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The Eurosystem Integrated Reporting Framework an overview 1 The Eurosystem Integrated Reporting Framework an overview 1 Background European Union EU banks face a whole range of data reporting obligations, including for statistical, resolution and prudential information. At the EU level, these are specified in various legal frameworks, including ECB statistical regulations on balance sheet items BSI1 and interest rates of monetary financial institutions MIR,2 the sectoral module of Securities Holdings Statistics SHS-S,3 granular credit and credit risk data AnaCredit4 and the implementing technical standards of the European Banking Authority EBA on supervisory data and the reporting of resolution information to the Single Resolution Board SRB. Existing ECB statistical regulations specify the information that must be reported, but not how the actual reporting process is to be carried out. They do not stipulate how the data should be organised the data model, the definitions to be used for collecting the data the data dictionary or the deadlines for reporting agents. In addition, national central banks NCBs are generally allowed to collect the statistical information needed to fulfil the ECB’s statistical requirements under their own statistical andor supervisory and resolution reporting frameworks.5 The national systems also cover NCBs’ obligations to report to the ECB where the relevant statistics are not covered by an ECB regulation e.g. under ECB statistical guidelines on monetary and financial statistics,6 external statistics7 or financial accounts8. NCBs meet reporting requirements of other international organisations too, such as the Bank for International Settlements BIS and the International Monetary Fund IMF, as well as data needs arising at the national level. So far, only a few euro area countries have implemented widely integrated national collection frameworks. In most cases, the national frameworks consist of many separate reports to be 1 Regulation EU No 2021379 of the ECB of 22 January 2021 on the balance sheet items of credit institutions and of the monetary financial institutions sector recast ECB202112, OJ L 73, 3.3.2021, p. 16. 2 Regulation EU No 10722013 of the ECB of 24 September 2013 concerning statistics on interest rates applied by monetary financial institutions recast ECB201334, OJ L 297, 7.11.2013, p. 51. 3 Regulation EU No 10112012 of the ECB of 17 October 2012 concerning statistics on holdings of securities ECB201224, OJ L 305, 1.11.2012, p. 6. The group module of SHS is not included in the current IReF scope, although it is likely to be considered for inclusion in a second step. 4 Regulation EU No 8672016 of the ECB of 18 May 2016 on the collection of granular credit and credit risk data ECB201613, OJ L 144, 1.6.2016, p. 44. 5 See, for instance, Recital 9 of Regulation EU 2021379 of the European Central Bank of 22 January 2021 on the balance sheet items of credit institutions and of the monetary financial institutions sector recast ECB20212 OJ L 73, 3.3.2021, p. 16. 6 Guideline EU 2021830 of the European Central Bank of 26 March 2021 on balance sheet item statistics and interest rate statistics of monetary financial institutions ECB202111. 7 Guideline EU 2012120 of the European Central Bank of 9 December 2011 on the statistical reporting requirements of the European Central Bank in the field of external statistics recast ECB201123. 8 Guideline EU 20143 of the European Central Bank of 25 July 2013 on the statistical reporting requirements of the European Central Bank in the field of quarterly financial accounts recast ECB201324. 2 submitted by reporting agents to NCBs. Figure 1 below depicts the current approach to statistical data collection from banks. This arrangement dates back to when the ECB was set up in 1998 and was justified at the time, as it meant that statistical reporting could be founded on well-established national reporting frameworks. However, the single monetary policy allows for more efficient reporting. For instance, banks could save costs if they did not have to maintain heterogeneous national systems that feature different national data models and heterogeneous dictionaries which are particularly challenging for cross-border banks different transmission frequencies, timelines and levels of aggregation possible duplications and overlaps in reporting, with complex schedules and processes differences in data quality rules such as validation checks, revision policies, approaches to derogations and data exchange formats. Figure 1 Current Eurosystem approach to collecting statistical information from banks The main objective of the Integrated Reporting Framework IReF is to reduce the reporting burden on euro area banks in line with Article 3382 of the Treaty9 and 9 Treaty on the Functioning of the European Union OJ C 326, 26.10.2012, p. 47. Transformations by banks Transformations by NCBs BIS IMF datasets b.o.p., i.i.p sector accounts AnaCredit SHS BSI MIR Country A Integrated approach Operational systems ECB Banks NCBs Country B Monetary data Credit register b.o.p. i.i.p. Supervisory data Security-by-security reporting Sector accounts 3 Article 3a of Council Regulation EC No 253398,10 while meeting the information needs of the European System of Central Banks ESCB. This will be achieved by integrating different statistical obligations and harmonising data collection across countries, such that statistical reporting will be significantly less dependent on the country in which a bank is resident. The ECB envisages issuing an IReF Regulation on statistical data requirements which would be directly applicable to banks resident in the euro area. Non-euro area EU Member States may decide to adopt the IReF reporting through national legislation in full or in part e.g. for content related to AnaCredit. The IReF could strengthen the banking and monetary union cross- country standardisation of reporting may remove some of the obstacles that can prevent smaller banks from engaging in cross-border operations, which in turn would foster competition in the EU financial sector. The gains in cost efficiency would be achieved by economies of scale and systematic application of the define once, report once, regulate once, perform as one system principle. For instance, the costs of developing the common data dictionary