EBA Proposes Staggered Pillar 3 Data Hub Publication Timeline for Small and Non-Complex Institutions

Key Takeaways

• The EBA's July 2026 public hearing presented a discussion paper on extending the Pillar 3 Data Hub (P3DH) to small and non-complex institutions (SNCIs).
• Under the proposal, the EBA would calculate and publish Pillar 3 disclosures on their behalf from supervisory reporting data, with a staggered publication schedule beginning in Q4 2026.
• Compliance teams at SNCIs should assess data readiness and reporting gaps now, as new supervisory reporting datapoints and templates are likely to follow.

Deep Dive

The EBA's July 2026 public hearing presented a discussion paper on extending the Pillar 3 Data Hub (P3DH) to small and non-complex institutions (SNCIs). Under the proposal, the EBA would calculate and publish Pillar 3 disclosures on their behalf from supervisory reporting data, with a staggered publication schedule beginning in Q4 2026. Compliance teams at SNCIs should assess data readiness and reporting gaps now, as new supervisory reporting datapoints and templates are likely to follow.

Under CRR3, the EBA must publish Pillar 3 disclosures for SNCIs using data those institutions already report to competent authorities. This removes the need for SNCIs to maintain their own disclosure channels and is intended to reduce operational costs. The P3DH for large and other institutions went live on 26 January 2026. Data submitted through supervisory reporting is treated as validated by the institution. The EBA will publish its calculation formulas for feedback, run the calculations with an internally developed engine, and publish the results. Institutions can raise issues through an email helpdesk. Resubmitting supervisory data triggers automatic recalculation and republication, with the republication date shown in the XBRL.csv file.

The EBA's analysis found that EU KM1 (all SNCIs) and EU CVA4 (listed SNCIs) have all datapoints available. EU OV1 is missing a few datapoints, and two would be added to COREP. EU CR1, CQ1, CQ3, and CQ7 depend on FINREP data that is not available at the individual level, so the EBA proposes adding these Pillar 3 templates to the supervisory reporting ITS for solo institutions. The remuneration templates (REM1 to REM4) would be added to the ITS for listed SNCIs, because not all institutions fall within the scope of the EBA remuneration guidelines. For qualitative tables (OVC, OVA, LIQA, CRA, MRA, ORA, REMA), three options are under consideration: A) take no action and keep disclosing as under CRR2; B) submit a PDF report through supervisory reporting; C) model the tables in the Data Point Model to allow structured submission.

The consultation closes on 20 July 2026. Two publication options are presented. Option A: Q4 2026 first publication (reference December 2025) for all requirements for non-listed SNCIs, and EU KM1 for listed SNCIs. In 2027, the second publication (reference December 2026) would cover KM1 and CVA4 for all listed SNCIs by end-April 2027, plus CR1, CQ1, CQ3, and CQ7 for listed SNCIs at the consolidated level. Steady state (reference December 2027) would be end-April 2028 for all requirements except remuneration, with remuneration information at end-June 2028. Option B delays non-listed SNCIs' full publication to end-September 2027 and then end-September 2028. The EBA is also asking whether institutions prefer end-April, end-June, or another date. End-April aligns with Transparency Directive financial statement timelines. The date must also reflect audit completion and the typical pattern of resubmissions.

SNCIs and their supervisors should:
- Submit consultation responses, since the hearing does not replace written feedback.
- Map current disclosures to COREP/FINREP datapoints and identify gaps.
- Review the proposed formulas for accuracy once published.
- Strengthen data quality controls and reconcile reporting with audited financials, because supervisory data will be published publicly.
- Define a process for resubmissions, which now trigger public republication.
- Decide which qualitative disclosure option to support.
- Plan for the retirement of in-house Pillar 3 processes, with a parallel run during the transition.

The main risks are public disclosure of erroneous or unstable data, reputational exposure from republications, and added reporting burden where new ITS templates are required. Loss of control over disclosure timing and presentation also requires governance attention.

Source: European Banking Authority