EBA Reporting Consultation: Reporting less, steering better – but at what cost?

116,000 data points per institution and reporting date, more than 740 statements to be filed – that was the reporting baseline for European banks at the end of 2024, measured against figures José Luis Escrivá, Governor of the Banco de España, made public in November 2025. On 10 April 2026, the European Banking Authority (EBA) published a consultation paper aimed at reducing this data volume by approximately 50 per cent: Consultation Paper EBA/CP/2026/07 on the revision of the Implementing Technical Standards (ITS) for supervisory reporting. Public hearing on 5 May, comment deadline on 10 July, first application as of the 30 September 2027 reference date – the cornerstones are set.

The headline reads like long-overdue relief: fewer data points, less effort, less bureaucracy. Yet anyone who reads the consultation paper quickly sees that "minus 50 per cent" is not what ultimately lands on the desks of reporting functions. In the same package, the EBA integrates new requirements from International Financial Reporting Standard 18 (IFRS 18), from the prudential treatment of Environmental, Social and Governance (ESG) risks, and from the revised market risk framework under the Fundamental Review of the Trading Book (FRTB). What the EBA presents as simplification is in truth a two-sided coin: significant deletion of established data points – combined with the addition of new reporting areas whose operational burden has not yet been factored into the budgets of many institutions.

What the EBA is actually proposing

Modular structure rather than monolithic reform

The consultation paper is deliberately modular. Instead of a single, hard-to-steer overall reform, the EBA presents nine thematic modules that can be commented on separately: liquidity and asset encumbrance, Financial Reporting (FINREP), operational risk losses, integration of EU-wide stress test reporting, market risk and FRTB, Common Reporting (COREP) on own funds, ESG reporting, alignment with Pillar 3 disclosures for Small and Non-Complex Institutions (SNCIs), and a set of further targeted amendments. This architecture is more than a formality: it allows institutions to respond with differentiated expertise and priority – the treasury function on the liquidity module, the market risk team on the FRTB module, the finance function on FINREP and IFRS 18.

EBA Chair François-Louis Michaud justifies the approach in the press release with a phrase that supervisors and the industry can each claim half of: "The new approach would reduce unnecessary burden while preserving the quality and relevance of the information supervisors need. It should also support easier data sharing and more integrated reporting across Europe." Behind the diplomatic formulation lies a structural promise: the EBA wants to engineer the transition from a logic of granular individual reporting to a logic of single, multi-purpose data sources. Rather than supervisors, macroprudential bodies and resolution authorities each requesting similar but non-identical datasets in parallel, the medium-term aspiration is an integrated data space.

The sharpest lever: deletion of redundant data points

Concretely, the EBA is deleting data points whose supervisory value has fallen well behind the cost of collecting them over time. In FINREP, this affects a range of breakdowns whose steering relevance has, from the Single Supervisory Mechanism (SSM) perspective, become marginal. In COREP, duplicate reports that have accumulated through layered reporting generations are to be removed. There is also a structural simplification: banking groups will in future be able to file many reports only at the highest EU consolidation level, no longer at every sub-consolidation step.

The integration of EU-wide stress test reporting into regular reporting deserves particular attention. Until now, stress test data have been requested as an ad hoc submission once or twice a year – with their own templates, validation rules and a parallel data preparation workstream in many institutions. The EBA promises to dissolve this parallel data factory: stress-test-relevant data points will become part of regular reporting, and the annual special collection will be eliminated. If this works as planned, it represents one of the largest operational efficiency gains of the reform – not through deletion, but through consolidation.

The other side: what is being added

IFRS 18: a deadline within the deadline

Anyone who skims the consultation paper easily misses that the IFRS 18 module carries its own, significantly earlier deadline: 10 May 2026 instead of 10 July. The reason is a temporal constraint. IFRS 18 – "Presentation and Disclosure in Financial Statements" – becomes mandatory from the 2027 financial year. The EBA must finalise the FINREP adaptations for IFRS 18 promptly so that banks can incorporate the revised templates into their IFRS 18 implementation projects. The tight deadline in the IFRS 18 module reflects operational necessity, not regulatory caprice – but it forces the finance function to address this module with high priority and ahead of the others.