would be a one-off investment for all ESCB countries. Under the new paradigm, cross-border banks could unify the technical specifications of their reporting for all their European entities. Leaner data flow management processes than those shown in Figure 1 could also be designed. Moreover, once the initial investment phase is over, the granular reporting of data will increase the agility and speed with which policymakers can react to new developments, since they will be able to have access to data fit for new purposes and which can be more easily re-arranged from the granular data already held. This overview provides key facts and procedural information on the IReF and how it fits in with the broader EU data integration initiative, which also encompasses resolution data and prudential data. 2 The scope of the IReF The IReF seeks to integrate existing ESCB statistical data requirements for banks as far as possible into a single, standardised reporting framework applicable across the euro area. In the initial phase, the IReF is focusing primarily on ECB statistical datasets relating to banks and will hence cover the requirements of the ECB regulations on BSI and MIR statistics, SHS-S and AnaCredit. In respect of SHS-S, the IReF will also cover requirements for banks in their role as custodians. Other ECB statistics that do not directly relate to bank balance sheet assets and liabilities, such as ECB payments or money market statistics, are not currently covered. The intention is also to integrate reporting obligations on banks’ own positions and transactions arising in the context of statistics on balance of payments b.o.p., international investment positions i.i.p., financial accounts and securities issued. Consideration is being given to integrating other requirements arising from the collection frameworks of international organisations, such as BIS locational banking 10 Council Regulation EC No 253398 of 23 November 1998 concerning the collection of statistical information by the European Central Bank OJ L 318, 27.11.1998, p. 8. 4 statistics and IMF standardised report forms. The feasibility of aligning the IReF more closely with the Financial Reporting FINREP requirements applicable at solo level11 is also being assessed. The granularity of the IReF scheme is expected to cover a large share of the statistics currently collected by NCBs that are outside the scope of ECB regulations. NCBs are also assessing the relevance of existing country-specific requirements CSRs. However, the business need for CSRs will continue to be relevant, for instance in connection with national legal obligations, such as activities related to anti-money laundering, government support or national credit registers. The Eurosystem has engaged in a detailed assessment of CSRs that would not be absorbed under the baseline scenario for the IReF and could not be discontinued by NCBs, with the aim of identifying which of these are common to several NCBs and might therefore be suitable for inclusion in the IReF Regulation. CSRs for which there is a business need but are not captured by the IReF Regulation will continue to be collected at a national level. At the same time, an extended technical layer will be developed, possibly consisting of a data model or a common dictionary, to describe requirements arising from the IReF Regulation and the CSRs that will continue to apply once the IReF enters into force. In this way, overlapping requirements across two or more countries will be described in a uniform way consistent with the IReF requirements. 3 The IReF target population The IReF is primarily intended to cover credit institutions and deposit-taking corporations other than credit institutions. Given the different reporting populations of the datasets within its scope, the IReF specifies separate requirements for these two categories. For example, instrument-level requirements on loans to legal entities will apply to credit institutions, whereas deposit-taking corporations other than credit institutions will continue to report loan data on an aggregated basis. Requirements addressed to money market funds MMFs are not part of the IReF and will continue to be set out in separate ECB legal acts, leaving discretion at the national level on how best to collect this information in practice. Some NCBs have developed an integrated reporting framework for investment funds covering both MMFs and non-MMFs. This approach may be adopted at Eurosystem level in the medium term. 4 Advantages of the IReF The advantages of the IReF for the various stakeholders mentioned in Section 1 are explained in more detail below. 11 Supervisory financial information collected at the level of the legal entity as laid down by Regulation EU 2015534 of the European Central Bank of 17 March 2015 on reporting of supervisory financial information ECB201513. 5 Reporting agents are expected to benefit substantially from the IReF. Reporting requirements will be presented on the basis of a logical data model and data collection will rely on a standardised implementation model. A common data dictionary will apply, thus ensuring a standard set of definitions. Reporting frequency and timelines, and granularity of requirements, will also be standardised. The framework will specify a common set of data quality rules most notably validation and a revision policy directly applicable to all agents. Cross-country standardisation may be of particular benefit to banking groups that operate across borders within the euro area. However, all banks, even smaller institutions, stand to gain from the integration of different statistical reporting requirements, especially as these become more stable over time. The reporting burden on small institutions could also be mitigated by suitable Eurosystem-wide derogations see next section. Ad hoc requests to fill information gaps are likely to become less frequent, and the higher level of standardisation will be conducive to standard IT solutions. Initial gains will differ from country to country, depending on the reporting model and the degree of integration of current national frameworks. The need for banks to procure external data services is also expected to decrease as requirements are harmonised. While there are one-off investments to be made at the implementation stage, regular costs may be reduced, not least because standardisation of