Supervisory Reporting ITS: What Changes Under CRR3
35+ template changes, new Output Floor disclosures, and FRTB reporting requirements. CRR3-aligned COREP has been in production since the first 2025 reference dates; the FRTB own-funds templates land on 1 January 2027. This is the reporting infrastructure transformation guide for banks that cannot afford to miss a submission deadline.
CRR3 (Regulation (EU) 2024/1623) has applied since 1 January 2025, and CRR3-aligned COREP has been in production since the first 2025 reference dates. The output floor phases in under Article 465 — 50% (2025), 55% (2026), 60% (2027), 65% (2028), 70% (2029), 72.5% from 2030. The remaining reporting build is the FRTB own-funds template set, due with the FRTB go-live on 1 January 2027 (Commission Delegated Regulation (EU) 2025/1496). An earlier version of this page presented January 2027 as the CRR3 reporting go-live and an 85% / 100% floor path; both have been corrected.
The regulatory reporting rebuild, end-to-end
Three companion pieces cover what actually changes in each of the three reporting frameworks that matter most to supervisors. Read them in order.
COREP — you are here
35+ template changes under CRR3, Output Floor, FRTB, CVA. The headline rebuild — already in most 2026 plans.
FINREP — the quiet half
IFRS 9 stage-migration, three-way reconciliation, ESG overlay and the new data-quality regime.
AnaCredit — the granular dataset
~95 attributes per loan, Regulation (EU) 2016/867 (ECB/2016/13). How supervisors triangulate it against COREP and FINREP.
Template Change Inventory by COREP Area
Not all template changes are equal. Some require minor data mapping adjustments; others demand new data sources, calculation engines, and multi-month IT projects. This inventory maps the real implementation effort.
| COREP Area | # Changes | Complexity | Data Sourcing | IT Effort | Severity |
|---|---|---|---|---|---|
| Credit Risk — SA (C 07.00–C 08.07) | 12 | VERY HIGH | MAJOR GAPS | 4–6 months | CRITICAL |
| Credit Risk — IRB (C 08.01–C 08.07) | 8 | HIGH | MODERATE GAPS | 3–5 months | HIGH |
| Output Floor (C 10.00 — NEW) | 4 | VERY HIGH | NEW SOURCE | 3–4 months | CRITICAL |
| Market Risk — FRTB (C 18–C 24 — NEW) | 7 | VERY HIGH | NEW SOURCE | 5–7 months | CRITICAL |
| CVA Risk (C 25 — REVISED) | 3 | HIGH | MODERATE GAPS | 2–3 months | HIGH |
| Operational Risk (C 16 — REVISED) | 2 | MEDIUM | MINOR GAPS | 1–2 months | MEDIUM |
| Large Exposures (C 26–C 29) | 2 | MEDIUM | AVAILABLE | 1–2 months | MEDIUM |
| Leverage Ratio (C 40–C 43) | 1 | LOW | AVAILABLE | 2–4 weeks | LOW |
Credit Risk SA, Output Floor, and FRTB templates are the three critical reporting workstreams. They account for 23 of the 35+ template changes and required entirely new data sourcing pipelines. The SA and Output Floor templates have been in production since 2025; FRTB is the build still ahead — if your reporting team has not begun implementation there, the January 2027 FRTB deadline is at serious risk.
Output Floor Reporting Cascade: 50% → 72.5%
The Output Floor is not a one-time implementation. It introduces a multi-year reporting obligation that changes each year as the Art. 465 floor percentage steps up, until the terminal 72.5% calibration applies from 2030.
New Template C 10.00: Output Floor
Reports the higher of IRB RWA and Floor% × SA RWA for each risk type. Banks must disclose which risk types are floor-binding and the magnitude of the floor add-on. This template requires parallel calculation of both IRB and SA RWA — meaning dual-engine production infrastructure.
Floor Binding Analysis by Risk Type
The ECB expects granular disclosure showing: Credit Risk floor binding (typically the largest), Market Risk floor binding, OpRisk floor binding, and CVA floor binding. Each risk type must report both the IRB number and the SA floor number. The delta is the capital add-on driven by the floor.
Phase-In Trajectory Reporting
Banks must report the current phase-in percentage and the projected impact at each future phase-in step. This means modelling forward-looking capital impact under the 65% (2028), 70% (2029) and terminal 72.5% (2030) steps of Art. 465. The ECB uses this data for supervisory capital planning and SREP assessment.
Interaction with Pillar 3 Disclosures
Output Floor data reported in COREP must reconcile to Pillar 3 public disclosures. Any material discrepancy triggers supervisory inquiry. Banks must align internal reporting, COREP, and Pillar 3 templates during the parallel reporting phase to ensure consistency before go-live.
