The EBA Simplification Package 2026: A Far-Reaching Reform of Supervisory Reporting

Background: Why now?

On 10 April 2026, the European Banking Authority (EBA) initiated one of the most comprehensive revisions to the Implementing Technical Standards (ITS) on supervisory reporting since their introduction, with the publication of consultation package EBA/CP/2026/07.

The proposed changes pursue two objectives: on the one hand, to meaningfully reduce reporting burdens; on the other, to integrate new regulatory requirements arising from the CRR, the new accounting standard IFRS 18, the revised market risk framework, and ESG regulation into the reporting framework.

The general consultation deadline is 10 July 2026; for certain reporting areas related to IFRS 18, the deadline of 10 May 2026 had already applied. Reporting under the revised framework is expected to commence from the reference date of 30 September 2027.

What is changing? The Key Elements:

Simplifications to existing reporting requirements

The EBA is pursuing a simplification programme built on six pillars:

• First in line is the reduction of data points and reporting templates: reporting items deemed dispensable from a supervisory perspective, or that overlap in substance with other reporting requirements, are being removed.
• In parallel, the frequency and scope of various reports are being adjusted. For example, ALMM (Additional Liquidity Monitoring Metrics) reporting for SNCIs is reduced to a quarterly frequency (templates C 66.01 and C 67.00 only), while large institutions continue to report monthly. Template C 44.00 (Leverage Ratio) moves from quarterly to annual reporting, and Template C 48.00 (Leverage Ratio Volatility) will in future only be required from large institutions. For LCR reporting, Template C 75.01 is discontinued for SNCIs, while it is retained on a quarterly basis for large institutions and medium-sized institutions.
• In addition, the proportionality principle is being expanded: small and non-complex institutions (SNCIs) receive relief or full exemptions in some areas. For FINREP derivatives templates (F 10.00 to F 11.04), SNCIs are only required to report quarterly where their derivative positions either exceed 1% of total assets or surpass EUR 2 billion in notional amount. For templates they do not use, SNCIs may nonetheless report on a voluntary basis (new Article 21a).
• The "Core + Supplement" approach extends the principle of mandatory core data sets with optional supplementary modules to further areas — in particular in FINREP, where individual templates will in future only be required upon breach of defined thresholds, such as an NPL ratio of 5% or an exposure to non-bank financial intermediaries of ≥ 5% of financial assets.
• Another aspect concerns the integration of parallel data collections: the previously separate ad hoc data collections for EU-wide stress tests are being absorbed into the regular reporting framework. Credit risk-related data points are incorporated into the standard reporting templates; standalone ad hoc submissions will in future be limited to projection data.
• Finally, qualitative improvements — better harmonisation of definitions and concepts across all reporting areas — are intended to reduce scope for interpretation and enhance data consistency.
  
  

New and expanded Reporting Requirements

Alongside the simplification measures, the paper also introduces new or expanded reporting obligations:

• IFRS 18 requires a fundamental revision of the FINREP templates: the new structure of the income statement (Operating, Investing, Financing) affects in particular templates F 02.00, F 16.01 to F 16.07 as well as F 45.02, F 45.03 and F 20.03. In addition, more granular collateral disclosures and new templates on non-bank financial intermediaries, crypto-assets and guarantees are being introduced.
• For ESG risks, a dedicated section is being established within the supervisory framework. The new reporting obligations are tiered by institution category. Large institutions with total assets exceeding EUR 30 billion submit templates D 01.00, D 02.00, D 04.00 and D 05.00 on a semi-annual basis, as well as templates D 03.00, D 10.00 and D 11.00 annually. Smaller large institutions report using the simplified template D 01.02 instead of D 01.00. Small and non-complex institutions and non-listed institutions are limited to the annual submission of template D 01.01.
• From 1 January 2027, the revised own funds requirements for market risk under the Fundamental Review of the Trading Book (FRTB) are expected to apply in the EU. This requires a significant expansion of market risk reporting obligations, including new requirements on the boundary between the trading book and the banking book as well as structural foreign exchange positions. New introductions include, among others, template C 99.00 for profits and losses arising from market risk, as well as revised provisions for template C 90.05.
• The CRR Amendments (Regulation (EU) 2024/1623) give rise to four further changes: a new shadow banking template for the aggregate capture of exposures to shadow banking entities by large institutions; a new COREP template for the impact of CRR III transitional arrangements on own funds; the replacement of the previous aggregate loss reporting by granular individual loss reporting via the complete template C 17.01 — combined with a one-off initial submission of historical loss data; and new reporting obligations for listed SNCIs in the context of Pillar 3 disclosure.
  
  

The nine modules at a glance

The consultation paper is structured into nine thematic modules, each containing its own consultation questions, reporting templates, explanatory notes and impact assessments:

• Module A — Liquidity and Asset Encumbrance
• Module B — FINREP (incl. IFRS 18)
• Module C — Operational Risk Losses
• Module D — Integration of EU-Wide Stress Tests
• Module E — Market Risk / PruVal / CCR / CVA
• Module F — COREP Own Funds and Transitional Arrangements
• Module G — ESG Reporting
• Module H — Pillar 3 for SNCIs
• Module I — Other Amendments
  
  

Looking ahead: Integrated Reporting as a strategic vision

The simplification package is embedded in a long-term strategic vision of the EBA: the full integration of supervisory, resolution and statistical reporting. This vision is being operationally driven forward by the Joint Bank Reporting Committee (JBRC) of EBA and ECB, which published recommendations on harmonised ESG definitions as early as January 2026. In parallel, an EU-wide public repository for supervisory data requests is expected to be fully operational by early 2027 — with the aim of avoiding duplicate data collections and strengthening accountability.

Implementation Challenges for Credit Institutions

Despite the welcome reduction in data points, the EBA Simplification Package will translate into a substantial implementation effort for many credit institutions. The structural changes to templates, classification logic and reporting scope affect data architecture, IT systems and internal processes across multiple business areas simultaneously — with a tight deadline of 30 September 2027. 

A particular challenge arises for institutions that make limited use of the standard functionality of their regulatory reporting software: where proprietary or heavily customised systems are in place, the new requirements cannot simply be activated via a vendor update and must instead be developed and implemented independently. 

Across all modules, the changes also intensify the need for cross-functional coordination between Treasury, Risk Management, Finance and Regulatory Reporting — especially where IFRS 18, FRTB and ESG requirements demand new data attributes and consistent definitions along the entire reporting chain. For institutions subject to the new granular operational risk loss reporting, the one-off initial submission of ten years of historical loss data adds a further operational burden. The integration of stress test starting points into regular COREP and FINREP reporting means that any inconsistencies between regular reporting, stress testing and Pillar 3 will become immediately visible to supervisors, raising the bar for data quality and governance. 

Institutions that begin their impact analysis early and take key architectural decisions before the end of 2026 will be significantly better positioned to meet the first reporting deadline.

How we can support you

The EBA Simplification Package is not merely a technical reporting project — it touches data architecture, IT infrastructure, internal governance, and the coordination between Finance, Risk, Treasury and Regulatory Reporting alike. We combine regulatory expertise with hands-on implementation experience, supporting you from the initial impact analysis and the design of your implementation roadmap through to assistance during live reporting. This includes assessing the impact of each of the nine consultation modules on your specific reporting setup, identifying where your existing systems and processes require adaptation, and developing pragmatic solutions tailored to your institution's size, complexity and technical infrastructure. Our goal is to ensure that you are fully prepared for the first deadline on 30 September 2027. Please do not hesitate to contact us.