requirements and additional granularity e.g. on loans to legal entities and level of detail e.g. on deposits under the IReF scheme may meet new user needs without changing data collection methods, thus minimising maintenance costs. Over the mediumlong run, banks will reap additional benefits from the integration of statistical, prudential and resolution requirements. These aspects are being assessed in more depth through the cost- benefit analysis being conducted in a transparent and cooperative way with all the IReF stakeholders, including banks see also Section 6 below. Statisticians at central banks will also benefit, as they will receive only one set of statistical information to produce the datasets covered by the IReF. Using a standardised data model to represent requirements will ensure methodological soundness and compliance with statistical standards. Data quality assessment procedures and revision policies can also be standardised. Integrated data collection may also create new opportunities to further automate statistics production and dissemination systems. Users of statistical information, including banks themselves potentially, also stand to benefit from the IReF, as it aims to ensure a precise and unambiguous definition of the statistical information relevant for their needs throughout the Eurosystem. This will improve the accuracy and comparability of data across datasets and across countries. The quality and analytical value of the data received will increase, as users will have a fully consistent and standardised dataset, rather than data provided under different frameworks that then need to be reconciled e.g. between BSI and SHS-S. In addition, users will be able to drill down from aggregated data to the underlying granular information subject to the relevant data access. As the IReF is expected to use granular data on loans and securities to compile statistics, further breakdowns will become available for policymakers, banks, academia and the public 6 at large while always respecting confidentiality requirements. These breakdowns will allow policymakers to analyse changes in economic and financial trends more quickly, thanks to the wealth of statistical information available to them. 5 Ensuring proportionality under the IReF Each ECB statistical collection framework includes derogations and sampling schemes aimed at ensuring representativeness and proportionality. The approaches are not usually harmonised across datasets. They range from cases where reporting agents may be partially exempted from the obligation to report data as they are small with respect to certain criteria e.g. BSI, SHS-S, AnaCredit, to cases where derogations relate to a subset of the requirements specified in a dataset e.g. BSI. In other cases, the collection framework may be based on a sampling approach e.g. MIR. At present, countries have discretion as to how they apply these general derogation schemes at the national level, resulting in a wide range of schemes, including cases where no derogations at all are applied. The Eurosystem recognises the need to ensure proportionality under the IReF and favours simple solutions across the euro area, such as derogations for small institutions, which would be subject to simplified reporting. Various options for structuring this simplified reporting are now being assessed in the course of the ongoing cost-benefit analysis. 6 Ongoing work and next steps The IReF is an ambitious endeavour that seeks to redefine the collection of statistical data from banks in terms of both content and processes. These and other aspects are being assessed in close cooperation with banks and other stakeholders by means of an ongoing cost-benefit analysis. When defining the methodology to be followed in the cost-benefit analysis, the Eurosystem has decided to adapt the merits and costs procedure to accurately reflect the cost reduction benefits for reporting agents and authorities. This procedure is typically used to evaluate the significance of the costs of new statistical requirements, whereas the IReF primarily aims to reduce costs by streamlining and standardising existing statistical data reporting in line with basic data management principles promoted by banks. The procedure is fully aligned with the principles of increased transparency in ECB regulations on European statistics adopted by the Governing Council in October 2016. The first step was taken in 2018 and consisted of a qualitative stock-taking questionnaire on the state of play across datasets and countries to help design scenarios for the collection aspects of a possible integrated framework reporting dates, data frequency, derogations, etc.. In 2019 the Eurosystem focused on assessing the results of this questionnaire and worked to define a more limited set of scenarios to be considered in future.12 The second step was a questionnaire 12 See Qualitative stock-taking questionnaire on the integrated reporting framework Analysis of high- level considerations and high-priority technical aspects, ECB, February 2019. 7 exploring the costs and benefits of the scenarios identified for various aspects of the collection framework. This cost-benefit assessment CBA covered specific data requirements and modelling options, reporting timelines, revision policy, approach to derogations, aspects related to technical and operational implementation, and integration of country-specific requirements, among other matters. The Eurosystem reviewed the results of the CBA to identify optimal features for banks, the Eurosystem and its users. The assessment focused on feedback received from stakeholders on the drivers of costs and benefits, the overall question of whether the benefits of implementing the IReF would outweigh the costs, and certain high-priority technical aspects in order to facilitate a discussion on the utility of establishing the IReF. A first report on the feedback received on these aspects was published in December 2021. This showed strong support for the IReF within the banking industry and among other relevant stakeholders, all of whom believed that the benefits of implementing the framework outweighed the costs. In the banking industry, support was highest among members of cross- border groups. For standalone institutions too, the proportion of respondents indicating that the benefits would outweigh the costs was much higher