Substantively, IFRS 18 brings two main areas for FINREP reporters: the new structuring of the income statement with mandatory subtotal categories, and the disclosure of Management-defined Performance Measures (MPMs). Both must be reflected in FINREP templates, which requires a non-trivial adaptation of the reporting architecture. Anyone who fails to use the consultation lever here accepts the EBA's interpretation and has to live with it.

ESG reporting: from annex to mandatory information

The ESG module integrates the prudential treatment of climate and environmental risks into standard reporting. The EBA is following a line that the SSM has already mapped out in its supervisory priorities for 2026–2028: ESG risks are no longer a separate agenda but a component of prudential supervision. For many institutions that have processed ESG data in separate data flows so far, this raises a fundamental architecture question: will ESG data in future be carried in the core reporting data model, or will a separate ESG data factory with an interface to reporting persist?

The ESG data in EBA/CP/2026/07 should not be conflated with the sustainability reporting wave under the Corporate Sustainability Reporting Directive (CSRD). What is at stake here is supervisory ESG reporting under Article 430 of the CRR – data that serve prudential risk measurement and monitoring, not sustainability disclosures to investors. The two reporting worlds overlap on the data side but are regulatorily and methodologically distinct. Anyone who fails to draw a clear line risks costly duplication.

FRTB: market risk reporting for a new world

The FRTB module reflects the transition to the revised market risk framework under CRR3. The new templates must depict the Internal Models Approach (IMA) and the Standardised Approach (SA) in their revised form. For banks with substantial trading books, this is the operationally most relevant addition in the entire consultation paper – the requirements are quantitatively and methodologically demanding, and deriving them from FRTB models requires data flows that are not yet in reporting quality at many institutions.

Simplification or deregulation? The supervisory perspective

Escrivá's two sentences and their subtext

In his BIS speech "Regulatory and supervisory simplification" of 25 November 2025, José Luis Escrivá foreshadowed what the EBA is now implementing – but he tied it to a condition. The first of his core sentences names the data volume: 740 statements, 116,000 data points per institution and reporting date, two thirds of them under the European FINREP and COREP standards. On top come ad hoc requests in areas where the standard reports leave gaps. The second sentence is the decisive one: "Less information, but of higher quality, would mean more efficient supervision and a lower burden for institutions." That is not the same as "minus 50 per cent data points." It is a qualitative statement that conditions the quantitative reduction.

Escrivá adds another sentence that should not be forgotten when reading the EBA paper: "Simplification does not mean deregulating or weakening the sector. On the contrary, it is about building a simpler, more stable and predictable framework." This rhetorical construction has appeared with striking frequency in supervisory documents over recent months – an indication that the conflation of simplification and deregulation is widespread in the market and is being actively addressed.

The line between simplification and effectiveness loss

The intellectually interesting question of the consultation paper is not whether 50 per cent is too much or too little. It is the question of where the boundary runs between simplification and the loss of supervisory effectiveness. Escrivá himself supplies a yardstick: "The growing Level 2 and Level 3 rulebook does not just entail high costs for institutions – it can even erode supervisory effectiveness." Translated: a too-detailed reporting obligation eventually produces more noise than signal, and supervision becomes ineffective. The EBA paper accepts this logic – it essentially deletes data points whose signal-to-noise ratio has, from the supervisors' perspective, fallen below a critical threshold.

This also makes clear what the paper is not: a gift to the industry. Cutting data points that supervisors themselves consider unhelpful brings operational relief in delimited areas. Anyone who hopes that the central risk indicators – on liquidity, own funds or credit risk models – will be substantively eased will be disappointed. In the core areas of prudential supervision, the data demand remains dense.

