Published by the Luxembourg Bankers’ Association (ABBL) on 10 July 2026, this consultation response to the EBA’s proposed amendments to the Implementing Technical Standards (ITS) on supervisory reporting supports the objective of a simpler, smarter and more proportionate reporting framework. The ABBL calls for realistic implementation timelines, greater predictability and recognition of the significant operational effort required to implement new, more granular reporting requirements, particularly for systemic institutions.