Response to the European Banking Authority’s Consultation on Implementing Technical Standards on supervisory reporting (simplification package)

This submission responds to the European Banking Authority’s (EBA) ‘Consultation on Implementing Technical Standards on supervisory reporting (simplification package)’. Building on several recent CETEx publications, the authors focus on environmental risk metrics, including climate- and nature-related risks; forward-looking transition planning and climate scenario risk assessment; and the integration of supervisory reporting into the Supervisory Review and Evaluation Process.

Core recommendations

The EU’s reform of supervisory reporting standards should involve further alignment of reporting frameworks. The EBA should:

• Ensure that there is consistency across definitions in reporting templates without introducing additional complexity or uncertainty for banks.
• Develop a comprehensive data dictionary on environmental, social and governance risks that supports a consistent interpretation of reporting requirements.
• Encourage banks that do not have access to sufficiently granular or reliable data to clearly disclose the proxies they use, explain their underlying methodologies and justify their assumptions.
• Continue to work with competent authorities in the EU and its Member States to improve data sharing and data flows across the EU.

DOI: doi.org/10.21953/researchonline.lse.ac.uk.001402