ECB Regulation on reporting of supervisory financial information
Having regard to Article 99(6) of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013, the ECB adopted Regulation (EU) 2015/534 in March 2015. This Regulation also governs the harmonised financial reporting (FINREP) requirements for institutions preparing national GAAP (nGAAP) financial statements. The Regulation is aimed directly at reporting institutions and does not require any national legal foundation. However, it is still necessary for national supervisors to review the applicability of the harmonised reporting requirements according to national accounting law – in Germany, this is the German Commercial Code (HGB). As a result, the requirements of the HGB are regularly weighted against the FINREP reporting scope of the applicable EU regulation. The definition of the FINREP reporting items is derived from the requirements in Annexes IV and V of Commission Implementing Regulation (EU) 2021/451 of 17 December 2020 (originally Commission Implementing Regulation (EU) 680/2014 of 16 April 2014). The tables below present the results of this accounting based reconciliation exercise. The published national reporting instructions represent the reporting framework for institutions reporting according to the HGB in Germany. The reporting expectations of national supervisors and as well the ECB are based on this.
The tables contain updated national instructions for the reporting of financial information for HGB reporters in connection with the respective applicable version of the ECB Financial Information Regulation.
A national working group – whose members include representatives of the German banking industry and selected auditing firms – was created to formulate these national instructions. The group works to develop the common understanding on accounting related individual reporting items shared by BaFin/Deutsche Bundesbank and banking industry representatives. Amendments to previous versions of the completion instructions that are the result of editorial revisions or changing EBA taxonomies are individually marked, as reporting expectations are based on the latest published version. The results of the working group on reporting instructions are agreed with the ECB and represent “strong recommendations” in terms of the ECB’s expectations.
“FINREP data points” reporting format
One particular detail of the ECB Regulation is the differentiation of reporting requirements via use of a size criterion in the interests of proportionality. In contrast to the other supervisory financial reporting formats, the reporting scope of “FINREP data points” does not require complete reporting templates. Instead, institutions using this reporting format only need to report single data points from selected reporting templates. In light of this, each applicable version of the ECB Financial Information Regulation contains a separate taxonomy exclusively for this reporting approach, including respective validation rules. In national reporting instructions for German national GAAP reporting institutions, reporting items required under the “FINREP data points” reporting framework are marked with “DP”.
Non-applicable validation rules
For the reporting of reporting institutions, the EBA and ECB validation rules apply on the basis of the published harmonised taxonomies. Due to national requirements for preparing financial statements, certain harmonised validation rules are not applicable for institutions that prepare HGB financial statements. The list published here shows the respective status of those validation rules which, from an nGAAP perspective, do not apply to the reporting of financial information on the basis of the HGB. This is the case if, inter alia, IFRS and nGAAP items are reconciled for validation purposes under automated FINREP checks. The German supervisory authorities will not check non-applicable validation rules when reports are submitted by HGB reporters. The non-applicable validation rules are also accepted as such by the ECB for their report submission purposes.
Chronology of the national reporting instructions in compliance with the respective taxonomy versions
The applicable taxonomy versions are updated on an ongoing basis at the European level. Therefore, over time, institutions will have to submit reports according to the taxonomy format that is the most up to date at that time. Following Regulation (EU) 2015/534 of 17 March 2015, significant institutions (SIs) were required for the first time to submit financial information on a solo and consolidated basis from 31 December 2015. The Regulation also introduced the obligation for SIs to report the financial information of their subsidiaries starting from 30 June 2016. Less significant institutions (LSIs) were required to submit financial information on a solo and consolidated basis as at 30 June 2017.
The following sections provide an overview of the development of the reporting instructions for HGB reporters, from taxonomy version 2.6 to the present day.
Taxonomy version 2.6
The original version of the national reporting instructions, which was foundational to the ECB’s Financial Information Regulation, was based on the requirements contained in FINREP taxonomy version 2.6, in accordance with Commission Implementing Regulation (EU) 2016/1702 of 18 August 2016. This original version applied starting from reporting date 30 June 2017. An updated version came into force from reporting date 31 December 2017 to the first application of the subsequent taxonomy version 2.7.
Taxonomy version 2.7
Regulation (EU) 2017/1538 of the European Central Bank of 25 August 2017 amending Regulation (EU) 2015/534 on the reporting of supervisory financial information due to amendments to the Council Implementing Regulation (EU) 2017/1443 of 29 June 2017 entered into force with effect from 1 January 2018. The changes made to Regulation (EU) 2017/1538 reflected amendments made to the EBA ITS harmonised FINREP requirements on the basis of the IFRS 9 framework. Subsequently, changes were also made to the reporting templates and instructions used by nGAAP reporters for reporting of supervisory financial information.
In Germany, these amendments affected all solo and consolidated reporters that prepare their financial statements according to HGB. Based on ECB Regulation (EU) 2017/1539, the initial date of application for ECB Regulation (EU) 2017/1538 for LSIs in Germany was postponed until 1 January 2019. For all SIs subject to direct ECB supervision, however, the amendments had already come into effect on 1 January 2018.
Taxonomy version 2.8
The national reporting instructions for taxonomy version 2.7 also applied to submitting reports under taxonomy version 2.8 in accordance with Commission Implementing Regulation (EU) 2018/1627 of 9 October 2018. No further substantive amendments were made at the time.
Taxonomy version 2.9
On 9 April 2020, the ECB adopted Regulation (EU) 2020/605 amending Regulation (EU) 2015/534. This Regulation incorporated the amendments made to reporting requirements in Commission Implementing Regulation (EU) 2020/429 of 14 February 2020. Starting from reporting date 30 June 2020, all reporting institutions were required to submit FINREP reports in accordance with this Regulation, following the national reporting instructions for taxonomy version 2.9. These instructions clarified, amongst other things, reporting of derivatives and Section 340f HGB contingency reserves on the HGB side.
Taxonomy version 3.0
On 14 May 2021, the ECB adopted Regulation (EU) 2021/943 amending Regulation (EU) 2015/534. This Regulation incorporates the amendments made to reporting requirements in Commission Implementing Regulation (EU) 2021/451 of 17 December 2020. From reporting date 30 June 2021, all reporting institutions are required to submit FINREP reports in accordance with this Regulation, following the completion instructions for taxonomy version 3.0. These instructions revise and clarify, amongst other things, reporting of profit and revenue reserves.