Published by the Luxembourg Bankers’ Association (ABBL) on 10 July 2026, this consultation response to the EBA’s draft Implementing Technical Standards on credit risk and IFRS 9 benchmarking reporting supports the integration of benchmarking into the supervisory reporting framework. The ABBL calls for greater clarity, proportionate reporting requirements, realistic implementation timelines and practical guidance to ensure the framework remains operationally feasible and consistent across institutions.