headaches. If an exposure's classification changes between the COREP extraction and the stress testing extraction, the two datasets no longer reconcile. If a supervisor's benchmarking request uses a different definition of "net interest margin" than FINREP, confusion ensues.

The revised proposal integrates these three streams. The regular reporting submission will include: (a) current COREP/FINREP templates, (b) stress testing parameters and outputs as extended modules, and (c) benchmarking metrics as additional FINREP extensions. All three are pulled from a unified data warehouse with consistent definitions.

The implication for institutions: build a single reporting data infrastructure rather than three separate ones. By September 2027, your stress testing engine should feed the same underlying exposure data as your supervisory reporting system. Your benchmarking metrics should be extractable directly from audited financial data, not recalculated ad-hoc.

IFRS 18, ESG, and FRTB — The New Additions

Beyond simplification, the revised ITS also add new reporting requirements:

  • IFRS 18 Alignment: FINREP templates are updated to align with IFRS 18 interest revenue recognition. This affects how financial institutions report interest income by portfolio segment and product type.
  • ESG Risk Integration: Climate risk and other ESG factors are incorporated into prudential reporting, extending the PILLAR II framework into PILLAR I supervisory templates. This is driven by ECB supervisory expectations and EBA guidelines on climate risk.
  • FRTB and SA-CCR Alignment: The fundamental review of the trading book (FRTB) and new counterparty credit risk methodology (SA-CCR) calculations are integrated into the revised supervisory reporting ITS, ensuring consistency between internal risk calculations and regulatory submissions.

For institutions already managing FRTB and SA-CCR under CRR3, this alignment is straightforward. For those still in transition, the revised reporting ITS will force alignment earlier than they might otherwise have achieved.

What This Means for Your Reporting Programme

The EBA is signalling: supervisory reporting is being fundamentally redesigned. If you wait until September 2027 to understand the implications, you are already 12 months behind. Here is what that redesign looks like operationally:

1

Current-state assessment (Now – May 2026)

Map all current COREP, FINREP, stress testing, and benchmarking templates against the EBA proposal. Identify: which templates will be retired, which will be simplified, which will remain materially unchanged. Calculate the delta between current data points and proposed data points by workstream.

2

Consultation response (May – July 2026)

Submit detailed feedback to the EBA on implementation feasibility, data definitions that need clarification, and any immateriality arguments for your institution (particularly relevant for SNCIs). Engage through your national banking association's EBA Banking Stakeholder Group.

3

Final ITS analysis (Aug – Oct 2026)

When the EBA publishes the final revised ITS (expected Q3/Q4 2026), conduct detailed impact analysis: which systems need to be retired, which need to be rebuilt, what is the data integration requirement between stress testing and supervisory reporting, what is the implementation cost and timeline.

4

Architecture and build (Nov 2026 – Jun 2027)

Design and build the new reporting infrastructure: integrate stress testing into the core reporting data warehouse, retire obsolete templates, rebuild simplified templates, configure IFRS 18 and ESG extensions. Conduct internal testing against historical data.

5

Parallel run and go-live (Jul – Sep 2027)

Run parallel submissions to the EBA under both current ITS and revised ITS. Validate that outputs reconcile, identify any data gaps or system glitches, and go live with the revised framework in September 2027.

Five Actions to Take Before the Consultation Closes

1

Audit current reporting infrastructure and data lineage

Identify all COREP, FINREP, stress testing, and benchmarking templates you currently produce. Map which systems generate which templates, how data flows between systems, and which calculations are replicated across systems. This is your baseline for understanding the impact of simplification and integration.

2

Quantify the cost of current complexity

How many FTEs are allocated to supervisory reporting? How much systems infrastructure is dedicated to generating stress testing templates, benchmarking reports, and regulatory reporting? How often does data reconciliation break down across these parallel processes? These costs are the baseline for the business case for integration.

3

Map templates to operational risk

Which templates are produced manually (highest error risk)? Which templates have had supervisory questions or deficiencies in recent exams? Which templates drive the biggest business decisions (e.g., capital planning, product pricing)? Prioritize these for integration and simplification.

4

Prepare a consultation response (for all institutions, especially SNCIs)

Don't wait for the final ITS. Respond to the current consultation on the principle: "We support simplification and integration. However, our business model does not include [X] risk, and producing [these templates] imposes material cost for minimal supervisory value. We request these be classified as supplement." Provide specifics: business model detail, cost estimates, materiality thresholds that would trigger supplementary reporting.

5

Engage with your regulator early

Don't wait for the revised ITS to be finalised. In Q2/Q3 2026, request a pre-implementation dialogue with your ECB or NCA supervisor. Present your current-state reporting infrastructure and your expected transition approach. Ask: "Are there specific reporting requirements or modifications you expect us to implement?" This gives you lead time to design the solution collaboratively rather than discovering misalignments at go-live.

HM
Hannan Mohammad

Founder & Managing Director, Ezelman · Former SVP Risk at a tier-one institution · Specialist in supervisory reporting architecture, regulatory data transformation, SNCI proportionality design, and ECB on-site inspection readiness

FAQ

What is the EBA proposing to simplify in supervisory reporting?
The EBA is consulting on revised Implementing Technical Standards (ITS) for supervisory reporting and supervisory benchmarking reporting, with the goal of reducing complexity and data burden without sacrificing regulatory insight. The proposal includes: (1) removal of approximately 16% of data points from ITS supervisory reporting templates on a 'need to have' basis (moving non-critical items from mandatory to optional or removing them entirely); (2) integration of parallel data collections—stress testing and supervisory benchmarking reporting are being folded into the regular reporting framework, eliminating overlaps and ad-hoc requests; (3) strengthened proportionality for Small and Non-Complex Institutions (SNCIs), moving to a 'core plus supplement' approach where SNCIs report a streamlined core set and supplementary templates only where material; (4) IFRS 18 alignment in FINREP templates; and (5) alignment with the DPM 2.0 (Data Point Model version 2.0) data infrastructure standards and JBRC (Joint Bank Reporting Committee) technical specifications. The net effect: approximately ~50% reduction in data points across the EBA reporting framework overall.
How does this affect Small and Non-Complex Institutions (SNCIs)?
SNCIs currently report approximately 49% of the total supervisory reporting requirements across the framework, despite representing a much smaller portion of systemic risk. The revised ITS proposes a further 18% reduction in the number of data points that SNCIs are required to report. The approach shifts from a 'one-size-fits-all' framework to a clearer 'core plus supplement' model: all institutions report a streamlined core set of templates (prudential capital, liquidity, large exposures, credit risk, market risk essentials), while supplementary reporting (detailed counterparty risk breakdowns, extensive market risk analytics, detailed loan-level data) is triggered only for institutions exceeding materiality thresholds or where supervisors determine it is necessary. This is a material simplification for smaller banks, which have historically spent significant resources on templating and calculation infrastructure to produce data of marginal supervisory relevance. However, institutions classified as SNCIs need to monitor the definitions of core vs. supplement closely to understand their actual reporting burden.
What is the timeline for implementation?
The EBA consultation on revised ITS for supervisory reporting closes on 10 July 2026 (with 10 May 2026 as the deadline for IFRS 18-related requirements specifically). The EBA will incorporate feedback, finalise the revised ITS, and submit them to the European Commission for endorsement. The revised ITS are scheduled to apply from September 2027 onwards. This gives institutions approximately 12–15 months from finalisation to implement changes: updating data definitions, reconfiguring reporting infrastructure, retraining finance and risk teams, and conducting testing against live data. For large institutions with complex reporting systems, this is a compressed timeline. For smaller banks, particularly SNCIs, the timeline is more manageable. Institutions should begin impact analysis now (during the consultation window) so they understand what systems, processes, and data governance changes will be required.
Why is stress testing being integrated into regular supervisory reporting?
Historically, supervisory stress testing (ECB/NCA annual stress testing) and regular supervisory reporting (COREP/FINREP) have been separate data collections, often requiring banks to extract, transform, and submit data through different channels on different timelines. This created redundancy: many of the underlying data points overlap (e.g., loan-level credit risk data needed for both stress testing and regular reporting). The EBA's proposal to integrate stress testing assumptions and outputs into the regular supervisory reporting framework is designed to: (1) reduce the total number of ad-hoc data requests, (2) create a single source of truth for supervisory data, (3) improve data lineage and reconciliation, and (4) align the stress testing calendar with the regular reporting calendar. Instead of submitting separate stress test templates to the ECB in June and regular COREP templates in July, banks will submit a unified reporting package that includes supervisory reporting plus stress testing extensions. This also enables supervisors to monitor stress testing scenarios and assumptions in near-real-time rather than on an annual ad-hoc basis. The practical implication: banks that have built separate stress testing infrastructure will need to integrate it with their core reporting systems by September 2027.
How should my bank respond to the EBA consultation?
Banks have until 10 July 2026 to submit comments on the consultation. The most effective responses will come from institutions that have: (1) completed a detailed impact analysis of the proposed changes against their current reporting infrastructure and data governance; (2) identified specific pain points in the current framework that the proposal does (or does not) address; and (3) raised concrete questions about implementation timelines, transitional relief, or technical specifications that remain unclear. Industry participation through national banking associations is also critical. The EBA's track record shows that consultations are responsive to well-reasoned, data-backed feedback on implementation feasibility. A response that says 'we support simplification but need 18 months to implement' is stronger than 'we support simplification.' Similarly, banks that flag specific data definitions that are ambiguous or technically infeasible will be heard. For SNCIs, the consultation is an opportunity to advocate for clear definitions of which templates are 'core' vs. 'supplement.' For larger institutions, the focus should be on implementation timelines, transitional arrangements, and any relief from dual reporting during the transition from CRR3 to the new reporting regime.