Communication NBB_2021_13 / New reporting frameworks developed by the EBA

NBB_2021_13 – 8 June 2021 Communication – Page 1/4 boulevard de Berlaimont 14 – BE-1000 Brussels tel. +32 2 221 54 65 company number: 0203.201.340 RPM Brussels www.bnb.be Communication Brussels, 8 June 2021 Reference: NBB_2021_13 your contact:
Gertjan van Gastel tel. +32 2 221 27 88 gertjan.vangastel@nbb.be New reporting frameworks developed by the EBA Scope

• Belgian stock exchange companies
  Objective
  This Communication aims to inform stock exchange companies about the impact of the new IFR/IFD prudential framework on the new information reporting mechanism, particularly regarding the National Bank of Belgium’s (BNB) expectations for the reporting of the reference date of June 2021 and the technical protocol to be followed for this purpose. Furthermore, the Communication informs stock exchange companies about the new EU reports as of the reference date of September 2021 and the adaptation of national periodic IF statements.

Communication – Page 2/4 NBB_2021_13 – 8 June 2021 Madam, Sir, From 26 June 2021, the new prudential framework applicable to investment firms will enter into force based on Regulation (EU) 2019/2033 (IFR) 1 and Directive (EU) 2019/2034 (IFD) 2. The IFR and IFD provide for a new classification of investment firms, establishing a distinction between systemic class 1 investment firms, non-systemic class 2 investment firms, and small non-interconnected class 3 investment firms. The new regulation includes specifically defined criteria that an investment firm must meet to be admitted to class 3, under which it is in principle not possible for stock exchange companies (hereinafter also referred to as “establishments”) under the supervision of the National Bank of Belgium (BNB) to fall into this category, based on the authorized and exercised activities. Stock exchange companies considered systemic under the IFR/IFD texts, i.e., falling under class 1, have already been approached by the BNB since it is necessary for them to move towards the status of credit institution. Through this Communication, we therefore intend to inform the remaining stock exchange companies, falling under class 2, under BNB supervision, about the impact of the new prudential framework on the new information reporting mechanism. In March 2021, the European Banking Authority (EBA) published the final draft of implementing technical standards for information reporting for the purpose of supervision and disclosure for stock exchange companies (ITS) 3. The EBA published the corresponding set of standards (EBA reporting framework version 3.1), including the XBRL reporting taxonomy and validation rules to be used by stock exchange companies, in mid-May 2021 4. Although Regulation (EU) 2019/2033 (IFR) applies largely from June 2021, the reporting obligations as set out in the final draft of the ITS for class 2 establishments should enter into force from the reference period of September 2021 (provided that the final version of the ITS draft is approved by the European Commission and published in the Official Journal of the European Union). Due to the differences in the implementation periods of the various legislations, a potential “information gap” could appear for the reference date of 30 June 2021. In this context, the objective of this Communication is multiple. The Communication clarifies the BNB’s expectations regarding reporting obligations for the reference period of June 2021, on the one hand, and explains the technical protocol to be followed for the relevant reports, on the other hand. Furthermore, the Communication informs establishments about the new harmonized European reporting obligations (as contained in the EBA’s final draft of ITS for stock exchange companies) which will apply from the reference date of September 2021. Finally, the Communication aims to inform establishments about the upcoming national periodic IF statements for investment firms (as currently
determined in circular NBB_2014_14 of 18 November 2014) after the implementation of the European reporting framework in September 2021. 1 Regulation (EU) 2019/2033 of the European Parliament and of the Council of 27 November 2019 on prudential requirements applicable to investment firms and amending Regulations (EU) No 1093/2010, (EU) No 575/2013, (EU) No 600/2014 and (EU) No 806/2014. 2 Directive (EU) 2019/2034 of the European Parliament and of the Council of 27 November 2019 on the prudential supervision of investment firms and amending Directives 2002/87/EC, 2009/65/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU and 2014/65/EU. 3 Cf. on this subject:
https://www.eba.europa.eu/sites/default/documents/files/document_library/Publications/Draft%20Technical%20St andards/2021/ITS%20on%20reporting%20and%20disclosures%20requirements%20for%20investment%20firms/ 963716/Final%20Draft%20ITS%20on%20Reporting%20and%20disclosures%20for%20investment%20firms.pdf.
4 Cf. on this subject: https://www.eba.europa.eu/risk-analysis-and-data/reporting-frameworks/reporting-framework-3.1.

