Definition of SME in Finrep vs COREP under CRR3 Regulation

Could you confirm whether, with the implementation of Regulation 2024/1623 of the European Parliament and of the Council amending Regulation (EU) No 575/2013 (the Capital Requirements Regulation 3 – CRR3), institutions will be required to report the concept of micro, small and medium-sized enterprises (SME) differently in FINREP and COREP, as provided in Recommendation 2003/361/EC and Article 5 point 9 of CRR 3, respectively?

In Annex V, Part 1, paragraph 5(i) of Regulation (EU) No 2021/451, the definition of SMEs is as set out in Commission Recommendation 2003/361/EC of 6 May 2003. By contrast, in CRR 2, the reference to that Commission Recommendation was only included in Article 501 Adjustment of risk-weighted non-defaulted SME exposures but only for the purposes of that article. Consequently, a Q&A was necessary to clarify the use of the same SME definition for FINREP and COREP, which was addressed through EBA Q&A 2013_27. In this Q&A, it is clarified that CRR and COREP should interpret the definition of SMEs in line with Recommendation 2003/361/EC, i.e., the definition of SMEs in FINREP and COREP are aligned. However, with the approval of CRR 3, which will enter into force on 1 January 2025, a new definition of SMEs is established in Article 5 point 9 of the CRR, which only takes into account the criterion of annual turnover (less than EUR 50 million). This definition will be used for reporting in COREP but not for FINREP, where no change has been introduced.