than those indicating the opposite. When the results are broken down by size of respondent, the level of support is, as expected, lower among small institutions than large and medium-sized ones nevertheless, over 60 of small institutions still indicated that the benefits would outweigh the costs. Since then, and in close cooperation with the banking industry, the Eurosystem has continued to analyse the answers received on the other aspects. The results were published in September 2022 a report on content-related topics and technical aspects covering a range of issues from loan write-offs to the preferred structure for representing and collecting the IReF requirements a report on the technical integration of CSRs and a report on reporting schedules, revision policy, the approach to derogations and implementation aspects. As a follow-up, the Eurosystem initiated a third step in 2023 a complementary cost- benefit assessment CBA with stakeholders to address additional topics of relevance, such as the merits of integrating common CSRs into the IReF Regulation, increasing the IReF analytical value e.g. on data relevant for the development of climate indicators, improving operational aspects and ensuring closer alignment of the IReF with FINREP solo. A first report on the complementary CBA results was published in February 2024. It assesses the extent to which CSRs could be usefully included in the IReF Regulation. Two additional reports published in April 2024 one focusing on improving the IReF analytical value and operational aspects and the other on closer alignment between the IReF and FINREP solo present the results of the analysis of the remaining complementary CBA topics. As a final step, the Eurosystem will perform a comprehensive comparison of costs and benefits based on the feedback received from stakeholders this comparison will then form the basis for drafting a Regulation on the IReF. In line with the ECB merits and costs procedure, the results of the comparison will be published to inform the 8 public consultation on the draft IReF Regulation, currently scheduled for 2024. The legal act will then be adopted by the Governing Council. The IReF Regulation will replace the existing regulations on BSI, MIR, SHS and AnaCredit with respect to the requirements for deposit-taking corporations. The MIR and AnaCredit regulations would be repealed, and the BSI and SHS regulations recast or amended to exclude deposit- taking corporations from the reporting populations.13 7 Implementation of the IReF Subject to adoption of the IReF Regulation by the Governing Council, currently scheduled for 2025, the IReF is expected to go live in 2027. In parallel, the Eurosystem is designing the organisation of Eurosystem statistical business processes as a preliminary step to investigating and implementing the IT solutions that will support data collection under the IReF. This time frame will give reporting agents and the Eurosystem enough lead time to prepare the legal and technical framework without unduly delaying the expected reduction in the reporting burden. The Eurosystem has recently engaged in a comprehensive investigation phase for the IReF and its technical implications and will regularly update the IReF implementation plan as part of this process and to reflect how broader collaborative efforts with other European authorities to integrate statistical, resolution and prudential requirements are developing see also Section 8. As part of this process, the IReF timeline may be amended to reflect the outcome of the investigation phase. 8 The IReF as part of the broader data integration initiative The IReF is part of a broader data initiative for an integrated reporting system for statistical, prudential and resolution data in the EU, as requested by the European banking industry14 and as envisaged by the European Parliament and the Council in Article 430c of Regulation EU 2019876.15 In line with the mandate received, the EBA carried out a feasibility study on an integrated reporting system and published the final report in December 2021.16 13 For instance, the BSI Regulation will continue to apply to MMFs. 14 See Boosting Europe Building Trust and Supporting Growth in Europe. EBF recommendations for the EU 2019-2024 legislative cycle and beyond, European Banking Federation, May 2019. 15 Regulation EU 2019876 of the European Parliament and of the Council of 20 May 2019 amending Regulation EU No 5752013 as regards the leverage ratio, the net stable funding ratio, requirements for own funds and eligible liabilities, counterparty credit risk, market risk, exposures to central counterparties, exposures to collective investment undertakings, large exposures, reporting and disclosure requirements, and Regulation EU No 6482012 OJ L 150, 7.6.2019, p. 1. 16 See On a Feasibility Study of an Integrated Reporting System under Article 430c CRR, EBA, 2021 and The EBA’s feasibility study on integrated reporting system provides a long-term vision for increasing efficiencies and reducing reporting costs, EBA, December 2021. 9 The ESCB published its views on this broader initiative in a report which served as input for the EBA’s feasibility study.17 The ESCB sees the IReF as a first step towards a fully integrated reporting system for banks in the EU, which should be based on a common data dictionary that has a common underlying meta model.18 The Joint Bank Reporting Committee JBRC an advisory body comprising representatives from relevant European and national authorities and involving the banking industry in certain tasks will be set up to advise on integrating statistical, resolution and prudential data reporting among banks. It could also advise on how best to lay the foundations for sharing data and ensuring interoperability among the relevant national and European authorities. The Committee should be up and running in the course of 2024. The Eurosystem is already cooperating closely with the banking industry to optimise reporting and reduce the overall reporting burden via the Banks’ Integrated Reporting Dictionary BIRD.19 BIRD offers a redundancy-free source i.e. a logical data modelinput layer from which transformations describe how to create data to meet the actual reporting requirements of authorities. This feature makes it less burdensome for banks to determine which source data to use and how to process the data correctly, thus