Subject:
Annex to sector letter banks April 2015 on supervisory reporting
This Annex lists the most important changes and amendments for the 2015 reports:
•Tighter data quality requirements
•Changes in data submission notation
•Changes in the reporting forms
•News on e-line DNB
- Tighter quality requirements for reports
1.1Validation rules and blocking rules
On 10 March 2015, the EBA issued an update of the validation rules applicable as of the March 2015 reference period: version 2.2, which is valid for the reports up to and including May 2015.
Effective from the March 2015 reference period, the EBA also introduced a number of blocking rules (see column H, 'severity' in the EBA Validation Rules document). If a blocking rule is activated for a report, the corresponding form set cannot be submitted to the ECB/EBA. In that case, both DNB and the banks are required to resubmit the form set as soon as possible (see also Section 2 of this Annex). For more information, please refer to the EBA website:
1.2EBA publication of validation rules and updates
The EBA issued an update of its validation rules (DPM 2.2) on 10 March 2015 in accordance with its new procedure aimed at timely publication of applicable validation rules. The EBA publishes the specifications of validation rules at least three weeks before the end of the reference period – i.e. in this case at least three weeks before 31 March.
1.3Validation rules and DNB validation testing as of Q1 2015
As explained in previous sector letters, banks must apply all EBA validation rules themselves prior to submitting their reports. The introduction of blocking and non-blocking validation rules does not exempt the banks from this obligation. As in the previous periods, DNB will continue to test the EBA validation rules on a partial basis, i.e. only the validation rules contained within a single form set and not all EBA validation rules. On 8 April 2015 an overview of the set of validation rules not assessed by DNB was published on the e-Line DNB news page.
The DNB validation test for the reference period starting from March 2015 will be available as of 20 April (this applies to the LCR reports on March 2015).
On 21 April, DNB will publish an updated set of validation rules on the e-Line DNB news page. This set contains EBA validation rules that could not be included in previous versions due to technical limitations. The DNB validation test will now better match the EBA validation rules, albeit still not completely. The DNB validation test will be available as of 27 April and can be applied to all CRD IV reports. This test only excludes those validation rules that are deactivated by the EBA and the cross checks between different form sets. Effectively this means that DNB, contrary to previous reporting periods, will no longer deactivate validation rules of its own accord.
As a bank, you are required to apply all EBA validation rules, except for those that are deactivated by the EBA. An overview of the applicable EBA validation can be found on the EBA website,
If you encounter an active EBA rule that is incorrect or impossible to apply in your opinion, please report this via
1.4Large exposure templates (reporting and applicable limits)
DNB has found that many banks report the large exposure limits in the C26.00 form incorrectly. As a result, the size of exposures relative to the limit is incorrect. Below is an instruction on how to correctly report the large exposure limits.
In principle, the limit is 25% of eligible capital and should be reported in line 220 of the C04.00 template. For exposures to non-institutions this applies in all cases; for exposures on institutions deviating limits may apply. The formula below gives the applicable limit:
If 25% of eligible capital is less than EUR 150 million, a limit of EUR 150 million applies – unless this is more than 100% of eligible capital, in which case a limit of 100% of eligible capital applies.
For more information, see the following document:
Please note: DNB and the ECB, as the competent authorities, may impose a lower limit on an institution.
1.5Early submission of reports
As indicated in the previous sector letter, it is always possible to submit reports before the applicable official submission deadline. This will help both DNB and you to have better and validated reports ready on the date of the submission deadline. It will also help prevent surprise findings, since DNB does not test all EBA validation rules and is not responsible for the banks' validated reports submitted to the ECB/EBA. The deadline continues to apply, of course:
On the date of the submission deadline at the latest, every bank must submit a report that satisfies the statutory requirements, including compliance with all EBA validation rules.
1.6DNB carries out additional checks
DNB has started to carry out additional checks on data quality. The use of data – and consequently the quality of that data – is crucial in the current supervisory framework. Carrying out additional checks is a key instrument in our quality improvement efforts.
