Response to consultation on draft Implementing Technical Standards on Pillar 3 data hub
Question 1: Do you agree with the proposed IT solutions that would support the implementation of the P3DH to Large and Other institutions? If not, please explain the reasons why.
Consultation Paper – Draft Implementing Technical Standards on IT solutions for public disclosures by institutions, other than small and non-complex institutions, of the information referred to in Titles II and III of Part Eight of Regulation (EU) No 575/2013
We welcome the opportunity to provide below our comments on this EBA consultation. The Leibniz Institute for Financial Research SAFE is committed to interdisciplinary research on European financial markets and offers independent, research-based policy advice. As an institute focused on fostering a sustainable, resilient financial system, SAFE approaches this consultation from a perspective prioritizing market transparency and the needs of financial market users, contributing insights that support effective regulation and robust market structures.
We provide our comments from the perspective of the "users" of the Pillar 3 Data Hub (P3DH), i.e. financial market participants as well as financial supervisors, ensuring that our feedback addresses their needs. Moreover, while the Pillar 3 disclosure requirements encompass a broad range of topics, as specified under Part Eight, the focus of our response is particularly on the ESG-related disclosure under Pillar 3, given the urgent need for enhanced data accessibility, comparability, and transparency, in this critical field. Finally, our response focuses on “Question 1: Do you agree with the proposed IT solutions that would support the implementation of the P3DH to Large and Other institutions? If not, please explain the reasons why.”
The draft Implementing Technical Standards (ITS) provides guidance on the IT systems and processes that large and other institutions should use when submitting Pillar 3 disclosures. It outlines the necessary IT solutions, data formats, and technical validations to ensure efficient and standardized data submission. A primary goal is to create a single platform where users can easily access and reuse disclosed data, ultimately supporting the EU’s commitment to transparency and market discipline.
We believe that the objectives of the P3DH outlined on paragraph 15 of the Consultation are of great importance. Specifically, we support its aim to promote transparency and market discipline, serve as a single platform for users, enable simultaneous data downloads, and enhance data comparability through a standardized format.
Furthermore, we welcome the fact that the ESG-related disclosure will be conducted via the P3DH by October 2025 for listed Large Insitutions and Others.
- On ultimate users of the P3DH
With regard to paragraph 60, our observation is that while the objective is transparency promotion, key parties—namely (i) investors and shareholders, (ii) regulators and supervisory authorities, (iii) credit rating agencies (CRAs), (iv) analysts and financial researchers, (v) competitors and industry peers, (vi) consumers of banking services, and (vii) data providers—do not appear to have been fully involved in the consultation process. Although the discussion paper consultation involved stakeholders, not all user categories seem to have been considered, particularly investors, financial supervisors, CRAs, and data providers, who are essential for achieving transparency.
Therefore, our suggestion is to include these users in the pilot exercise running until December 2025, as mentioned in paragraph 60.
We greet the initiative to provide a dashboard for users with information on updates, including timestamps for corrections, as outlined in paragraphs 45 and 63. This functionality significantly enhances transparency, allowing financial market participants to track the latest disclosures and changes efficiently. To further benefit users, we suggest implementing automatic alerts to notify users when new data is published or existing information is corrected. Such a feature would improve timely access to critical updates, aiding users in making well-informed decisions based on the most current data available.
- On the publication of data in locations other than the website of EBA
With regard to paragraph 29, we consider that the fact that institutions shall be required to publish on their respective websites Pillar 3 information, which is the same as the one published on the EBA website, is likely to create room for fragmentation and data inconsistencies.
In this regard, circumstances where such information is disclosed or updated on the institution’s website but not yet in the P3DH – because the “as soon as possible” clause allows for it – should be avoided.
For instance, in the ESG space, we see data inconsistencies faced by investors and analysts when confronted for the same data point with two different disclosed values from two different data providers. This is due to the fact that one data provider sources the information from the company’s website while the other from the report and the value reported on the company’s website is different than the value in the respective report (updated at different times).
- On the clarity of the text to manage time expectations
Paragraph 30 et seqq., in line with Article 434(1) of the CRR, for Large and Other institutions foresees that the submission of Pillar 3 information needs to take place “no later than the date on which institutions publish their financial statements or financial reports for the corresponding period, where applicable, or as soon as possible thereafter”. While we understand that these provisions come from the Level 1 text, we would like to remind of the objective of transparency and suggest to the EBA to articulate expectations. Circumstances where the Pillar 3 information is disclosed / updated on the institution’s website but not yet in the P3DH – because the “as soon as possible” clause allows for it – should be avoided.
For instance, in the ESG space, we see data inconsistencies faced by investors and analysts when confronted for the same data point with two different disclosed values from two different data providers. This is due to the fact that one data providers sources the information from the company’s website while the other from the report and the value reported on the company’s website is different than the value in the respective report (updated at different times).
- On the storage time of disclosed information
With regard to paragraph 35, we salute the decision to archive disclosed information for a period of 10 years. This approach provides financial market participants with long-term access to historical data and for a consistent time period across institutions, which is essential for conducting trend analysis or benchmark risk assessments.
However, paragraph 20 “keep the archive with Pillar 3 data accessible for a certain period of time (no less than the storage period set by national law for information included in the institutions’ financial reports); “ – in line with CRR Article 434 (5). To ensure consistency over time also in cases of changes of national law with storage below 10 years and mitigate the risk of data storage fragmentation across institutions, we suggest the EBA to clarify that the data in the P3DH shall be stored no less than the storage set by national law of member states, however no less than 10 years.
- On the disclosure of statistics of visitors to the P3DH
With regard to paragraph 20, we agree with the envisaged disclosure of statistics of visitors to the P3DH, and notably the monitoring of the numer of visits to the EBA’s single access point for institutions’ disclosures and include the related statistics in its annual reports.
- On the identifiers of institutions
We understand from paragraph 36 of the Consultation Paper that the legal entity identifier (LEI) will be employed. In light of the critical importance of identifiers, we suggest making available to users the ISIN of the stock for listed institutions (in addition to the LEI).
- On the corrections to resubmissions
As foreseen in paragraphs 38-39, resubmissions of Pillar 3 information replaces the previous submission, hence the need for any resubmission to include all the information relevant for the same module and not the corrections performed. Hence, the EBA will make available the dates of submission and resubmission by the institution.
In this regard, we would like to suggest making available to users the information as to what exactly was corrected.
- On the data visualisation and exploration
As reflected in paragraph 45, we welcome the fact that, the EBA will provide visualisation and exploration tools for transparency purposes and to facilitate comparison across institutions, countries, portfolio etc.
- On the language of Pillar 3 PDF reports
In paragraph 50, it is mentioned that Pillar 3 PDF reports can be submitted in the national language(s), English or both. In this regard, we suggest considering accepting PDF format as data extractable formats, where these allow extraction of text by a machine and are human-readable.
- On the consistency between data provided by banks under disclosure as per Pillar 3 regulatory requirements and supervisory reporting
As noted in paragraph 25, we salute the EBA's effort to ensure consistency between supervisory reporting and disclosure requirements as regards quantitative information disclosed by institutions. This alignment is important for financial market participants who rely on accurate and comparable data to assess risk and make informed investment decisions. By streamlining the data across both reporting and disclosure, the EBA facilitates better transparency and comparability, enabling market participants to confidently evaluate institutions' financial health and risk profiles, thus supporting a more stable and efficient financial market.