Regulation (EU) 2015/534 of 17 March 2015
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 published Regulation (EU) 2015/534, which extends financial reporting requirements (FINREP) to supervised groups applying national accounting rules (nGAAP). This Regulation is aimed directly at all institutions that are subject to reporting requirements. Against this background, FINREP reporting items based on Annex IV of Commission Implementing Regulation (EU) No 680/2014 of 16 April 2014 as well as further subsequent Regulations have been reconciled with requirements under the German Commercial Code (HGB). The tables below present the outcome of this reconciliation exercise and are based on FINREP Version 2.6 pursuant to Commission Implementing Regulation (EU) 2016/1702 of 18 August 2016. This version has been effective since the reporting date of 31 December 2016. The tables, which have now been adjusted, will apply to the reporting institutions from the reporting date of 31 December 2017 until the date on which the next FINREP Version 2.7 is first applied pursuant to Commission Implementing Regulation (EU) No 2017/1443 of 29 June 2017. In principle, this Regulation will apply from 1 January 2018. However, for less significant institutions that apply the German Commercial Code, this version will only come into force on 1 January 2019 pursuant to Regulation (EU) 2017/1539 of the European Central Bank of 25 August 2017.
The tables also include guidance for those institutions applying the German Commercial Code on how to report financial information in the context of the ECB regulation. This guidance was compiled by a working group with representatives of the German banking industry and reflects the common understanding of BaFin, the Deutsche Bundesbank and banking industry stakeholders. The results of the reconciliation exercise have been agreed with the ECB.
FINREP data points reporting format
In contrast to the other supervisory financial reporting formats, the “FINREP data points” reporting format only queries single data points from selected reporting forms rather than complete reporting forms. In light of this, on 20 March 2017 the ECB published a separate taxonomy exclusively for this reporting approach, including respective validation rules.
Non-applicable validation rules
The list below shows the respective status of the validation rules which, from an nGAAP perspective, do not apply to the reporting of financial information on the basis of the German Commercial Code. This is the case inter alia if, under FINREP, IFRS and nGAAP items are reconciled for validation purposes. The German NCAs will not check these rules when reports are submitted by reporting entities applying the German Commercial Code. Like the Deutsche Bundesbank, the ECB will not reject any reports that violate the relevant validation rules (ie blocking rules do not apply). This also applies if, until further notice, the EBA continues to categorise these rules as blocking rules.