EBA Guidelines on the resubmission of historical data for investment firms

Previously, European legislation required without exception to correct previous reports when errors or inaccuracies were discovered. These guidelines provide a framework to alleviate this burden to some extent. De Nederlandsche Bank (DNB) will immediately act in accordance with these new EBA guidelines. This is explained below. This page clarifies the EBA guidelines, which remain leading.

Institutions are expected to attach importance to the submission of high-quality data to the supervisor. We consider data, including prudential reports, to be a crucial tool for good and efficient supervision. Data-driven supervision is the starting point for DNB's risk-based supervision. The quality of prudential reporting is therefore crucial. In this way, DNB can use its available resources efficiently.

Nevertheless, errors can occur in supervisory reports. The European framework stipulates that when errors are detected in current and/or historical data by the reporting institution or by the competent authorities, the submitter of the reports is obliged to correct these data immediately and without restriction. The EBA guidelines introduced on 17 October 2024 new guidance on how far back in time the historical resubmission should go.

There are two different ways in which an institution may be required to submit a resubmission. If the institution itself identifies the error, it will have to inform DNB and we will open up a resubmission obligation. DNB will also open up a resubmission obligation if an error is detected by DNB.

The EBA guidelines distinguish on the basis of the frequency of the relevant reporting. In general, institutions are expected to resubmit corrected data for the current reference date and/or for previous reference dates going back at least one calendar year. For each reporting frequency, the following applies:

• Annual reporting: resubmission of historical data for at least the previous calendar year (one reference date in addition to the reference date of the current data).
  
  
• Quarterly report: resubmission of historical data for at least the previous calendar year (four reference dates in addition to the reference date of the current data).

The guidelines also allow DNB to request the resubmission of historical data for more reference dates than required at any time, if this is necessary for the performance of its statutory or supervisory tasks. Such a request should be proportionate to the materiality of the errors in previously reported data and to the institution’s risk profile or prudential requirements.

In summary, this amounts to the following:

• If errors have only been detected in the last report, the institution must resubmit them.
• If errors in the most recent reports have consequences for previous reports, the institution must also resubmit the historical reports in accordance with the above scale.
• If errors are detected in a report older than 12 months, the supervisor may request the institution to resubmit that report and the subsequent reports until the first report in which the errors have been corrected.

Finally, we note that errors that fall within the tolerance limits or thresholds, as laid down in the already agreed submission rules (Reporting frameworks European Banking Authority), do not have to be re-reported. See paragraph 24b of the EBA Guidelines.

Implementation

If you discover errors in the submitted reports, you must request DNB to open one or more resubmissions. This also implies consistency between the audited annual report and the reporting dates of the relevant year.

For questions, please contact investment firm.rap@dnb.nl.