Reporting reference dates for template C 33.00

Could you please confirm what the first reporting reference date for the sovereign exposures template (C 33.00) for institutions i. who report on a calendar year basis (i.e. accounting reference date 31 Dec) ii. whose accounting reference date deviates from the calendar year (say 31 March) and are permitted to apply Article 2(3) of Regulation (EU) No 680/2014 is?

The Draft Final Report EBA/ITS/2017/01 (Version 2) which was published on 7 April 2017 states that the reporting reference date will be 31 March 2018 (see last sentence on p4). Further, paragraph 8 in this Final Report states that the template should be reported with a semi-annual frequency. The above implies that all institutions subject to C33 reporting will have their first reporting reference date on 31 March 2018 and after that on 30 September. Countering this, Article 2(1)(c) of Regulation (EU) No 680/2014, states that institutions shall submit information for semi-annual reporting on 30 June and 31 December. Provision is made under Article 2(3) for reporting reference dates to be altered where institutions are permitted by national laws to report their financial information based on their accounting year-end which deviates from the calendar year. In these circumstances, the reporting reference dates may be adjusted so that reporting is done every three, six or twelve months from their accounting year-end, respectively. This would imply that for institutions whose accounting reference dates are on a calendar year basis, their first reporting reference date will be 30 June 2018 and not 31 March 2018. Furthermore, for institutions whose accounting reference dates deviate from the calendar year and on say 31 March, their first reporting reference date will be 31 March 2018 in accordance with Article 2(1)(c) of Regulation (EU) No 680/2014. Their next reporting reference date will be on 30 September.