providing full data lineage. BIRD also features mappings to translate the different metadata and codifications used in various dictionaries into a single metadata language. If the authorities agree on a common data dictionary featuring semantic integration, this part of BIRD will no longer be necessary. BIRD could either be adapted to the new common data dictionary or provided additionally, as is currently the case. For maximum benefit it would, of course, be preferable if the common data dictionary were developed and maintained in collaboration with BIRD. The possibility of a common input approach will be investigated, as also indicated by the EBA in its feasibility study. Both the IReF and BIRD will provide crucial support for banks in their reporting tasks by logically and methodologically bridging the gap between authorities’ reporting requirements and banks’ operational systems. BIRD is expected to benefit significantly from the IReF as statistical reporting becomes standardised across countries. This will allow for the direct application of BIRD in the euro area for statistical requirements. As more reporting frameworks are incorporated into the IReF, BIRD will provide more effective support to banks and the overall integration of statistical, prudential and resolution requirements. In 2021 BIRD was reshaped to enable both the metadata and the data model i.e. the designstructure to be aligned with the IReF so as to generate further benefits and synergies. This will, for example, enable the IReF to adapt more easily to 17 See The ESCB input into the EBA feasibility report under article 430c of the Capital Requirements Regulation CRR 2, ECB, September 2020. 18 A common meta model information model refers to the standard and formalised layer that depicts the semantic information. This is described in On a Feasibility Study of an Integrated Reporting System under Article 430c CRR, EBA, March 2021, in the process chain and the three levels of abstraction in the syntactic layer of the data definition part. 19 Thus far BIRD has covered the reporting requirements for AnaCredit, SHS-G, FINREP, asset encumbrance and resolution planning as separate outputs. Other datasets, including those within the scope of the IReF, are currently being considered. 10 possible extensions e.g. SHS-G that are already included and modelled in BIRD, making it much more scalable. Banks will remain fully responsible for organising their internal reporting systems and ensuring the accuracy of their reports to the authorities, including application of the transformation rules. BIRD provides more detailed, though not legally binding, interpretations. Most crucially, it does not change the reporting requirements. The approach to data collection from banks aims to be cost-effective and transparent. The IReF describes statistical requirements in a redundancy-free layer and will represent future statistical reporting obligations issued by the ECB and applicable to Eurosystem banks. BIRD describes how information held at bank level should be transformed to comply with these obligations not only ECB statistical regulations but also EU prudential and resolution requirements. The difference between BIRD and the IReF is that the latter will be mandatory, while the former will remain voluntary and will only exist at the level of reporting agents. From a logical perspective, BIRD and the IReF are very similar, as both integrate requirements in a redundancy-free way from which multiple outputsproducts can be created. However, they vary in scope, as the IReF integrates only statistical requirements. Transformation rules to generate the IReF and other i.e. prudential and resolution reporting requirements from the BIRD input layer will be applied by banks, not authorities. However, under the IReF, the ESCB will apply transformations internally to a large degree to generate statistical products that have so far been directly reported by banks. The BIRD input layer may also be used by banks for their own internal purposes. BIRD could be effective in making reporting processes among banks more closely aligned with their operations and ultimately allow them to base their work and that of the Eurosystem on the same or very similar sets of data. Data quality should increase and costs decrease, as the BIRD input layer would provide a comprehensive and flexible tool to support data reporting. European Central Bank, 2024 Postal address 60640 Frankfurt am Main, Germany Telephone 49 69 1344 0 Website www.ecb.europa.eu All rights reserved. Reproduction for educational and non-commercial purposes is permitted provided that the source is acknowledged. For specific terminology please refer to the ECB glossary available in English only.

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AnaCredit stands for analytical credit datasets . The project was initiated in 2011 and data collection started in September 2018. ECB Regulation on AnaCredit The Regulation on the collection of granular credit and credit risk data sets out the reporting requirements and defines the reporting population. Regulation EU 2016867 on the collection of granular credit and credit risk data ECB201613 Explanatory note on the ECB Regulation ECB201738 ECB Guideline on the procedures for the collection of AnaCredit data from NCBs , as amended by Guideline EU 2020381 of the European Central Bank of 21 February 2020 and Guideline EU 20211829 of the European Central Bank of 7 October 2021 . A consolidated version is also available on EUR-Lex.europa.eu ECB20146 ECB Decision on the organisation of preparatory measures for AnaCredit ECB201614 ECB Decision amending ECB20146 on the organisation of preparatory measures for AnaCredit ECB20147 ECB Recommendation on the organisation of preparatory measures for AnaCredit ECB201920 ECB Decision on the procedure for non-euro area MSs to report under the AnaCredit regulation On 4 December 2015 the ECB published the AnaCredit draft regulation, giving to the public the opportunity to make observations until 29 January 2016. Mainly associations and federations replied. The ECB, together with national central banks, assessed the observations received. As a result, an amended version of the draft regulation was approved by the Governing Council in May 2016. A Feedback Statement explains how the observations received were assessed and taken into