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Summary of the Consultation Paper on the Amendments to the Guidelines on Common Reporting (COREP)

I. Background

The Guidelines on Common Reporting (COREP) were first issued by the Committee of European Banking Supervisors (CEBS) in January 2006 to standardise prudential reporting for credit institutions and investment firms under Directives 2006/48/EC and 2006/49/EC. A recast version was published in October 2006, followed by amendments in July 2008 focusing on remittance dates and reporting frequencies. The latest version, published in January 2010, incorporated amendments to the CRD (Directives 2009/27/EC and 2009/83/EC) and CRD II (Directive 2009/111/EC). These amendments were made in response to Article 74 of the revised CRD, which requires competent authorities to apply uniform reporting formats, frequencies, and dates by 31 December 2012.

II. Methodology and Scope of the Work

CEBS is developing the revised COREP guidelines in two phases, aligned with the European Commission’s "better regulation agenda". In the first phase, CEBS conducted:

• A commonality study based on national implementations of COREP.
• A user test survey to evaluate the usefulness of the data.
• Regular meetings of the COREP Operational Network and seminars with risk experts to gather ideas for improvement.

The revised COREP templates and instructions are now available for consultation. In the second phase, feedback from the consultation and changes from new EU Directives (e.g., CRD III and IV) will be incorporated. Additionally, the common reporting templates developed for large exposures reporting will be integrated into the COREP framework.

III. Problem Identification and the Case for Policy Changes

The main challenges include:

• Legal differences: Divergent national legislation and accounting rules hinder harmonisation of data definitions and common terminology.
• Reporting differences: Variations in templates, frequencies, and remittance dates complicate cross-border analysis and increase reporting burdens.
• IT differences: Inconsistent data standards and submission requirements add complexity.

These differences primarily affect cross-border financial institutions, which still face significant reporting costs despite the aim of reducing them. The lack of harmonised data also limits the effectiveness of financial stability monitoring.

IV. Objectives of Policy Changes

The goal of revising COREP is to:

• Improve the efficiency of financial supervision by providing comparable and standardised data.
• Reduce the burden on institutions through a unified reporting system.
• Support macro-prudential analysis and risk assessment.
• Encourage a common supervisory culture and practices across the EU.

CEBS aims to ensure that any changes do not lead to further regulatory failure, such as excessive compliance costs or insufficient data collection.

V. Policy Changes: Uniform Reporting Formats and Implementation

The revised COREP guidelines aim to eliminate differences in reporting formats and ensure 100% implementation of a uniform framework across all Member States. Key changes include:

• No distinction between "Core" and "Details" templates.
• Uniform templates across Member States.
• Detailed implementation instructions including:
  • Clear legal references.
  • Precise data definitions.
  • Links to the FINREP framework.
  • Reporting examples.
  • Validation rules.
  • A COREP network to address implementation questions.

CEBS also provides supervisory disclosures on its website, showing how COREP is implemented in each country.

VI. Proportionate Reporting

Although reporting is uniform, it must be proportionate to the nature, scale, and complexity of the institution's activities. CEBS introduces a second level of proportionality affecting reporting frequency:

• Baseline frequencies are set for most templates (quarterly for credit institutions and investment firms, semi-annual for some).
• Adjusted frequencies apply to domestic-only institutions and are based on criteria determined by competent authorities.

For cross-border institutions, the baseline frequencies apply universally to ensure homogeneous data for supervisory analysis.

VII. Reporting Frequency, Reference Dates, and Remittance Dates

Baseline Reporting Frequencies

(*) The CR SEC Details template should be submitted by stand-alone institutions and institutions located in a different jurisdiction than the parent entity.

Adjusted Reporting Frequencies

(*) The CR SEC Details template should be submitted by stand-alone institutions and institutions located in a different jurisdiction than the parent entity.

Reporting Reference Dates

• Quarterly reporting: 31 March, 30 June, 30 September, and 31 December.
• Semi-annual reporting: 30 June and 31 December.
• Annual reporting: 31 December.

Remittance Dates

• Individual reporting: Maximum of 20 business days.
• Consolidated reporting: Maximum of 40 business days.
• CEBS allows additional time for domestic-only institutions.

VIII. Summary of Main Changes in the COREP Guidelines

The main changes in the COREP Guidelines are reflected in the templates and instructions attached to this consultation paper. The following colour coding is used:

• Red cells: Items that will be deleted.
• Green cells: Items that will be added.

Additionally, the guidelines incorporate methodological changes to enhance data harmonisation and comparability.

IX. Questions for Respondents

1. Do you have additional recommendations that could be taken up by CEBS to achieve uniform implementation of COREP?
2. What is your assessment of CEBS proposals to address proportionality in COREP, particularly the establishment of national criteria that could lead to lower reporting frequencies for certain domestic-only institutions?
3. What is your assessment of CEBS's proposal regarding the establishment of baseline and adjusted reporting frequencies for individual templates?
4. What is your assessment of the inclusion of country-specific items through the implementation of an additional template "CA annex"?