EU banks are set to switch to revised supervisory reporting requirements later than envisaged in the spring. On 6 November 2026, the European Banking Authority (EBA) said it would move the planned first reporting reference date to December 2027. It put selected requirements for liquidity, asset encumbrance, supervisory benchmarking and environmental, social and governance reporting on a later track to December 2028. The EBA is still finalising the technical standards and plans to publish its final draft in December 2026.
Key facts
- The April consultation proposed 30 September 2027 as the first reference date. The November plan moves it to December 2027.
- Selected requirements for liquidity, asset encumbrance, supervisory benchmarking and ESG reporting are slated for a December 2028 reference date.
- The EBA plans to publish its final report on the draft in December 2026 and submit the draft to the European Commission for adoption.
- The technical package, including the data point model, taxonomies and validation rules, is due in early 2027.
Which date applies to which return?
The April consultation, section 3.4, named 30 September 2027 as the first expected reference date for returns under the revised standards. The November announcement moves that first date and sets out a later stage for selected reporting areas. A reference date tells a bank what point in time its reported data should describe. Publication of the rule and the deadline to submit a return are separate dates. For stress testing, for instance, the EBA plans a dedicated module with separate submission deadlines and reporting frequencies.
| Stage | Date | Status |
|---|---|---|
| First reference date in the April draft | 30 September 2027 | Earlier proposal |
| EBA final report on the draft | December 2026 | Planned publication |
| Technical package | Early 2027 | Planned publication |
| First reference date in the November plan | December 2027 | Planned reference date |
| Selected reporting areas in the November plan | December 2028 | Planned reference date |
The split gives institutions a way to sequence the work of changing their reporting systems by subject. The EBA expects at least a year for implementation of the new requirements and more time for the deferred areas. Which data an institution needs to prepare by a given date depends on which reporting obligations apply to it. The extra time for selected liquidity reporting, for example, does not extend the timetable for every other module.
Which reports would come together?
Commission Implementing Regulation (EU) 2024/3117 sets out the existing supervisory reporting standards. The EBA’s regulatory dossier shows why integrating the benchmarking returns is a distinct change. The credit-risk and IFRS 9 templates used for the exercise with a reference date of 31 December 2025 were part of a separate technical standard. The EBA proposes to bring them into the general supervisory reporting framework as a separate module. For IFRS 9 benchmarking, it plans simpler requirements and a greater focus on reporting at consolidated level. Institutions covered by the benchmarking exercise should keep using the 2026 benchmarking standards during the transition, the EBA said.
The EBA also plans fewer fields and clearer instructions for detailed reporting of operational risk losses. During the transition, it says institutions should use existing templates to report only the data unaffected by the new granular classification. That interim instruction concerns how to record losses. It is separate from the later reference date for selected benchmarking returns.
For stress tests the EBA intends to remove selected data points and set up a dedicated reporting module. This differs from the change to credit-risk benchmarking. The latter brings requirements that previously sat in a separate instrument into the main framework. Stress testing would have its own module and reporting rhythm within the proposed framework. Elsewhere, the EBA says it will cut some collateral and ESG reporting and reduce reporting frequency for selected requirements.
What happens to extra requests from supervisors?
Members of the EBA’s Board of Supervisors have committed to cutting overlapping national and supervisory requests where the EU framework already collects equivalent information. That commitment concerns additional requests alongside regular reporting. Authorities can still ask for other information they need for their work. The EBA is thus addressing two different sources of reporting work, the templates institutions fill out and the supplementary requests they receive.
The authority expects to publish guidelines on how supervisors and resolution authorities design data requests by the end of 2026. It also expects a public EU-wide repository of those requests to become operational in the first quarter of 2027. The repository is intended to show what information authorities ask institutions to supply and is a separate project from the technical reporting standards.
The way institutions receive the reporting instructions is also due to change. The April paper, citing Article 430(7) of the Capital Requirements Regulation, explains that instructions are to appear on the EBA website with its reporting tools. The legal text of the standards, once adopted by the Commission, would appear in the EU’s Official Journal. Teams changing reporting systems will therefore need the adopted legal text for the obligation and the technical instructions to see how to complete the fields and structure the files.
For the regular returns, the next step is the EBA’s final report in December. The European Commission will consider the draft for adoption. The technical package due in early 2027 is where institutions can expect to find the specifications they need to map their data fields and validate the files they submit.
