EBA final report on ITS for TCB supervisory reporting under CRD6

On 5 March 2026, the European Banking Authority (the EBA) published its final report on the draft Implementing Technical Standards (ITS) specifying supervisory reporting requirements for third-country branches (TCBs) operating in the EU and their head undertakings (HUs), incorporating significant simplifications following industry feedback.

Background

In July 2025, we reported on the EBA's consultation on draft ITS issued under Article 48l of Directive 2013/36/EU (CRD6), which specify the supervisory reporting requirements for TCBs operating in the EU and their HUs. The consultation closed on 31 October 2025, and the EBA received three responses, of which two were made publicly available.

The EBA has now published its final report (EBA/ITS/2026/01), incorporating a series of targeted adjustments to improve clarity, proportionality, and operational feasibility, while streamlining the framework. These changes respond to two parallel drivers: the feedback received from stakeholders during the consultation process and the strategic direction set by the EBA's governing bodies as part of a wider programme to streamline supervisory reporting and reduce costs.

The final ITS proposes two sets of templates: information requirements concerning the TCBs themselves (Annex I) and information requirements regarding their HUs (Annex II). Proportionality continues to be addressed through the "core + supplement approach" applied to Class 1 and Class 2 TCBs, with a core set of data points applicable to all TCBs and additional information required only for Class 1 TCBs.

Below we highlight the principal changes from the consultation and their implications for TCBs and their groups. We cover this update in our CRD6 Manager product. See more details of that here: CRD6 Manager.

Key implications for TCBs and HUs

The postponement of the first reporting reference date to 31 March 2027 provides welcome relief for firms. However, TCBs and their HUs should not be complacent. The reporting requirements remain substantial and will require significant operational investment, particularly regarding:

• System architecture changes to integrate new templates into existing reporting software and data-governance frameworks;
• Data lineage mapping to link EU branch reporting with head-office systems, often located in jurisdictions with different regulatory definitions and privacy rules;
• IT and staff training investments to ensure data quality and internal validation of new data fields, particularly the qualitative HU information (business strategy, recovery plans, supervisory assessments); and
• Coordination between TCBs, HUs, and other group entities to ensure timely exchange of information, particularly for the quarterly reporting of templates H 01.00 and H 02.00.

Key changes from the consultation paper

The final ITS introduces several significant changes compared to the consultation paper. The key amendments are summarised below.

1. Extended timeline and implementation period:

The most significant change concerns the initial reporting reference date. Under the consultation paper, the first reference date was proposed to be December 2026, effectively giving TCBs and HUs an implementation period of approximately one year.

Consultation paper (July 2025): The first reporting reference date was proposed to be December 2026, with the ITS applying from 28 December 2026.

Final Report (March 2026): The first reporting reference date has been postponed to 31 March 2027, with the ITS applying from 28 March 2027. This provides a full one-year implementation period and avoids 2026 data collection.

Implication: This change directly addresses stakeholder concerns about the feasibility of the original timeline, particularly regarding technology budgets, the availability of HU data, and the need for system architecture changes. This provides TCBs with additional time to adapt their internal systems and processes and avoids any data collection requirements for 2026. Firms should use this additional time to ensure operational readiness.

2. Extended remittance deadlines for Annex II templates:

The final ITS also extends the remittance deadlines for Annex II templates (i.e. HU reporting) by one month compared to the consultation paper.

Consultation paper: Remittance deadlines for information on the HU in Annex II were aligned with those for Annex I (TCB reporting).

Final Report: Remittance deadlines for Annex II templates have been extended by one month to accommodate differences in third-country accounting calendars and data availability constraints.

The revised remittance dates for Annex II are now as follows:

• Quarterly reporting: 11 June, 11 September, 11 December and 11 March (previously 12 May, 11 August, 11 November and 11 February);
• Semi-annual reporting: 11 September and 11 March (previously 11 August and 11 February);
• Annual reporting: 11 March (previously 11 February).

Implication: TCBs will have additional time to collect, validate, and transmit HU data, which was a key concern raised during the consultation, particularly for branches with limited access to group systems or where home-country filing dates fall after EU deadlines.

3. Flexibility for non-calendar financial year ends:

Consultation paper: The consultation paper allowed TCBs to adjust reporting reference dates where they report based on a non-calendar accounting year-end.

Final Report: Articles 1(3) and 2(3) have been revised to extend similar flexibility where the HU is permitted by its home supervisor to submit regulatory metrics based on fiscal rather than calendar quarters.

Implication: This provides greater flexibility for TCBs where the HU operates on a different financial year-end, reducing the burden of reconciling data across different reporting periods.

4. Simplification of template (E 01.01):

Consultation paper: Template E 01.01 for Class 1 TCBs required originated amounts to be split by whether the TCB retains continuing involvement (columns 0050 and 0060).

Final Report: Columns 0050 and 0060 have been removed from template E 01.01. The EBA acknowledged that this requirement exceeded what is mandated in the Level 1 text.

Implication: This reduces the complexity of the reporting template and removes a requirement that respondents argued exceeded the CRD mandate.

5. Streamlining of the reverse solicitation template (H 04.00):

Template H 04.00, which addresses services provided by the HU on the basis of reverse solicitation, has been significantly streamlined.

Consultation paper: The July 2025 version of Template H 04.00 required granular country-level reporting, including:

• Total amounts for reverse solicitation activities across the Union
• A breakdown for the 1st EEA country (the EEA country with the largest associated assets)
• A breakdown for the 2nd EEA country (the EEA country with the second largest associated assets)

This resulted in 9 rows of data: 3 activities × 3 levels each (Total, 1st EEA country, 2nd EEA country). The intended supervisory insight was to provide competent authorities with a view of the geographic distribution of reverse solicitation activities within the Union, allowing them to identify which Member States were most exposed to services provided by HUs on this basis.

