On 2 June 2020, the EBA BoS published Guidelines on reporting and disclosure of exposures subject to measures applied in response to the COVID-19 crisis. These Guidelines set out reporting and disclosure requirements for information and data on the application of payment moratoria within the scope of the “Guidelines on legislative and non-legislative moratoria on loan repayments applied in the light of the COVID-19 crisis (EBA GL 2020/02)” and on public guarantees for new loans and forbearance measures granted against the backdrop of the COVID-19 crisis. The additional reporting requirements will apply for an expected period of 18 months.

On 16.12.2022 the EBA published its EBA Closure Report of Covid-19 Measures which was welcomed by BaFin and Deutsche Bundesbank. In para 16 of the report the EBA states that it repeals the Guidelines EBA/GL/2020/07 from 01.01.2023. Therefore, the final submission under these additional reporting requirements will be made for the reference date 31.12.2022.

Scope of application

The reports under the EBA Guidelines are to be submitted by all CRR credit institutions, both at the level of the individual institutions and at group level, taking into account the waiver under Article 7 of the CRR. In addition, promotional banks must also submit such reports.

Scope of reporting

All institutions subject to the reporting requirement must submit the following reporting templates: F 90.01, F 90.02, F 91.01, F 91.02 and F 91.05 (Annex 1). This applies regardless of the consolidated level or size of an institution.

Frequency of reporting

All reporting forms included in the scope of reporting are to be submitted on a quarterly basis. The reports are to be submitted to the Deutsche Bundesbank in line with the reporting deadlines for CoRep/FINREP reporting under the ITS on Supervisory Reporting.

First submission date

The planned use of XBRL for collecting reporting data requires a certain amount of time to implement. In light of this, the report as per September 2020 will be the first report to be submitted (with the deadline for submission 11 November 2020).

It is not necessary to also submit the reports as per June 2020.

Disclosure

Under the EBA Guidelines, the disclosure requirements may be waived for institutions. BaFin and the Deutsche Bundesbank have chosen to exercise this option. German LSIs and promotional banks are therefore not subject to the disclosure requirements under the EBA Guidelines.