In line with the EBA’s “Statement on supervisory reporting and Pillar 3 disclosures in light of COVID-19” issued on 31 March 2020, the remittance date for the information to be submitted to the CSSF (in its function as resolution authority) pursuant to the CIR is extended by one month (i.e. to 29 May 2020) with the exception of the following normally expected templates (“the normally expected templates”):
- Information on the institution’s liability structure (template Z 02.00);
- Information on the institution’s own funds requirements (template Z 03.00); and
- Information on the institution’s intragroup financial interconnections (template Z 04.00).
The normally expected templates have to be reported at the usual remittance date, i.e. at the latest by 30 April 2020.
For the institutions under the SRB’s direct remit (significant institutions (SIs) and certain cross-border groups), the Liability Data Report has replaced the normally expected templates. Therefore institutions under the SRB’s direct remit do not have to submit templates Z 02.00, Z 03.00 and Z 04.00 but the Liability Data Report which was due by 31 March 2020. In general, where the submission can be performed within the ordinary deadlines without compromising the quality of the information reported in XBRL, institutions are encouraged to submit all the required templates(1) in a timely manner.
For the remaining institutions which are under the CSSF’s direct remit, institutions should submit at the latest by 30 April 2020 the normally expected tables. In order to avoid two transmissions of XBRL files (a first transmission at the latest by 30 April 2020 for the normally expected templates, and a second transmission at the latest by 29 May 2020 encompassing the normally expected templates and all the other templates to be submitted by the institutions(1)), and where the submission can be performed by the usual remittance date (30 April 2020) without compromising the quality of the information reported, a timely submission is encouraged for all the templates required to the institutions.
(1) in accordance with the letters sent to the management of the institutions at end of the year 2019.