account in the Regulation. Feedback statement - Responses to the observations on the draft European Central Bank Regulation on the collection of granular credit and credit risk data, May 2016 Rationale The financial crisis showed that aggregate statistics are not sufficient for an adequate understanding of the underlying developments, given that a number of economic and financial indicators have diverged significantly across different segments of the economy, such as sectors of activity, firm size or geographical areas. The AnaCredit dataset makes it possible to fill this data gap supporting the ECB in performing its central banking and banking supervision functions, such as monetary policy analysis and operations risk management financial stability economic research statistics AnaCredit makes it possible to identify, aggregate and compare credit exposures and to detect associated risks on a loan-by-loan basis. Scope At present, banks only report information on loans to corporations and other legal entities, mostly on a monthly basis. Should the ECB’s Governing Council decide to extend the AnaCredit project at a later stage, e.g. including housing loans to private households, these would be reported anonymously to the ECB. Users The dataset is designed for The ECB and all national central banks of the participating countries National and European supervisory authorities National and European resolution authorities European Systemic Risk Board European Commission To some extent, reporting agents Some users will only have access to part of the dataset at an aggregated level to ensure confidentiality. Confidentiality Data are treated according to strict confidentiality rules as set out under existing European law, and are only accessible to the aforementioned users and for the foreseen uses. Exchange of information among central credit registers before AnaCredit In 2010 a Memorandum of Understanding was established between several EU national central banks, replacing the Memorandum signed in 2003. It provides a framework for the voluntary bilateral exchange of information between national central credit registers, to facilitate cross-border sharing among reporting institutions of the information stored in these credit registers. Given the establishment of AnaCredit, the exchange of information under this Memorandum of Understanding has been discontinued since September 2018. Memorandum of Understanding AnaCredit Manual The Manual provides detailed information and guidance on AnaCredit reporting requirements. Its overall objective is to ensure consistent and effective application across the euro area of the AnaCredit statistical framework, as set out in Regulation EU 2016867 of May 2016 ECB201613. The Manual does not contain any additional requirements and has no binding legal status. The AnaCredit Regulation is the sole legally binding act. The Manual is made up of three parts Part I explains the general AnaCredit methodology and provides information about the reporting population and setting up the reporting, including a general description of the underlying data model. Part II describes all datasets and data attributes of AnaCredit data collection in detail and provides specific reporting instructions. Part III presents selected case studies and scenarios that require more in-depth explanations. Finally, the annexes provide additional information relevant for reporting agents, such as lists of country specific national identifiers and legal forms as well as examples of complete data reports concerning stylised instruments. 31 May 2019 second edition of the AnaCredit Manual published The Manual was updated in May 2019 to incorporate the additional explanations provided in the QAs published on the ECB’s website between July 2017 and December 2018. AnaCredit reporting manual Part I General Methodology, second edition AnaCredit reporting manual Part II Datasets and data attributes, second edition AnaCredit reporting manual Part III Case studies, second edition Annexes List of legal forms List of national identifiers List of international organisations List of postal code formatting rules and regular expressions per country Examples of complete reports Guidance on non-EU entities identifiers search This document provides detailed guidance on where to retrieve a valid national identifier and which identifier type to use to report the identifier. The list is sorted by country of residence of the counterparty for which a national identifier needs to be found and which is resident outside of the EU. Guidance on non-EU entities identifiers search QAs The Manual is complemented by further explanations provided via the ongoing QA process. Reporting agents and other stakeholders can submit a question to the relevant national central bank NCB at any time. The NCB or, in the case of broader questions, the European System of Central Banks, subsequently prepares a response and the NCB concerned communicates this back to the requester adjusting the response in line with the national reporting framework if applicable. A selection of these QAs is published here on an ongoing basis. AnaCredit reporting manual questions answers How to read the QAs in combination with the AnaCredit Regulation and the Manual The QAs form part of the AnaCredit Manual. They extend and complement the clarifications already provided in the Manual. Similarly to the rest of the Manual, the QAs have no binding legal status, nor do they contain any additional requirements. The QAs published on the ECB’s website between July 2017 and December 2018 were incorporated in the second edition of the AnaCredit Reporting Manual. Note on national implementations The Manual inclusive of the QAs does not provide any information about the national implementation of AnaCredit requirements by NCBs. Reporting agents and other stakeholders are invited to contact the relevant NCB for such information. Validation checks The ECB performs validation checks to ensure that data reported to AnaCredit are complete and consistent, in accordance with the requirements. The below document explains the main set of validation checks that are performed. AnaCredit validation checks, version 1.8 Plausibility checks The ECB also performs plausibility checks, which aim to identify AnaCredit data that are likely to be incorrect and must therefore be verified. Together with the validation