EBA · 2014_1128 Final Q&A

FINREP reporting requirements

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
99, para. 2
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Submitted by
Credit institution
Submitted
2014-04-29
Answered
2016-11-25
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

If an institution is currently not within the scope of FINREP (i.e. not subject to article 4 of Regulation (EC) No. 1606/2002), but may fall within the scope of FINREP in the future, what would be the institution's first reporting reference date for FINREP?

Background

Article 99 (2) of Regulation (EU) No 575/2013 outlines the type of institutions that will need to report financial information under FINREP. If an institution neither prepares its consolidated accounts under IFRS nor issues financial instruments on an EU regulated market, then it is not within the scope of FINREP. If either of these circumstances changed, when would the first reporting reference date be for that particular institution? For example, if on 15th October (Q4) an institution that had previously not been in the scope of FINREP issued financial instruments on an EU regulated market and hence triggered one of the criteria under Article 99 (2) of Regulation (EU) No 575/2013, when would its first reporting reference date be for FINREP? As this would have occurred during the Q4 reporting period for FINREP, would the first relevant reporting reference date be Q1 in the next year (i.e. 30th March in the next year) as the institution was not within the scope of FINREP at the start of the Q4 reporting period?

Answer

According to Article 99 (2) of Regulation (EU) No 575/2013 (CRR), institutions subject to International Accounting Standards (IAS) in accordance with Article 4 of Regulation (EC) No 1606/2002 and credit institutions other than those referred to in Article 4 of Regulation (EC) No 1606/2002 that prepare their consolidated accounts in conformity with the international accounting standards adopted in accordance with the procedure laid down in Article 6(2) of that regulation shall report financial information. In accordance with Article 9 of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), the first reporting reference date for FINREP shall be the closest reference date following the date at which the applicable criteria were triggered, i.e. the first reference date for supervisory reporting at which the entity prepared its financial statement in accordance with the international accounting standards. Example:If an institution that had previously not been within the scope of FINREP reporters adopts IFRS on 15th October (Q4) and hence triggers one of the criteria under Article 99 (2) CRR, the first reference date for reporting financial information under Article 99 (2) CRR shall be 31 December of that year.

Original source: European Banking Authority, Q&A ID 2014_1128

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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