Final Report: The template has been significantly streamlined. The March 2026 version removes the country breakdowns entirely, retaining only Union-wide totals for each activity type (taking deposits, lending, guarantees and commitments). The template now has just 3 rows instead of 9. Other amendments include:

• References to the ultimate HU have been removed.
• Granular country breakdowns have been deleted.
• Revenue columns have been removed.
• Instructions have been clarified to confirm that figures should be aggregated rather than consolidated.

Implication: This is a welcome simplification that addresses stakeholder concerns about the impracticality and operational burden of the original template, particularly regarding the determination of "associated net revenues" and reporting at the level of the ultimate HU.

Supervisory Trade-off

The streamlined template shifts the supervisory objective from detailed geographic monitoring to aggregate compliance monitoring:

• Lost insight: Competent authorities will no longer have visibility over which specific Member States are most affected by reverse solicitation activities from HUs. This limits their ability to assess cross-border concentration risk at a granular level.
• Retained insight: Supervisors will still be able to monitor the overall scale of reverse solicitation activities (assets, liabilities, and off-balance sheet items) by activity type, which remains sufficient to verify compliance with Article 21c of the CRD.

The EBA determined that the aggregate data collected remains adequate to allow competent authorities to carry out monitoring of transactions entered into on the basis of reverse solicitation, while significantly reducing the operational burden on reporting entities.

The aggregate Union-wide totals are considered sufficient because the core supervisory objective under Article 21c is to detect whether reverse solicitation is being used as a substantial business channel (indicating potential circumvention) rather than an occasional exception. This can be assessed through total volumes of assets, liabilities, and off-balance sheet items associated with reverse solicitation activities, without requiring a geographic breakdown that would add operational burden without commensurate supervisory value.

6. Enhanced proportionality for Class 2 TCBs:

Final Report: The EBA has enhanced proportionality, including less frequent reporting for Class 2 TCBs and simplification of several data collections. For templates related to the HU (Annex II), proportionality has been applied at the frequency level, with Class 2 TCBs reporting semi-annual templates on an annual basis instead.

Implication: This reflects feedback from respondents that the original proposals were onerous for smaller branches with limited resources.

7. Clarification on aggregation versus consolidation:

Final Report: The EBA has clarified that HU reporting requires aggregation (summing individual stand-alone figures) rather than consolidation. This addresses concerns raised by respondents about the practicality of producing consolidated figures on a quarterly basis.

Implication: This clarification reduces the operational burden on TCBs, particularly those without visibility over other group entities' EU exposures or the ability to consolidate data using common accounting frameworks within the required timelines.

8. Structural improvements to Annex II templates:

Consultation paper: Templates in Annex II required separate submissions for different HUs.

Final Report: A z-axis dimension has been introduced across most templates in Annex II, enabling multiple HUs to be reported at the sheet level within a single submission. This addresses potential technical constraints NCAs could encounter in collecting the same file multiple times for different HUs.

Implication: This change enhances operational feasibility and reduces the risk of data fragmentation for TCBs that need to report on multiple HUs.

9. Amendments to templates H 01.00 and H 02.00:

Consultation paper: Template H 01.00 covered aggregated assets and liabilities of the ultimate HU in the Union, while H 02.00 required detailed information on all subsidiaries and TCBs of the third-country group in the Union.

Final Report:

• Template H 01.00 has been expanded to include details on the direct HU and other applicable HUs of the reporting TCB, addressing a data gap that would otherwise necessitate ad hoc data requests.
• Template H 02.00 has been simplified: columns 0010-0040 (identifying the direct HU of selected subsidiaries and other TCBs) have been removed.
• Instructions for H 02.00 have been amended to clarify that entities should use the same accounting standard applied for supervisory reporting in their respective state of establishment, avoiding additional conversion work.

Implication: These amendments reduce duplication and clarify the scope of reporting, while ensuring competent authorities have a complete view of the group structure.

10. Amendments to template E 09.02:

Final Report: The instructions for the Liquidity Coverage Ratio (LCR) summary template (E 09.01) have been enhanced to ensure consistency with CRR definitions. The EBA has confirmed that only a summary LCR template is required for Class 1 TCBs, rather than the full CRR LCR reporting package.

Implication: TCBs should review the amended instructions to ensure their LCR calculations are aligned with CRR definitions.

What stayed the same

The Final Report largely confirms the structure and content of the July 2025 consultation, including:

• The two-annex structure (Annex I for TCB information, Annex II for HU information).
• The "core + supplement" approach to proportionality between Class 1 and Class 2 TCBs.
• The requirement for Class 1 TCBs to report only a summary LCR template (E 09.01) rather than the full LCR framework.
• The alignment of certain TCB reporting templates with Credit Institutions templates for large exposures, LCR and ALMM.
• The reporting frequencies set out in the consultation (monthly, quarterly, semi-annual and annual depending on template and TCB classification).

Next steps

Following the submission of the final draft ITS to the European Commission for adoption, and publication of the final report and IT tools on the EBA website, the EBA will develop the data point model (DPM), XBRL taxonomy and validation rules based on the final draft ITS. The technical package is expected to be published in draft form in Q1 2026 and in final form in Q2 2026.

The ITS will enter into force on the day following its publication in the Official Journal of the European Union, and will apply from 28 March 2027. The first reference date for all reporting requirements is 31 March 2027.

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