The industry position: EBF between approval and subtext

Substantive approval with semantic reservation

A direct response from the European Banking Federation (EBF) to EBA/CP/2026/07 had not been issued by the end of April 2026 – the consultation window runs until July, and federations use the time for internal consultation with their member banks. Yet the EBF position has become clear through its response to the parallel European Commission consultation on the competitiveness of the banking sector dated 19 April 2026. The EBF explicitly supports "reducing cumulative regulatory and reporting burdens by eliminating duplications and disproportionate requirements, in line with the simplification agenda."

Notable is a second EBF position that complements the EBA narrative substantively while questioning it semantically: "One of them is 'simplification without deregulation'. EU regulation is massive and extremely complex. Certain parts are effective and useful, whereas others are duplicated, cumbersome, and inefficient. Legislators should preserve the effective parts of the regulation but should not hesitate to reform or undo the unnecessary parts, especially gold-plating." With this, the EBF takes a position that Escrivá rhetorically rules out: the industry considers deregulation in clearly delimited areas desirable. That is not a contradiction to the EBA, but a tension – and it shows that the consultation is not just a technical but a normative debate about the right level of supervisory data demand.

German federations: no public signal so far

Neither the Association of German Banks (Bundesverband deutscher Banken, BdB) nor the German Savings Banks Association (Deutscher Sparkassen- und Giroverband, DSGV) had issued a public statement on EBA/CP/2026/07 by the end of April 2026. This is not unusual – federations typically calibrate their position only after internal member consultation. For German institutions, this means that federation channels must be actively used now: anyone who wants to feed specific concerns into the EBF or BdB statement must address this in May via the federation channels.

What this means for German banks in concrete terms

Net relief depends on the portfolio

The headline "minus 50 per cent data points" obscures an important fact: the reduction is not evenly distributed across institutions. Banks with large trading books will face additional burden in market risk reporting through FRTB, which can partially or fully offset the deletions in other modules. Banks with complex ESG exposures – for instance in the energy and transport sectors – bear the brunt of the ESG module additions. Smaller and non-complex institutions (SNCIs) benefit disproportionately because the consultation paper substantially simplifies Pillar 3 disclosure requirements for them and additionally allows SNCIs to consolidate at the highest EU level.

The consequence is that no blanket statement on net relief can be made for the German market. Each institution must conduct its own module-by-module analysis – which data points fall away from which module, which are added, how does aggregate effort change. This analysis is not just a reporting exercise; it is the basis for a substantiated consultation response that goes beyond a blandly approving formula.

Reporting architecture: the second wave of modernisation

The larger strategic question behind the consultation paper is whether German banks will use the opportunity to modernise their reporting architecture. Many institutions today operate a reporting landscape that has grown over years, with fragmented data flows, manual handovers between front office, risk, treasury and finance, and a high dependency on Excel-based reconciliations. Deleting redundant data points alone does not improve this architecture. The integration of stress test reporting, the ESG module and the FRTB requirements do, however, force architectural decisions that are overdue anyway: unified data models, single sources of truth, automated data flows and real-time validation.

Anyone treating the consultation paper merely as an ITS update that can be handled with adaptations to the existing reporting tool risks underestimating the operational burden in the implementation phase 2026/2027. Anyone using it as the trigger for a reporting architecture reform can extract the structural efficiency gains in the medium term that Escrivá set out as the goal.

Module	Direction	Who is affected
FINREP / IFRS 18	Addition – new P&L structuring, MPMs in FINREP templates	All IFRS reporters; separate deadline 10 May 2026
FINREP / Deletions	Reduction – removal of redundant breakdowns	All FINREP reporters; largest effect for big consolidation groups
COREP own funds	Reduction – removal of duplicate reports	All CRR institutions
Market risk / FRTB	Addition – new templates for IMA and SA under CRR3	Banks with trading books; largest operational effort
Liquidity / Asset Encumbrance	Reduction – deletion of little-used breakdowns	All CRR institutions
ESG reporting	Addition – ESG data integrated into standard reporting under Art. 430 CRR	All CRR institutions; largest burden for carbon-intensive portfolios
EU-wide stress test	Consolidation – integration into regular reporting, removal of the ad hoc exercise	All institutions subject to direct EBA stress testing
Pillar 3 / SNCIs	Reduction – simplification of disclosure requirements, consolidation at highest EU level	Small and Non-Complex Institutions; clear beneficiaries
Operational risk losses	Adjustment – alignment with the final CRR3 treatment	All CRR institutions