The method comprises various types of checks: On the one hand, Finrep and Corep are independently assessed on plausibility and consistency. Plausibility checks focus on the logic behind the figures, while consistency checks monitor whether figures are matching where they are supposed to do so. On the other hand, Finrep and Corep are matched. DNB also compares the supervisory figures to the legal requirements, and in the future they will be matched with the figures from the banks' annual reports.
The checks are gradually phased in. DNB is now testing the checks for correct operation in a pilot comprising a number of banks. In the next phase, the method will be rolled out to the other banks. All checks will be announced in advance, so that you will know what we will be focusing on. This phase is set to start in June (Q2 2015).
The checks complement the EBA validation rules and will not constitute a blocking factor for data submission to the ECB.
- Changes in data submission notation
Banks are used to submitting their regular supervision reports in thousands of euros. The EBA Data Point Model (DPM) assumes data submission in single euros, however. To date, for the submission of ITS data (in XBRL format), DNB has multiplied the data by 1,000 in order to comply with the notation requirements for the EBA as well as the ECB.
The EBA's XBRL validation process also prescribes a method for applying rounding margins to the validation rules. This method assumes a maximum rounding margin of 500 for reports submitted in single euros, which is smaller than that currently applied by DNB (in practice this is now 5, so 5,000) and also smaller than the minimum reporting unit of 1,000 in the current Dutch situation.
This means that reports that are found valid by DNB may be rejected by the ECB and the EBA in the near future as a result of a too large variation in rounding margins. The introduction of blocking rules (see also Section 1.1 of this Annex) to be applied by the EBA to reports submitted as from the first quarter of 2015 causes this issue to become critical in submitting data to the ECB and the EBA, as the EBA is bound to reject such files submitted by DNB.
DNB, the Dutch Banking Association (NVB) and the banks recently discussed the matter in order to try and find a solution.
It has been agreed that the banks will submit their CRD IV[1] reports in single euros as of Q3 2015 (first submission deadline: 15 October 2015, for the September monthly report) and extend the percentage fields to include more decimals, and that all banks will start applying this reporting procedure at the same time. DNB will adjust e-Line DNB to this end.
Submitting reports in thousands of euros until Q3 2015 means that these might be rejected by the ECB and the EBA as a result of blocking validation rules (including too large variations in rounding margins).
Therefore, it has also been agreed that as of Q1 2015 the banks will only submit (in the current e-Line DNB application) reports in thousands of euros that are fully correct. This means that no EBA validation rules should be triggered and that rounding variations of 1 (i.e. 1,000) are considered too large to submit the reports to the ECB and the EBA in case of blocking rules.
That is why we no longer include a provision to deal with margin variations (previously a margin of up to 5 was possible) as from our Q1 validation report.
If your institution is unable to submit correct data for a validation rule, please let us know at your first data submission.
We will only implement the adjustments for CRD IV reports, including those that have not yet started. The SE reports, payment system reports, interest rate risk reports, liquidity reports 8028 and 8029, sector concentration reports and other regular or incidental container reports remain unchanged.
By submitting your reports early (see also Section 1.5 of this Annex), before the final data submission deadline (for Q1 2015 this is 12 May 2015), you can help us anticipate in good time on new or changed validation rules.
- Changes in the reporting forms
3.1 Finrep reports for Title 9 reporting entities
Following the implementation of Phase 1 of the Non-IFRS Banks Financial Information data submission request, Phase 2 will be implemented as of March 2015. This will involve a request for additional templates. The Finrep GAAP forms for the March 2015 reporting period have been available in e-Line DNB from 1 April 2015, both in the production and the simulation environment. The XML specifications were published on e-Line DNB's news page on 2 April 2015. See
3.2 Additional Liquidity Monitoring Metrics
New reports will be introduced with effect from 1 July 2015 to supplement the LCR and NSFR liquidity reports. Depending on proportionality, these will be either monthly or quarterly reports. An extended submission deadline will apply on a transitional basis for the reporting period until December 2015, with the deadline being the 30th calendar day of the month following the reporting period. The first report on July 2015 must be submitted by Monday 31 August 2015 at the latest. With effect from the December 2015 report, the submission deadline will be set in line with the ITS deadline for monthly reports, i.e. the 15th calendar day (which is equal to the LCR report deadline). The first report on December 2015 must be submitted by 15 January 2016 at the latest. We will inform you in good time about submission of the forms in e-Line DNB and the XML specifications. More information is available via the following link:
3.3 Funding Plans
June 2015 will be the first reporting period for significant banks in which they have to report their funding plans using EBA templates. These plans must be submitted every six months, in line with the data submission deadlines for the ECB's Short Term Exercise (STE) templates. The final submission deadline for June 2015 data is set at 1 September 2015. For the other banks (LSIs) these reports are not yet mandatory. We will inform you in good time about submission of the forms in e-Line DNB and the XML specifications. DNB will use the data from e-Line DNB for the ECB's STE data collection: you do not have to resubmit these data yourself.
