This final report presents the implementing technical standards (ITS) related to the reporting of third-country branches (TCBs) under the CRD VI directive. It outlines the regulatory information that these branches must provide to their competent authorities, while introducing new requirements regarding assets and liabilities. Adjustments have been made to improve clarity and operational feasibility, with the…
This document is the final report of the European Banking Authority (EBA) published in 2026, entitled "Final Report on draft ITS on the supervisory reporting of third country branches under CRD VI". It presents the draft implementing technical standards (ITS) concerning the reporting obligations of third country branches (TCB) under Directive 2013/36/EU as amended by Directive (EU) 2024/1619 (CRD VI). The scope covers the regulatory and financial requirements that TCB must periodically communicate to competent authorities, as well as information related to their head undertaking (HU). The document is based on approximately 42 pages provided, focusing on the technical, regulatory, and operational aspects of harmonized TCB reporting within the European Union.
The EBA final report presents draft implementing technical standards (ITS) aiming to harmonize the reporting of third country branches (TCB) under the minimum harmonized regime of CRD VI. This topic is crucial as it addresses the need for effective and consistent supervision of TCB within the European Union, considering their growing volume of activities and existing regulatory fragmentation (p. 3-5). The main findings are that CRD VI introduces new requirements, notably reporting information on the head undertaking (HU) of TCB and on assets and liabilities originated by the branches themselves. The report proposes two sets of reporting templates: one for TCB (Annex I) and one for their HUs (Annex II), with a proportionate "core + supplement" approach distinguishing Class 1 (larger and more complex) and Class 2 (smaller) TCB (p. 3, 8). Member States applying requirements similar to those for credit institutions must nevertheless fill information gaps via these templates (p. 3, 9). Following the public consultation, simplifications were integrated to improve clarity, proportionality and operational feasibility, notably postponing the first reporting date to 31 March 2027, extended submission deadlines, and streamlining of templates and instructions (p. 3, 13-14, 26-27). Next steps include submission of the ITS to the European Commission, publication of IT tools (data point model, XBRL taxonomy, validation rules) in the first half of 2026, and effective implementation from 31 March 2027 (p. 3). The main recommendations are to adopt these ITS to ensure harmonized, proportionate and operationally viable reporting while preserving the integrity and comparability of supervisory data.
The EBA's mission is to contribute to the development of the European banking Single Rulebook, ensuring a harmonized prudential framework for EU financial institutions (p. 4). CRD VI, published in June 2024, incorporates the post-crisis Basel III reforms and introduces a new regime for third country branches (TCB) to address their growth and regulatory fragmentation within the EU (p. 4-5). The TCB regime aims to enable effective supervision and a comprehensive view of third country groups' activities in the Union, with harmonized minimum requirements (p. 5-6). Article 48l(1) of the CRD mandates the EBA to develop ITS defining formats, definitions and reporting frequencies for TCB. This document responds to this mandate, specifying the technical and operational modalities of reporting, while considering proportionality according to TCB classification (Class 1 or 2) (p. 6-8). The scope covers financial and regulatory information of TCB and their head undertakings, with the possibility for national authorities to impose additional requirements (p. 9-10). Limitations include non-consideration of specific national requirements outside the harmonized framework and operational complexity related to data collection, notably for smaller TCB (p. 9-10).
1. Regulatory framework and reporting objectives:
- CRD VI establishes a minimum harmonized regime for TCB, with detailed reporting requirements on both branches and their head undertakings (HU) (p. 3-6).
- The EBA must define ITS specifying formats, definitions and frequencies, with a proportionate approach according to TCB classification into Class 1 (larger) and Class 2 (smaller) (p. 7-9).
2. Classification and proportionality:
- TCB are classified into two categories, with "core + supplement" reporting: a common core for all, additional information for Class 1 (p. 8).
- For HU data, proportionality applies only to reporting frequency; collected data are identical for both classes (p. 8).
3. Reporting frequencies and modalities:
- Monthly, quarterly, semi-annual or annual reporting depending on templates and TCB class (p. 8-9).
- Fixed submission deadlines, with possible adjustments according to entities' accounting periods (p. 17-19).
