EBA proposes a simpler supervisory reporting framework: ABBL supports the direction while calling for proportionate implementation

The ABBL welcomes the European Banking Authority’s proposed revisions to the Implementing Technical Standards (ITS) on supervisory reporting, supporting the objective of creating a simpler, smarter and more proportionate reporting framework while highlighting the importance of realistic implementation, regulatory predictability and proportionality.

A positive step towards smarter supervisory reporting

The European Banking Authority (EBA) has launched a consultation on proposed revisions to the Implementing Technical Standards (ITS) governing supervisory reporting.

The proposals seek to streamline reporting requirements, reduce duplication and improve consistency across reporting modules, making supervisory reporting more efficient for both institutions and supervisors.

The ABBL welcomes this direction and supports the EBA’s efforts to create a simpler, smarter and more proportionate supervisory reporting framework.

More proportionate and predictable reporting requirements benefit supervisory authorities, financial institutions and, ultimately, the customers they serve.

However, the effectiveness of these simplification measures will largely depend on how they are implemented in practice.

Simplification must reflect the reality of implementation

While the removal of certain reporting templates represents a positive development, the ABBL notes that the expected reduction in reporting burden is likely to be more limited for larger and systemic institutions than headline estimates may suggest.

Several simplification measures are accompanied by new reporting requirements, including the integration of stress-testing information into regular supervisory reporting.

This represents a significant implementation effort, requiring new data sourcing capabilities, governance arrangements, validation processes and system adaptations.

Adequate lead times remain essential

The ABBL also emphasises that successful implementation requires realistic timelines.

Financial institutions need sufficient time to assess regulatory changes, adapt systems, conduct testing and ensure data quality.

Where implementation deadlines are compressed, transitional arrangements and phased implementation should be considered to mitigate operational risk while maintaining the quality of supervisory reporting.

Greater predictability supports better implementation

The ABBL strongly supports initiatives that improve regulatory predictability, including the introduction of fixed implementation calendars aligned with reporting reference dates.

Greater certainty would facilitate project planning, budget allocation and resource management across institutions and software providers, while reducing implementation costs and operational complexity.

The ABBL also believes that early adoption of revised reporting requirements should remain voluntary, allowing institutions to implement changes according to their own capabilities and infrastructures.

Practical guidance remains key

The ABBL welcomes the EBA’s communication tools, including the Time Traveller, Signposting Tool and Reporting Framework Overview, which already contribute positively to transparency and change management.

Additional implementation guidance, clearer mappings between framework versions, structured change logs and stronger links between ITS amendments, Data Point Model releases and validation rules would further strengthen institutions’ ability to prepare for regulatory change.

One framework does not fit all

The ABBL also recommends that future impact assessments better differentiate between Small and Non-Complex Institutions (SNCIs) and larger or systemic institutions.

While simplification measures may generate significant savings for smaller firms, implementation efforts remain substantially higher for larger institutions, meaning that the net reduction in reporting burden is likely to be materially lower than aggregate estimates suggest.