NBB_2021_13 – 8 June 2021 Communication – Page 3/4
1. Reports at the reference date of 30 June 2021
To bridge the “information gap” at the reference date of 30 June 2021 while reducing reporting burdens for the sector, the BNB requests that establishments prepare their reports at the reference date of 30 June 2021 in accordance with the reporting requirements defined in Regulation (EU) No 680/2014 5, as amended in particular by the ITS on prudential supervision (EBA framework version 2.9/2.10). Consequently, establishments must apply the same taxonomy for the reference date of 30 June 2021 as for reports at the reference date of 31 March 2021. Technical note:
To allow the continuation of the “old” taxonomy instead of the new EBA 3.0 framework for the reference period of 30 June 2021, two minor interventions are necessary in the XBRL reports:
1. the reporting code in OneGate is no longer the default reporting code, but is followed by “_SBV”. Example: “AE_IND” becomes “AE_IND_SBV”;
2. the reporting date cannot be 30 June 2021: this date would refer to the applicable EBA 3.0 framework. Therefore, the report prepared as of 30 June 2021 must be technically loaded under the period closed on 31 March 2021.
This can already be tested in the OneGate test environment. An illustration of an XBRL document valid for asset encumbrance charges is attached to this Communication. This annex can be consulted on the Bank’s website.
For establishments with the “data entry” option, it is imperative to select the report followed by “_SBV” and the period 31/03/2021 to declare figures as of 30 June 2021.
For reports as of 30 June 2021, establishments must therefore not yet implement the reporting requirements stipulated in the EBA’s final draft regarding information reporting for investment firms. They must also not implement the new requirements imposed in Regulation (EU) No 2021/451 (the EBA framework for ITS on prudential supervision version 3.0).
2. Reports from the reference date of 30 September 2021
From the reference date of 30 September 2021, the BNB expects establishments to produce their reports in accordance with the requirements set out in the EBA’s final draft of ITS on stock exchange company disclosures. For these reports, establishments are expected to use the EBA’s XBRL taxonomy as published on its website.
National reports
Following the introduction of the new European reporting framework for stock exchange companies, the BNB will also adapt the existing national periodic IF statements for stock exchange companies, as determined in circular NBB_2014_14 of 18 November 2014. To limit the reporting burden for establishments, from the reference period of September 2021, they must only communicate the following tables as determined in circular NBB_2014_14:

• No. 01 – Assets;
• No. 02 – Liabilities;
• No. 03 – Income statement;
  5 Commission Implementing Regulation (EU) No 680/2014 of 16 April 2014 defining implementing technical standards with regard to prudential information to be provided by establishments, in accordance with Regulation (EU) No 575/2013 of the European Parliament and of the Council (as amended).

Communication – Page 4/4 NBB_2021_13 – 8 June 2021

• No. 04 – Allocation of results.
  The other reporting tables (No. 05 to 15) as contained in circular NBB_2014_14 will therefore no longer apply from the reference period of September 2021. In specific circumstances and/or for particular reasons, the BNB reserves the right, however, to request reporting tables No. 05 to 15 if necessary.
  Given the importance of this project, we ask you to ensure that adequate procedures are put in place and that sufficient resources are available to transmit your reports within the prescribed deadlines. However, the BNB will take into account, in the assessment of the quality of information transmitted, in a first phase, the fact that the reports have been recently introduced and are based on a new regulatory framework. If you have questions regarding the content of this new ITS, we strongly advise you to address them directly to the EBA under the “Single Rulebook Q&A” section of its website. Any question relating to operational specifications can be addressed to SchemaA@nbb.be. Please note that we are sending a copy of this Communication to the auditor(s) and approved auditor(s) of your establishment. Yours faithfully, Pierre Wunsch Governor