Data Sourcing Gap Matrix
Every new template data point must trace to a source system. This matrix identifies the most common data sourcing gaps we see across European banks.
| Template Area | Required Data Field | Typical Source | Availability | Gap Remediation |
|---|---|---|---|---|
| SA-CR (C 07) | Granular exposure classification by CRR3 categories | Core banking / loan system | RED | Reclassification project: 3–4 months |
| SA-CR (C 07) | External credit rating mapping (ECAI) | Rating vendor feed | AMBER | Mapping table update: 4–6 weeks |
| Output Floor (C 10.00) | SA RWA by risk type (parallel to IRB) | Risk engine (dual calc) | RED | Dual engine build: 4–6 months |
| FRTB (C 18–24) | Risk factor sensitivities (delta, vega, curvature) | Front office / pricing engine | RED | New data pipeline: 5–7 months |
| FRTB (C 18–24) | Non-modellable risk factor (NMRF) identification | Market data vendor | RED | NMRF assessment framework: 3–4 months |
| FRTB (C 18–24) | Default Risk Charge (DRC) components | Credit risk engine | AMBER | Engine extension: 2–3 months |
| CVA (C 25) | SA-CVA sensitivities by counterparty | CVA desk / XVA engine | AMBER | XVA engine upgrade: 2–4 months |
| IRB (C 08) | CCF parameter estimates with CRR3 floors | IRB model / risk engine | GREEN | Parameter update: 4–6 weeks |
FRTB Reporting Requirements Breakdown
FRTB introduces entirely new reporting templates that have no predecessor in legacy COREP. Four components drive the reporting complexity.
Sensitivities-based Method (SbM)
Reports delta, vega, and curvature sensitivities across seven risk classes: GIRR, CSR Non-Sec, CSR Sec Non-CTP, CSR Sec CTP, Equity, Commodity, FX. Each risk class requires granular bucket-level sensitivity reporting. This is the most data-intensive FRTB component.
Internal Model Approach (IMA)
For banks with approved internal models: Expected Shortfall (ES) calculations, stress testing results, and backtesting outcomes. P&L attribution test (PLAT) results must be reported by trading desk. Failed PLATs force desk-level fallback to SbM — creating hybrid reporting complexity.
Default Risk Charge (DRC)
Standalone default risk capital for positions where issuer default is a material risk. Separate DRC calculations for IMA and SbM approaches. Requires credit spread and jump-to-default sensitivity data that most banks do not currently capture at the required granularity.
Residual Risk Add-On (RRAO)
Capital add-on for exotic instruments with risks not captured by SbM or IMA (e.g., correlation products, longevity swaps, weather derivatives). Requires product-level identification and categorisation. The notional-based calculation is simple; the product classification challenge is not.
FRTB templates (per BCBS d457 / CRR3 Title IV) require daily granular risk-factor data that most banks have never reported to supervisors. The data pipeline from front-office pricing engines to regulatory reporting systems typically does not exist and must be built from scratch. Banks that start FRTB reporting infrastructure late — e.g., Q3 2026 for a January-2027 FRTB go-live — will not be ready.
System Change Impact by Technology Layer
CRR3 reporting changes cascade through every layer of the technology stack. Understanding which systems are impacted and to what degree is essential for accurate IT budgeting and resource planning.
Core Banking / Loan Systems
Exposure reclassification under CRR3 categories requires changes to counterparty and facility master data. New attributes (e.g., CRR3 exposure sub-class, SME supporting factor eligibility) must be added. Typical change lead time: 4–6 months including UAT. This is the upstream dependency everything else waits for.
Risk Calculation Engine
Must produce both IRB and SA RWA in parallel for Output Floor. New FRTB calculations (SbM, DRC, RRAO) must be integrated. CVA engine must support SA-CVA and BA-CVA methodologies. Most engines require version upgrades or module additions. Vendor dependency is a material risk.
Data Warehouse / Data Lake
New data points, revised data models, and additional data quality rules. ETL logic must accommodate new template structures. Data lineage documentation must be extended. Reconciliation checkpoints between source systems, warehouse, and reporting output must be established for every new data flow.
Regulatory Reporting Tool
New XBRL taxonomy, revised validation rules, new template structures (EBA DPM 4.x). Most reporting-platform vendors provide CRR3 updates, but release timing varies. Banks must validate vendor releases against EBA specifications independently. Do not assume vendor releases are error-free.
