Circular NBB_2025_17 / Qualitative and quantitative periodic reporting obligation concerning proprietary trading activity

NBB_2025_17 – 25 November 2025 Circular – Page 1/3 14 Berlaimont Boulevard – BE-1000 Brussels tel. +32 2 221 30 17 company number: 0203.201.340 RPM Brussels www.bnb.be

Circular
Brussels, 25 November 2025
Reference: NBB_2025_17 your contact:
Gaëtan Doucet tel. +32 2 221 38 10 gaetan.doucet@nbb.be

Obligation of qualitative and quantitative periodic reporting concerning proprietary trading activity

Scope
Belgian credit institutions that collect deposits or issue debt instruments covered by the Belgian deposit protection system.

Summary/Objectives
This circular, within the framework of simplification, eases the periodic quantitative reporting to be provided by institutions subject to the NBB Regulation of 1 April 2014 concerning proprietary trading activity.
This circular replaces Circular NBB_2022_20 with effect from 25 November 2025.

Madam,
Sir,

You will find below the instructions of the National Bank of Belgium (NBB) concerning the periodic qualitative and quantitative reporting of proprietary trading activity.

1. Context
   The reporting referred to follows the provisions of the articles of the NBB Regulation of 1 April 2014 concerning proprietary trading activity (hereinafter the "Regulation"), in accordance with Articles 117 to 133 of the Law of 25 April 2014 on the status and supervision of credit institutions (hereinafter the "Law"). The first reference date applicable to both qualitative and quantitative reporting is set at 30 June 2015, and the first transmission date is 15 September 2015.

In accordance with the Law, all Belgian credit institutions that collect deposits or issue debt instruments covered by the deposit protection system referred to in Article 380 of the Law will transmit to the NBB periodic qualitative and quantitative reporting. All institutions subject to this Regulation are required to transmit a qualitative compliance report.

Pursuant to Article 16 of the Regulation, the NBB will, within the framework of the assessment of the principle of proportionality, grant an exemption from the obligation of periodic quantitative reporting to institutions that meet the provisions of Article 94 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms.

Furthermore, institutions that do not meet the aforementioned "de minimis" conditions provided for in Article 94 of Regulation (EU) No 575/2013 but nevertheless carry out limited trading activities are partially exempt from the quantitative reporting obligation. Specifically, provided that the threshold based on the volumes of their trading activities is less than 1.5% and the threshold based on the risks associated with these activities is less than 0.5%, institutions are subject to a limited quantitative reporting obligation comprising two significance thresholds (Tables 06.00 and 07.00) and, if produced internally, VaR data (Table 08.00).

However, without prejudice to the foregoing, the NBB may still subject any credit institution benefiting from these conditional exemptions to the periodic reporting obligation (more extensive) when it deems necessary based on the specific situation of the institution in question. Moreover, any credit institution subject to the complete or limited reporting obligation may submit an additional request to the NBB services to obtain a total or partial exemption from the reporting obligation for non-significant trading activities present in its subsidiary(ies).

2. Qualitative compliance report of reporting
   Pursuant to Article 14 of the Regulation, credit institutions are required to inform the NBB, on an annual basis for important credit institutions, and on a biennial basis for less important institutions as defined in Council Regulation (EU) No 1024/2013, and upon any significant modification, of the content of the compliance programme referred to in Articles 9 and following. Chapter II of the attached draft presents a recommendation for a minimum reporting structure.

This qualitative compliance report will be included in section F of the effective management report concerning the internal control assessment referred to in Circular NBB_2011_09 of 20 December 2011.
The practical arrangements (including the frequency of reports and deadlines) as well as the requirements of the aforementioned circular apply mutatis mutandis to this new section.

By way of exception, the first reference date and the first transmission date of this qualitative compliance reporting report are identical to those of the quarterly quantitative reporting tables described in Chapter III of the instructions on this matter in Annex 1, namely 30 June 2015 and 15 September 2015 respectively. In this context, institutions are only required to transmit the new section F of the effective management report concerning the internal control assessment on the reference date of 30 June 2015.

However, this qualitative reporting obligation does not exempt the concerned credit institutions from notifying the NBB in advance of each significant intermediate modification of internal limits or of the activity and risk profile of trading units, so that it can examine whether the trading activity and the risks associated with it remain limited and compatible with legal and regulatory provisions.

3. Quarterly quantitative reporting tables
   Within the framework, on the one hand, of monitoring the two significance thresholds of authorized trading activities that may lead to a capital add-on, as provided for in Article 12, § 4, of the Regulation and, on the other hand, of the existing risks (diversified VaR) of these trading activities as provided for in Article 12, § 2, specific reporting tables apply.

Furthermore, Article 15 of the Regulation imposes on credit institutions subject to this periodic reporting obligation to transmit to the NBB on a quarterly basis quantitative information on their trading activities concerning:

• positions for each risk factor and the sensitivity of the value of these positions to market price variations;
• for institutions that have an internal model for market risk approved by the NBB, the amount of risk measured by the internal model;
• daily realized results and their analysis;
• the volume of transactions carried out during the quarter;
• the effectiveness of hedging operations regarding risk reduction.

Regarding the reporting of sensitivity mentioned in the previous paragraph, this shall only be reported when at least one of the thresholds referred to in Article 12, § 4, of the Regulation is exceeded during the quarter preceding the reporting date.

Furthermore, it is no longer required to periodically report information concerning the holding period of positions in debt instruments and shares.

Chapter III of Annex 1 provides explanations and specific instructions for the reporting of quantitative tables established for this purpose. The first reference date and the transmission date of the quarterly compliance report of quantitative reporting are set at 30 June 2015 and 15 September 2015 respectively.
The tables are included in Annex 2 of this circular.

This circular as well as the reporting tables and the instructions relating thereto can also be consulted on the NBB website.
A copy of this circular is sent to the auditor(s), approved auditor(s) of your institution.

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

Pierre Wunsch
Governor

Annex 1:
Instructions for periodic reporting concerning compliance with requirements for proprietary trading activities.
CHAPTER I - General guidelines
CHAPTER II - Qualitative compliance report of reporting
CHAPTER III - Quarterly quantitative reporting tables

Annex 2:
Quarterly quantitative reporting tables (Excel)