4. Content of reporting templates:
- Annexes I and II detail templates for TCB and their HUs respectively, covering financial information (assets, liabilities, internal transactions), regulatory (capital endowment, liquidity), qualitative (recovery plans, strategy) (p. 11-14).
- CRD VI novelties: reporting of originated assets/liabilities, information on services provided via reverse solicitation, details on recovery plans and HU strategies (p. 7-8, 12-13).
5. Post-consultation simplifications and adjustments:
- Postponement of the first reporting date to 31 March 2027 to facilitate implementation (p. 13, 26).
- Extension of submission deadlines for HU data by one month (p. 13, 26, 36).
- Streamlining of templates: removal of redundant or less relevant fields, clarification of instructions, reduction of duplications (p. 13-14, 26-27).
- Introduction of a technical dimension (z-axis) to facilitate multi-HU reporting in a single file (p. 27).
6. Alignment with other frameworks and national constraints:
- Member States may apply requirements similar to credit institutions but must fill gaps with ITS templates (p. 9-10).
- TCB reporting is distinct but partially aligned with other obligations, such as reporting by intermediate institutions (IPU) (p. 29).
7. Technical and operational aspects:
- Data must comply with applicable accounting standards, be identified via LEI, and follow precise formats (p. 20).
- Possibility to submit unaudited figures, with obligation for prompt correction if differing from audited figures (p. 18).
- Operational challenges include HU data collection, coordination between entities, and management of differing accounting calendars (p. 33-39).
8. Impact and costs:
- Economic impact is considered limited, costs largely absorbed by existing requirements (p. 25).
- Simplifications aim to reduce costs and complexity while maintaining data quality and comparability (p. 13-14, 25-27).
9. Public consultation and feedback:
- Three responses received, with consensus on the need to balance rigor and proportionality (p. 26-39).
- Main concerns: feasibility, costs, deadlines, access to HU data, and proportionality for smaller branches (p. 28-39).
- The EBA incorporated several adjustments in response, notably on deadlines, template simplification, and extension of HU data deadlines (p. 26-27, 36).
Findings:
- CRD VI establishes a harmonized regime for TCB reporting, with precise requirements on financial, regulatory and qualitative data (p. 3-14).
- The EBA developed ITS with standardized templates, adapted frequencies and detailed instructions, validated by a public consultation (p. 3, 26-29).
- Classification into Class 1 and Class 2 allows proportionate application of requirements (p. 8).
- Implementation deadlines are set for 31 March 2027, with a full year for preparation (p. 3, 26).
Assumptions:
- Aggregation of HU data is feasible by TCB despite operational challenges (p. 38).
- Introduced simplifications suffice to reduce burden without compromising data quality (p. 13-14).
Interpretations:
- The absence of proportionality in HU templates (identical for Class 1 and 2) aims to ensure completeness and comparability of data (p. 24).
- The choice not to fully align TCB reporting with that of credit institutions aims to reconcile TCB specificities and comparability (p. 25).
Uncertainties:
- Practical difficulties for TCB, notably Class 2, in collecting detailed HU data within deadlines (p. 33-39).
- Impact of differing accounting and regulatory calendars between third countries and the EU on data quality and synchronization (p. 36-39).
- Regulatory evolution, notably with DGSD3 reform, potentially rendering some templates obsolete (p. 12).
- Operational risks related to implementation of new IT systems and coordination between entities (p. 33-34).
The EBA concludes that the proposed ITS meet CRD VI requirements for TCB reporting, ensuring a harmonized, proportionate and operationally viable framework (p. 25-27). Simplifications introduced after consultation improve feasibility and reduce burden without compromising data quality (p. 13-14, 26-27). Postponement of the first reporting date to 31 March 2027 and extension of submission deadlines for HU data are key measures to facilitate implementation (p. 3, 26, 36). The EBA recommends rapid adoption of these ITS by the European Commission, followed by publication of IT tools (data point model, XBRL taxonomy, validation rules) in the first half of 2026, to enable TCB compliance from the application date (p. 3, 21, 27). Finally, the EBA emphasizes the need for ongoing cooperation between competent authorities and entities to ensure reporting quality and completeness, while remaining attentive to future regulatory and operational developments (p. 26-27).
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