Application of disclosure templates in EBA/GL/2018/10 for O-SIIs

Does the operation of paragraphs 17, 18 and 19 of EBA/GL/2018/10 mean that the 2018 NPL Guidelines apply to all O-SIIs, even if they are not credit institutions? If so, how is this reconciled with paragraph 6 of EBA/GL/2018/10, which states that the 2018 NPL Guidelines apply to credit institutions?

EBA/GL/2016/11 (the 2016 Guidelines) and EBA/GL/2018/10 (the 2018 NPL Guidelines) are linked, in that certain templates in the 2016 Guidelines are replaced by the 2018 NPL Guidelines for some types of reporting entity. The 2018 NPL Guidelines apply to credit institutions, as set out in paragraph 6. Paragraph 17 states that the 2018 NPL Guidelines replace templates 14 and 15 from the 2016 Guidelines. Paragraph 18 states that institutions that are required to complete templates 14 and 15 from the 2016 Guidelines should instead disclose the information set out in the 2018 NPL Guidelines. Paragraph 19 of the 2018 NPL Guidelines similarly refers to the replacement of templates 12 and 13 in the 2016 Guidelines. Institutions that are required to complete these templates should instead complete templates 5 and 6 of the 2018 NPL Guidelines. Within the 2016 Guidelines, templates 12, 13, 14 and 15 apply to institutions falling within para 7 of those Guidelines, ie G-SIIs and O-SIIs. In our case, this affects two separate O-SIIs: one is a stand-alone credit institution, and the other is a regulatory consolidation group containing an investment firm and its UK holding companies (but no credit institutions). Paragraphs 17, 18 and 19 of the 2018 NPL Guidelines thus seem to bring non-credit institutions into scope where they are O-SIIs. This causes a conflict with paragraph 6, which states that only credit institutions are within scope of the 2018 NPL Guidelines. Furthermore, the individual templates contained in Annexes to the 2018 NPL Guidelines all refer to credit institutions in the ‘scope of application’.