On 22 November 2019, the European Banking Authority (EBA) issued a consultation paper on a draft implementing technical standard (ITS) on disclosure and reporting of the minimum requirement for own funds and eligible liabilities (MREL) and the total loss absorbency requirement (TLAC).

The draft ITS includes proposals for templates and tables implementing the TLAC/MREL Pillar 3 disclosure requirements and the supervisory reporting requirements. In addition to the draft ITS, the consultation paper includes two recommended reporting templates covering the forecast of MREL and TLAC positions and funding structures, and a mapping file between disclosure and reporting.

The approach that the EBA has followed seeks to maximise efficiency by institutions when complying with their disclosure and reporting obligations, and to facilitate the use of information by authorities and market participants. For this purpose:

  • MREL and TLAC are integrated inside both the reporting and disclosure templates;
  • reporting and disclosure requirements are enshrined in a single ITS; and
  • disclosure quantitative information is integrated with supervisory reporting data, and a mapping between both is provided.

The deadline for comments on the consultation paper is 22 February 2020.

The first reference date for reporting in accordance with the ITS when finalised is expected to be 30 June 2021, both for reporting on MREL and the TLAC requirement. The expected implementation period for the proposed reporting requirements is approximately one year.