See the Open Book page for more information on this topic.
Instructions, guidelines and templates for the funding plans can be found on the EBA website:
3.4Amendments to Corep and Finrep as of June 2015
The EBA has also published amendments to the Corep and Finrep (IFRS and GAAP) forms with effect from June 2015. These changes will also be processed in e-Line DNB by June 2015. Most of them concern adjusted text labels and some of them relate to the locking and unlocking of cells. We will inform you in good time about submission of the forms in e-Line DNB and the XML specifications. See also the EBA's publication of 18 March 2015:
- E-Line DNB
4.1 e-Line DNB opening hours
With effect from April, the e-Line DNB opening hours have been extended. On working days, you can now log on until 10 p.m. instead of 8 p.m.
e-Line DNB is not available during the weekend and on holidays. For technical support you can contact DNB's ICT Servicedesk on working days from 8 a.m. to 6 p.m. Due to daily maintenance work on the DNB systems it is not possible to make e-Line DNB available between 10 p.m. to 7 a.m. on working days, during the weekend or on holidays. In incidental maintenance-related cases, DNB reserves the right to close e-Line DNB early. We will inform you about this at least a week in advance on the e-Line DNB news page ( provided the urgency of the maintenance and repairs allow for this. We will evaluate the extension of opening hours after six months.
Please note that DNB technical support for questions or disruptions is not available between 6p.m. and 8 a.m.
4.2 Submitting nil reports in E-Line DNB
Some reporting entities still submit 'empty' reports for reports that are not applicable to their organisation. We advise you to let us know that a certain form is not applicable to your organisation by submitting it as a nil report in e-Line DNB. You can do this by clicking the 'nihil verkl.' button at the bottom of the relevant form. Next, save the form.
4.32014 certification and container reports
Every year, banks have to have their reports certified by the external auditor. The final submission deadline for the auditor's report is 30 June 2015, with a best efforts obligation deadline of 31 May 2015 (as agreed in the tripartite consultation with the Netherlands Institute of Chartered Accountants (NBA) Sectoral Committee for Banks, Investment Institutions and Investment Firms (SBB) and the NVB). Certification is required for all consolidation levels, i.e. consolidated, subconsolidated and solo.
Annex 7 to the Regulation on Statements of Financial Undertakings under the Wft 2011 provides an overview (in Dutch only) of reports for which certification is required. See:
The new CRD IV reports for Leverage Ratio, LCR, NSFR and Asset Encumbrance are not subject to the certification requirement.
Please note:
National reports 8028 and 8029 (liquidity test) are also not subject to the certification requirement, and neither is the request for submission of financial information (Finrep F.01.01 to 02.00) for branch offices. The Regulation will have to be amended in this respect.
This year, DNB has requested the banks to submit their auditor's reports through e-Line DNB rather than by mail or e-mail. DNB is developing a reporting form for this purpose, in which institutions can upload one or multiple attachments. The reporting requirement for the December 2014 period will be available in e-Line DNB as of end-April 2015.
Date17 April 2015 / Reference
2015/266418 / Page
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[1] FINREP, COREP, Asset Encumbrance, LCR, IP Losses, Additional Liquidity Monitoring Metrics, Funding Plans and Benchmark.