Vendor Dependency Analysis
Most European banks rely on third-party vendors for at least one critical component of their reporting chain. Understanding vendor risk is not optional — it is a programme management necessity.
| Vendor Category | CRR3 Impact | Expected Release | Risk Rating | Mitigation |
|---|---|---|---|---|
| Risk Calculation Engine | FRTB module, SA-CVA, Output Floor | Q2–Q3 2026 | CRITICAL | Contractual delivery milestones; manual calculation fallback |
| Regulatory Reporting Platform | New templates, XBRL taxonomy, validations | Q3 2026 | HIGH | Early access to beta releases; parallel vendor/in-house testing |
| Market Data Provider | NMRF assessment, risk factor classification | Q2 2026 | HIGH | Multi-vendor strategy; internal NMRF assessment capability |
| Credit Rating Agency Feed | CRR3 ECAI mapping tables | Q1 2026 (available) | LOW | Standard mapping update — low complexity |
| Data Quality / Governance Tool | New data quality rules, lineage extensions | Q2–Q3 2026 | MEDIUM | Manual data quality processes as interim bridge |
For every critical vendor: What is your contractual CRR3 delivery date? What happens if you miss it? Do we have a manual workaround for the first submission cycle? Have you validated your release against the final EBA taxonomy? If your vendor cannot answer all four questions with specificity, escalate to procurement immediately.
Parallel Reporting: When to Start, Test Cycles, Benchmarks
Parallel reporting is not optional — it is how you validate that your reporting infrastructure produces accurate, reconcilable output before a first live submission. With CRR3 COREP in production since 2025, the cycle below applies to the FRTB own-funds templates due from the Q1 2027 reference date.
First Parallel Run (Q3 2026 reference date)
Generate the new FRTB market-risk templates using Q2 2026 data. Run full EBA validation rule set. Identify hard errors and soft warnings. Reconcile to legacy COREP where comparable data points exist. Target: <5% variance on comparable metrics. This run will surface the majority of data sourcing and mapping issues.
Second Parallel Run (Q4 2026 reference date)
Full production run with Q3 2026 data. All hard validation errors resolved. Soft warnings documented with justification. Complete reconciliation between COREP, Pillar 3, and internal management reporting. This is your dress rehearsal — if it does not work cleanly, the January 2027 FRTB go-live is at risk.
Reconciliation Tolerance Bands
Total RWA: <1% variance between COREP and internal reporting. Output Floor add-on: exact match (no tolerance). FRTB capital charge: <2% variance between risk engine and reporting output. CVA: <3% variance (higher tolerance due to calculation complexity). Any metric outside tolerance requires root cause analysis before go-live.
Submission Cycle Timing
Target: complete CRR3 COREP generation within 15 business days of reference date (consistent with current remittance deadlines). If your parallel run takes >20 business days, your production process is too slow. Identify bottlenecks in data sourcing, validation resolution, or sign-off chain and remediate before go-live.
NOW / NEXT / THEN — Reporting Implementation Phases
A phased action plan for reporting infrastructure transformation. Each phase has hard dependencies on the previous. Compression is possible but increases defect risk exponentially.
- Complete data point inventory: every new CRR3 data point traced to source system
- Identify RED data gaps and initiate remediation projects for SA-CR, Output Floor, FRTB
- Vendor engagement: confirm CRR3 release dates, request early access to beta versions
- Core banking system: begin exposure reclassification for CRR3 categories
- FRTB data pipeline: initiate build from front office to reporting layer
- Assign dedicated reporting workstream lead with direct SteerCo reporting line
- ETL logic build and unit testing for all new/changed templates
- First parallel run (Q3 2026): identify validation errors, data quality issues
- Vendor platform upgrade: deploy CRR3 reporting module, validate against EBA taxonomy
- Second parallel run (Q4 2026): full dress rehearsal with reconciliation
- Reconciliation between COREP, Pillar 3, and internal management reporting
- Data quality attestation by data owners for all reporting data flows
- Go-live cutover plan: production switch procedures, rollback contingency
- First COREP submission including FRTB own-funds templates (Q1 2027 reference date)
- Enhanced monitoring: daily validation checks during first submission cycle
- Rapid response team on standby for submission issues or EBA validation queries
- Post-submission review: lessons learned, process improvement backlog
- Begin planning for the 2028 Output Floor step in trajectory reporting (Art. 465: 65% in 2028)
- Decommission legacy reporting templates once CRR3 reporting is stable
Primary documents cited in this analysis
- [1]EBAEBA/ITS/2024/06 (9 July 2024) — Implementing Technical Standards on supervisory reporting under CRR3, adopted as Commission Implementing Regulation (EU) 2024/3117: reporting framework 4.0, first reference date 31 March 2025 → source
- [2]
- [3]ECBECB SSM Supervisory Manual — European banking supervision: an overview (most recent edition) → source
Dates, paragraph numbers and document versions verified at publication. Where consultations are still open, we flag draft status in text. Corrections: research@ezelman.com.
This analysis underpins our COREP/FINREP ITS-rebuild mandates.
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