FINREP Taxonomy 2.7 Treatment of ECLs on FVOCI Assets

ECLs on FVOCI assets are recognised in equity, as per IFRS 9.5.5.2. How should these be treated on FINREP template 4.3.1?

In taxonomy 2.7, template 4.3.1 discloses the gross carrying amount and associated impairments/ECLs on financial assets held at fair value through OCI. Column 010 is the net of these, to give the net carrying amount. Validations v5582_i to v_5585_i require this net carrying amount to equal the carrying amount on template 01.01 (balance sheet assets). Gross carrying amount per Annex V Part 1.34 states: “under IFRS for debt instruments at amortised cost or at fair value through other comprehensive income, the gross carrying amount shall be the carrying amount before adjusting for any loss allowance”. IFRS 9 paragraph 5.5.2 states: “An entity shall apply the impairment requirements for the recognition and measurement of a loss allowance for financial assets that are measured at fair value through other comprehensive income in accordance with paragraph 4.1.2A. However, the loss allowance shall be recognised in other comprehensive income and shall not reduce the carrying amount of the financial asset in the statement of financial position”. Under IFRS 9, all loss allowances/ECLs for FVOCI assets are recognised in the OCI reserve in equity, rather than against the asset. On template 4.3.1, the gross carrying amount is the fair value of these assets, as no loss allowances have been applied. If ECLs are disclosed on template 4.3.1, it would give a carrying amount inconsistent with template 01.01. The validation rules require a consistent treatment of ECLs on FVOCI assets across all templates, in particular 4.3.1, 18.0, 19.0. Similarly, template 12.1 includes disclosure of the closing ECLs on FVOCI assets (as per paragraph 156 of Annex V), which should be consistent.