Question ID
2017_3252
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annexes III, IV and V, validation rules
Type of submitter
Consultancy firm
Subject matter
EBA validations APPEAR to be relevant to IFRS and GAAP though they only include a GAAP template (F 04.06)
Question

Can you confirm that these validations are out of scope for IFRS and, if so, why in the EBA validations list their severity is marked as "Blocking for IFRS"?

Background on the question

Our understanding is that these validations should be applied to IFRS with the F 04.06 element removed. Our implementation excludes the validations entirely for IFRS.v1377_m:
{F 05.00, r080,c010} = {F 04.01, r130,c010} + {F 04.02, r130,c010} + {F 04.03, r130,c030} + {F 04.04, r080,c060} + {F 04.04, r220,c060} + {F 04.06, r130,c010} + {F 01.01, r030,c010}

v1378_m:
{F 05.00, r080,c020} = {F 04.01, r140,c010} + {F 04.02, r140,c010} + {F 04.03, r140,c030} + {F 04.04, r090,c060} + {F 04.04, r230,c060} + {F 04.06, r140,c010}

v1379_m:
{F 05.00, r080,c030} = {F 04.01, r150,c010}+ F 04.02, r150,c010} + {F 04.03, r150,c030}+F 04.04, r240,c060} + {F 04.06, r150,c010} + {F 01.01, r040,c010}

v1380_m:
{F 05.00, r080,c040} = {F 04.01, r160,c010} + {F 04.02, r160,c010} + {F 04.03, r160,c030} + {F 04.04, r110,c060} + {F 04.04, r250,c060} + {F 04.06, r160,c010}

v1381_m:
{F 05.00, r080,c050} = {F 04.01, r170,c010} + {F 04.02, r170,c010} + {F 04.03, r170,c030} + {F 04.04, r120,c060} + {F 04.04, r260,c060} + {F 04.06, r170,c010}

v1382_m:
{F 05.00, r080,c060} = {F 04.01, r180,c010} + {F 04.02, r180,c010} + {F 04.03, r180,c030}F 04.04, r130,c060} + {F 04.04, r270,c060}+F 04.06, r180,c010}

Submission date
Final publishing date
Final answer

As stated in the sheet ‘explanation’ of EBA’s list of validation rules, ‘blocking for IFRS’ validation rules are those fully applicable to IFRS reporting institutions but not necessarily to reporting institutions following other accounting standards, namely reporting institutions applying national GAAP.

Validation rules v1377_m to v1382_m were originally intended to be designed to be applicable simultaneously both for institutions applying IFRS and those applying national GAAPs in their FINREP reports in accordance with Annexes III, IV and V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting). However, those validation rules do not take into account all portfolios relevant under nGAAPs and are therefore likely to fail for many nGAAP reporters. The severity status ‘blocking for IFRS’ implies that institutions applying IFRS must comply with the mentioned validation rules – otherwise the submitted data would be incorrect or incomplete – while institutions applying nGAAP may not fulfil them even if the submitted data is accurate and complete.

 

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

Disclaimer

The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.