Circular NBB_2024_13 / EBA Guidelines of 8 April 2024 on the new submission of historical data under the EBA reporting framework (EBA/GL/2024/04)

NBB_2024_13 – 3 September 2024 Circular – P. 1/2 Boulevard de Berlaimont 14 – 1000 Brussels tel. +32 2 221 38 12 company number: 0203.201.340 RPM Brussels www.nbb.be

Circular
Brussels, 3 September 2024
Reference: NBB_2024_13
Your contact:
Pieter-Jan Janssens tel. +32 2 221 20 23 pieterjan.janssens@nbb.be

EBA Guidelines of 8 April 2024 on the new submission of historical data under the EBA reporting framework (EBA/GL/2024/04).

Scope

• Belgian credit institutions¹;
• approved or designated Belgian mixed financial holding companies;
• branches in Belgium of credit institutions subject to the law of another Member State;
• Belgian stockbroking companies;
• Belgian investment holding companies and mixed financial holding companies included in consolidated supervision by the National Bank of Belgium, where said group includes a significant stockbroking company;
• payment institutions and electronic money institutions.

Summary/Objectives
This circular aims to implement the guidelines of the European Banking Authority (EBA) of 8 April 2024 on the new submission of historical data under the EBA reporting framework (EBA/GL/2024/04) (hereinafter the EBA Guidelines). The French version of the text prepared by the EBA can be found on the website of the National Bank of Belgium.

¹ Those placed under the direct supervision of the Bank, referred to as 'less significant institutions'. For institutions placed under the direct supervision of the ECB, the 'significant institutions', reference is made to the ECB's approach within the Single Supervisory Mechanism (SSM).

VAN BELGIE n1 BanqueflgggnaleBank
Eurosystem

NBB_2024_13 – 3 September 2024 Circular – P. 2/2

Madam,
Sir,

In the context of prudential supervision, various financial institutions subject to supervision periodically communicate information to competent authorities or resolution authorities (in Belgium, the NBB), in accordance with the different EBA reporting frameworks.

Although financial institutions are expected to pay sufficient attention to the quality of the reported data, errors or inaccuracies may appear in the data once it has been submitted to the responsible authority; these errors may be detected by the institutions themselves or by the responsible authority.

If such errors or inaccuracies are identified in submitted reports, current legal requirements relating to the different (European) reporting frameworks provide that these reports must be corrected by the institution concerned. If these errors or inaccuracies appear not only in the most recent reports (the 'current data'), but also in previously submitted reports (the 'historical data'), this historical data must also be adapted as soon as possible². Furthermore, when their audited figures differ from the non-audited figures submitted³, financial institutions must proceed without delay to a new submission of the revised audited figures⁴.

However, current European reporting requirements did not specify how far back financial institutions had to go to adjust this historical data (i.e., for which past reference periods financial institutions had to correct the data). The attached EBA Guidelines seek to address this by defining a common European approach. The Guidelines indicate for which past reference periods the data (the historical data) must be resubmitted by financial institutions to the responsible authority. This approach aims to help financial institutions ensure that their reporting obligations are always complete and up-to-date, even in the event of inaccuracies or errors.

As indicated in the EBA Guidelines, these Guidelines will enter into force from 17 October 2024 and will apply to all existing (and future) EBA reporting requirements for supervisory and resolution purposes. For reference, the EBA website on the different versions of the EBA reporting frameworks can be consulted to stay informed about existing and upcoming reporting requirements: Annual Reports | European Banking Authority (europa.eu).

A copy of this circular is sent to the approved auditor(s) of your company.

We ask you to accept, Madam, Sir, the expression of our distinguished consideration.

Pierre Wunsch
Governor

Appendices: 1 - EBA Guidelines of 8 April 2024 on the new submission of historical data under the EBA reporting framework (EBA/GL/2024/04).

² See, inter alia, Article 3(5) of Implementing Regulation (EU) 2021/451, Article 1(4) of Implementing Regulation (EU) 2021/453, Article 2(5) of Implementing Regulation (EU) 2021/2284, Article 2(4) of Implementing Regulation (EU) 2021/763 and Article 5(4) of Implementing Regulation (EU) 2018/1624.

³ Non-audited figures are figures for which no opinion has been issued by an external auditor; audited figures are figures that have been audited by an external auditor who has issued an opinion on them.

⁴ See, inter alia, Article 3(4) of Implementing Regulation (EU) 2021/451, Article 2(4) of Implementing Regulation (EU) 2021/2284, Article 2(3) of Implementing Regulation (EU) 2021/763 and Article 5(3) of Implementing Regulation (EU) 2018/1624.