Comments on EBA consultation papers (EBA/CP/2024/06 / EBA/CP/2024/07)

We very much welcome the fact that the EBA has clearly defined and described the requirements for
the implementation of the CRR III amendments. It makes a lot of sense to utilise data from other supervisory reporting areas. This can alleviate the burden. Nevertheless, additional work should be avoided in order to prevent unnecessarily increasing the workload due to complete innovations. This is one of the topics of the European Commission's (EC) approach in the Strategy on supervisory data in EU financial services of 21st December 2021. To reduce reporting hurdles, existing data from neighbouring supervisory institutions should be used (data sharing and uses). Additionally, the EC's proposal to amend Regulations (EU) No 1092/2010, (EU) No 1093/2010, (EU) No 1094/2010, (EU) No 1095/2010 and (EU) 2021/523 with regard to certain reporting obligations in the areas of financial services and investment support aims to streamline reporting obligations and reduce the administrative burden. The proposal seeks to facilitate the exchange of information between the supervisory authorities of the financial sector (the ESAs) and to avoid duplication of reporting obligations.

This core idea can and should be applied to the selected fields of the C 16.02 and C 16.03 reporting forms. The calculation rules relating to FINREP data demonstrate that the supervisory authority can also obtain this data directly from the FINREP system, thus avoiding double reporting.