checks they provide the quality assurance of granular reporting on credit for AnaCredit. The following document explains the main set of plausibility checks that are performed. AnaCredit plausibility checks, version 2.0 SEE ALSO Find out more about related content Explainers What is AnaCredit Publications The Analytical Credit Dataset - A magnifying glass for analysing credit in the euro area All pages in this section Are you happy with this page Yes No What made you unhappy Page not working Information not useful Design not attractive Something else Thank you for letting us know Site directory FOLLOW US Copyright 2024, European Central Bank Useful links Work with us Glossary Other institutions Using our site Disclaimer Copyright Privacy statement Language policy Technical updates to this site Corporate Policies Data Protection Access to documents Responsible disclosure Contact Contacts Address Public holidays data-count position relative data-countafter position absolute right -20px bottom 0px display block content attrdata-count color rgba255, 255, 255, 0.8 text-shadow 0 0 8px black font-size 11px body.hideCount data-countafter display none function let addedCount false let addCount function let list document.querySelectorAllh2,h3,h4,p,a forvar i 0 i list.length i let item listi item.setAttributedata-count,item.textContent.length document.onkeypress functione ife.ctrlKey e.code KeyM ifaddedCount document.body.classList.add'hideCount' addedCount false else document.body.classList.remove'hideCount' addCount addedCount true Our website uses cookies We are always working to improve this website for our users. 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Seite 1 von 3 Deutsche Bundesbank, Zentrale, DS 32 Wilhelm-Epstein-Straße 14, 60431 Frankfurt am Main, Telefon 49 69 9566-36964 infobundesbank.de, www.bundesbank.de An alle Banken MFIs und an die Rechenzentralen der Sparkassen und Kreditgenossenschaften sowie an die Bankenverbände und Meldewesen- Software-Hersteller 28. März 2024 Rundschreiben Nummer 242024 Primärstatistisches Meldewesen Kreditdatenstatistik AnaCredit hier Konkretisierung der Meldevorgaben für das Kreditdatenfeld kumulierter Wertminderungs- betrag und die Zusammenfassung von Sicherheiten mit ähnlichen Merkmalen Hinweis zum Start des neuen Non-Compliance Verfahrens der EZB Sehr geehrte Damen und Herren, mit diesem Rundschreiben informieren wir Sie über 1. eine Konkretisierung der Meldevorgaben für das Datenfeld kumulierter Wertminderungs- betrag 2. die Zusammenfassung von Sicherheiten mit ähnlichen Merkmalen in einem Sicherhei- tenkorb 3. den Start des neuen Non-Compliance Verfahrens der EZB 1. Konkretisierung der Vorgaben für das Kreditdatenfeld kumulierter Wertminderungsbe- trag keine Meldung von Vorsorgebeträgen für allgemeine Bankrisiken gemäß 340f HGB Auf Grundlage der AnaCredit-Verordnung EU 2016867 ist im Datenfeld kumulierter Wertmin- derungsbetrag für Instrumente, die einer Wertberichtigung unterliegen können, der Betrag von Verlustberichtigungen zuzuordnen, die dem Instrument zum Meldestichtag zugeordnet werden. Gemäß nationaler Rechnungsvorschriften handelt es sich hierbei um Verlustberichtigungen in Höhe der Pauschal- oder Einzelwertberichtigungen. Analysen der AnaCredit-Meldungen haben Seite 2 von 3 Deutsche Bundesbank, Zentrale, DS 32 Wilhelm-Epstein- Straße 14, 60431 Frankfurt am Main, Telefon 49 69 9566-36964 infobundesbank.de, www.bundesbank.de allerdings ergeben, dass im Datenfeld kumulierter Wertminderungsbetrag uneinheitliche Anga- ben enthalten sind. Neben Pauschal- und Einzelwertberichtigungen werden von einigen Institu- ten zusätzlich Beträge aus der Vorsorge für allgemeine Bankrisiken gemäß 340f HGB berück- sichtigt. Daher wird für das Datenfeld kumulierter Wertminderungsbetrag eine Konkretisierung erforderlich. Diese Notwendigkeit ergibt sich aus der AnaCredit-Verordnung, in der unter den Gründen für die AnaCredit- Datenerhebung in den Punkten 1 und 9 das Risikomanagement im Euro- system und ein analytischer Überblick über die Kreditrisiken der Berichtspflichtigen benannt sind. Um diesen Zielen gerecht zu werden und aus den gemeldeten granularen Daten eine klare Risikoeinschätzung vornehmen zu können, ist eine einheitliche Meldepraxis aller Berichts- pflichtigen in den hierfür relevanten Datenfeldern erforderlich. Als weiterer Aspekt ist zu beachten, dass die Berücksichtigung der Vorsorge für allgemeine Bankrisiken als kumulierter Wertminderungsbetrag aufgrund der Ausweisvorschriften für die Bilanzstatistik BISTA zu höheren Abweichungen im BSI-Abgleich führt. Um den Abgleich der AnaCredit-Daten mit der BSI-Statistik zu verbessern, und in Anbetracht der generellen Schwan- kungsanfälligkeit der Vorsorgereserven, wird daher die Nicht-Meldung von Vorsorgebeträgen für allgemeine Bankrisiken nach 340f HGB als kumulierter Wertminderungsbetrag ab dem Meldetermin Dezember 2024 verbindlich. Das bedeutet, dass diese Beträge spätestens ab dem Meldestichtag 31.12.2024 nicht mehr im Datenfeld kumulierter Wertminderungs- betrag gemeldet werden dürfen. Die neuen Vorgaben werden Anfang 2025 ebenfalls in die Richtlinien zur Kreditdatenstatistik AnaCredit aufgenommen. Der zeitliche Verzug zwischen Bekanntgabe der neuen Vorgabe und deren verbindlicher Umsetzung soll den betroffenen Insti- tuten die Zeit geben, erforderliche Anpassungen rechtzeitig in ihre Meldungslogik zu implemen- tieren. 2. Zusammenfassung von Sicherheiten mit ähnlichen Merkmalen in einem Sicherheiten- korb In AnaCredit besteht die Möglichkeit, Sicherheiten mit ähnlichen Merkmalen in einem Sicher- heitenkorb zusammenzufassen und als eine Sicherheit zu melden. Dies wird beispielsweise bei der Meldung von Wertpapierportfolios genutzt, welche eine Vielzahl einzelner Wertpapiere ent- halten können. Auch für den Fall einer weiten Zweckerklärung, in der sämtliche Sicherheiten eines Sicherungsgebers als Sicherheit für alle Instrumente innerhalb eines Vertrages oder so- gar aller Verträge eines Schuldners herangezogen werden, kann eine Zusammenfassung von Sicherheiten mit ähnlichen Merkmalen erfolgen. Die Möglichkeit der Zusammenfassung von Sicherheiten mit ähnlichen Merkmalen in einem Sicherheitenkorb ist immer dann zu nutzen, wenn die Voraussetzungen für eine Bündelung vor- liegen ähnliche Merkmale und die Einzelmeldung der Sicherheiten und deren Verbindung zu Instrumenten den Umfang einer Teilmeldung für einen Meldestichtag deutlich übersteigen Seite 3 von 3 Deutsche Bundesbank, Zentrale, DS 32 Wilhelm-Epstein-Straße 14, 60431 Frankfurt am Main, Telefon 49 69 9566-36964 infobundesbank.de, www.bundesbank.de würde. Hintergrund ist, dass die Einzelmeldung von Sicherheiten mit ähnlichen Merkmalen gegenüber einer gebündelten Meldung zum Zweck der Risikoeinschätzung aus den AnaCredit- Daten heraus keinen besonderen Mehrwert bietet und relevante Informationen zur Sicherheit dadurch nicht verloren gehen. Darüber hinaus wird vermieden, dass die Meldung der einzelnen Sicherheiten z.B. einzelne Kraftfahrzeuge, einzelne Wertpapiere zu einer erheblichen Anzahl an Datensätzen in der Tabelle empfangene Sicherheiten und zu einem Vielfachen an Datensät- zen in der Tabelle Instrument-empfangene Sicherheiten führt. Auch reduziert sich die Gefahr, dass bei fehlerhaften Datenfeldern eine sehr hohe Anzahl an Validierungsfehlern zustande kommt. 