The consultation as a strategic lever

Public hearing on 5 May – the window is narrow

Registration for the public hearing on 5 May 2026 closed on 28 April – before this article appears. Anyone attending the hearing has registered already; anyone who missed it can follow the session retrospectively via the EBA website once the recording becomes available. EBA public hearings are in practice the last opportunity to address clarifications, concretisations and conflicts directly with the EBA and its staff in a structured format. A well-placed question there not infrequently shapes the later interpretation in the final paper.

Written consultation response: the actual work

The written response to the EBA is the substantive lever. It should not consist of blanket approval but of an institution-specific analysis of module-by-module impacts and concrete change proposals with rationale. A well-constructed consultation response follows a three-tier scheme: first, a fundamental position on the reform direction; second, module-specific comments with concrete additional data point deletions or rejections of additions; third, technical comments on definitions, validation rules and transitional provisions.

One point deserves particular attention: the transitional provisions. The EBA plans the first reporting under the revised framework as of 30 September 2027. Measured against what many institutions consider a reasonable implementation period, that is an ambitious deadline. Anyone who wants to propose transitional easements, staggered application or materiality thresholds must formulate this concretely in the written consultation response. General calls for "more time" are, in EBA consultations, experienced not to be taken up.

Activate federation channels – but do not delegate

Most German institutions will additionally or exclusively comment via their federation channels – BdB, DSGV, the Association of Foreign Banks in Germany, and the Association of German Public Sector Banks (Bundesverband Öffentlicher Banken Deutschlands, VÖB). These federation statements matter because they condense the collective industry position. They are not, however, a substitute for an own consultation response if an institution has specific concerns that the federation response does not adequately cover. Specific business model implications, unique portfolio structures, technical reporting architecture constraints – all of this belongs in an own response, not in the federation voice.

Operational implications beyond the consultation

The implementation window to September 2027

Even when the consultation phase is over and the final ITS are issued in late 2026 or early 2027, the implementation window to 30 September 2027 remains surprisingly short. Realistically: initial architecture decisions must still be taken in 2026, data flows for the new modules (FRTB, ESG, IFRS 18) must be built in 2026/2027, and test runs for the first reporting should take place no later than the second quarter of 2027. Anyone who waits for the final paper before starting on the architecture work loses implementation time that cannot be recovered later.

Concretely: the modules with the largest new requirements – FRTB, ESG, IFRS 18 – must be set up now in parallel with the consultation response, because the requirements are substantively in place. The question is not whether but how. The consultation can turn detail screws but cannot prevent the addition of these modules.

The supervisory signal: what the EBA is saying about supervision from 2027 onwards

The consultation paper is not just a technical ITS update but a signal about the direction of supervision in the coming years. The EBA and the SSM are moving – this becomes visible in the modular structure and the rationales – from a logic of broad data demand to a logic of targeted data use. Data points that do not actively feed into supervisory decisions are deleted. Data points that are decision-relevant for the new risk areas (ESG, market risk under FRTB) are added. The implication is clear: supervision will become more selective, more data-intensive in the focused areas, less comprehensive in breadth.

For risk and compliance functions this means: the reporting strategy of the coming years must align with supervisory priorities – not with a blanket compliance logic. What supervisors observe intensively must be reported intensively; what they no longer observe can be served with less effort. That is a different reporting philosophy from the past ten years.

Recommendations

For German institutions, what matters now is to use the remaining consultation window strategically and to sharpen the implementation architecture in parallel. Five steps belong on the agenda for the coming weeks: