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EBA Guidelines on additional reporting and disclosure requirements in the context of COVID-19


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On 2 June 2020 the European Banking Authority (EBA) issued Guidelines on reporting and disclosure of exposures subject to measures applied in response to the COVID-19 crisis.

The EBA Guidelines specify new reporting and disclosure requirements to be applied by competent supervisors in their supervisory practices. For some reporting requirements, supervisors may apply the principle of proportionality.

Only part of data reported under the EBA Guidelines mandatory for FIN-FSA-supervised LSIs

The Financial Supervisory Authority (FIN-FSA) will implement the EBA’s COVID-19 reporting so that, at least for the time being, less significant institutions (LSIs) will not be required to report templates subject to the competent authority’s discretion. Therefore, the mandatory templates to be reported are templates 90.01, 91.01 and 91.05. In respect of templates 90.01 and 91.01, the reporting requirement also concerns activities of supervised entities in other countries where EBA-compliant moratoria have been applied.

The templates should be reported at the highest level of consolidation, but not at sub-consolidated or solo level if an institution reports data at the sub-consolidated level.

The reported data should be submitted in XBLR format.

Reporting by FIN-FSA-supervised LSIs starts from the situation as at 30 September 2020

The EBA Guidelines will enter into force once their official translations have been published, and, according to the Guidelines, the first data submission concerns the situation as at 30 June 2020. However, the FIN-FSA has decided to postpone the start of reporting so that the first data submission by LSIs will be from the situation as at 30 September 2020. This will give time for the publication of the Guidelines in Finnish and Swedish and for their incorporation in the FIN-FSA regulations and guidelines, and will give banks a reasonable period of time for the required systemic changes.

FIN-FSA does not require disclosure of information with the EBA Guideline’s disclosure templates

The FIN-FSA does not require LSIs to disclose information according to the relevant templates of the EBA Guidelines. However, it should be noted that institutions should disclose, in accordance with the EU Capital Requirements Regulation (CRR), all material information on their risks and capital adequacy and carefully consider what additional information they should disclose considering the coronavirus situation.

For further information, please contact

  • Torsten Groschup, Senior Risk Expert, telephone +358 9 183 5333, or torsten.groschup(at)
  • Jaana Ladvelin, Senior Capital Adequacy Expert, telephone +358 9 183 5313, or jaana.ladvelin(at)
  • Tommi Aarnio, Risk Specialist, telephone +358 9 183 5007, or tommi.aarnio(at)


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Regulator Information

Abbreviation: FIN-FSA
Jurisdiction: Finland

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