Circular Letter No. CC/2024/00000043

Circular Letter No. CC/2024/00000043
Sent to:
Credit Institutions, Financial Companies, Payment Institutions and Electronic Money Institutions.
Mod. 99999924/T – 01/14
Subject: Guidelines regarding the resubmission of historical data within the EBA reporting framework

The European Banking Authority (hereinafter referred to as the "EBA") published the "Guidelines on resubmission of historical data within the EBA reporting framework" (EBA/GL/2024/04) (hereinafter "Guidelines") on 9 April 2024.

These Guidelines are addressed to competent authorities and to financial institutions and apply to the reporting structure for supervisory and resolution purposes developed by the EBA, regarding data regularly submitted by financial institutions to competent and resolution authorities. The Guidelines apply even if the submission of data by financial institutions is voluntary.

The EBA issued the Guidelines with the aim of specifying and circumscribing the requirements for the resubmission of historical data, in the event of errors, inaccuracies or other changes to previously reported data and in accordance with the reporting structure developed for supervisory and resolution purposes.

In summary, and without prejudice to the full consultation of EBA/GL/2024/04, the Guidelines define the following criteria for the resubmission of data to the respective competent or resolution authorities:
a) If errors, inaccuracies and related corrections affect current and historical data, the current data and the affected historical data must be resubmitted; b) The resubmission of historical data must be done taking into account its periodicity, with historical data for previous reference dates, dating back at least one calendar year, being resubmitted; c) Corrections must include both the elements in which the errors were detected and the related data affected by the corrections; d) If errors, inaccuracies and related corrections affect only current data, financial institutions must resubmit them corrected.

The content of these Guidelines does not prejudice the power of the Banco de Portugal to request, at any time, additional information regarding historical data that is considered necessary for the exercise of its responsibilities. Likewise, the Guidelines complement and do not prejudice the provisions of the following legal provisions:

• Article 3(5) of Commission Implementing Regulation (EU) 2021/451 of 17 December 2020;
• Article 2(4) of Commission Implementing Regulation (EU) 2021/763 of 23 April 2021;
• Article 5(4) of Commission Implementing Regulation (EU) 2018/1624 of 23 October 2018.

The Guidelines enter into force on 17 October 2024. The Banco de Portugal communicated to the EBA its intention to comply with the Guidelines, thereby incorporating the content of the Guidelines into the exercise of its supervisory activities.

In view of the above, and in the exercise of the competence attributed to it by Articles 17 and 17-A of its Organic Law, approved by Law No. 5/98 of 31 January, the Banco de Portugal hereby transmits to the financial institutions supervised by it its expectation that the requirements for the resubmission of historical data be complied with in accordance with the Guidelines from the reference date of 17 October 2024 (inclusive).

1 Guidelines on resubmission of historical data | European Banking Authority (europa.eu) 2 In the meaning of Article 4(2)(i) of Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010.
3 In the meaning of Article 4(1) of Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010, which includes, in particular, credit institutions, financial companies, payment institutions, electronic money institutions and branches of these entities.

Mod. 99999924/T – 01/14