3. Der Start des neuen Non-Compliance Verfahrens der EZB Wie bereits während des DK Treffens am 24.01.2023 angekündigt, findet ab dem 30. April 2024 das neue Non-Compliance Verfahren der EZB erstmalig für AnaCredit Anwendung. Auf Grund- lage der Verordnung EU 20221917 der Europäischen Zentralbank 1 sind alle Berichtspflichti- gen dazu aufgefordert, ihre AnaCredit Meldedateien fristgerecht bei der Bundesbank einzu- reichen. Bei drei oder mehr einem Berichtspflichtigen zur Last gelegten Übertretungen der monatlichen Berichtspflichten innerhalb von sechs aufeinanderfolgenden Monaten droht ein Übertretungsverfahren, welches im äußersten Fall finanzielle Sanktionen nach sich zieht. Für die vierteljährlichen Berichtspflichten findet dies bei drei oder mehr Übertretungen innerhalb von vier aufeinanderfolgenden Quartalen Anwendung. Das neue Non-Compliance Verfahren gilt erstmalig für die monatlichen Berichtspflichten des Meldetermins April 2024, bzw. für die vierteljährlichen Berichtspflichten des Meldetermins März 2024. Die monatlichen und vierteljährlichen Einreichungsfristen der AnaCredit- Meldung sind in der statistischen Anordnung festgelegt Mitteilung80012020 bundesbank.de. Die konkre- ten Einreichungstermine können Sie ebenfalls unserer Homepage entnehmen httpswww.bundesbank.dedeservicemeldewesenbankenstatistikkredit datenstatistik- anacredit--611424. 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Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard Comments to be received by 31 July 2024 IASBED20242 International Accounting Standards Board SMEs March 2024 Exposure Draft IFRS for SMEs Accounting Standard Exposure Draft Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard Comments to be received by 31 July 2024 Exposure Draft Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard is published by the International Accounting Standards Board IASB for comment only. Comments need to be received by 31 July 2024 and should be submitted by email to commentlettersifrs.org or online at httpswww.ifrs.orgprojectsopen-for-comment. All comments will be on the public record and posted on our website at www.ifrs.org unless the respondent requests confidentiality. Such requests will not normally be granted unless supported by a good reason, for example, commercial confidence. 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CONTENTS from page INTRODUCTION 4 INVITATION TO COMMENT 7 DRAFT AMENDMENTS TO THE THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD 10 APPROVAL BY THE IASB OF EXPOSURE DRAFT ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD PUBLISHED IN MARCH 2024 20 BASIS FOR CONCLUSIONS ON EXPOSURE DRAFT ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD 21 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 3 Introduction Why is the IASB publishing this exposure draft The International Accounting Standards Board IASB published the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard in September 2022 2022 Exposure Draft. At its September 2023 meeting, the IASB discussed the project plan for redeliberating the proposals in the 2022 Exposure Draft. The IASB confirmed that, based on the feedback on the Second Comprehensive Review of the IFRS for SMEs Accounting Standard, the scope of that review should be as proposed in the 2022 Exposure Draft, which was to consider alignment with full IFRS Accounting Standards that are effective on or before 1 January 2020.1 Nevertheless, the IASB reviewed all amendments to full IFRS Accounting Standards with an effective date after 1 January 2020 and assessed whether the scope of the Second Comprehensive Review should be extended to include any of these amendments. In making this assessment, the IASB considered the needs of users of SMEs’ financial statements and feedback from the SME Implementation Group SMEIG that Supplier Finance Arrangements and Lack of Exchangeability are relevant to SMEs.2,3 The IASB noted that the feedback on developing amendments to full IFRS Accounting Standards for supplier finance arrangements and lack of exchangeability also applies to SMEs. Consequently, the IASB decided to extend the scope of the Second Comprehensive Review and it proposes amendments to the IFRS for SMEs Accounting Standard to align a Section 7 Statement of Cash Flows with IAS 7 Statement of Cash Flows, as amended by Supplier Finance Arrangements and b Section 30 Foreign Currency Translation with IAS 21 The Effects of Changes in Foreign Exchange Rates, as amended by Lack of Exchangeability. IN1 IN2 IN3 IN4 1 The Second Comprehensive Review considers alignment with the requirements in full IFRS Accounting Standards that were effective at the publication date of the Request for Information Comprehensive Review of the IFRS for SMEs Standard. The Request for Information was published in January 2020. 2 The SME Implementation Group SMEIG advises the IASB on implementing and applying the Standard. Members of the SMEIG are appointed by the Trustees of the IFRS Foundation after a public call for nominations. The SMEIG normally includes accountants working in SMEs, auditors in small or medium-sized public practices, bank lenders and other users of the financial statements of SMEs. 3 In this exposure draft, the term SMEs’ refers to entities that are eligible to apply the IFRS for SMEs Accounting Standard that is, SMEs are entities that do not have public accountability and that publish general purpose financial statements for external users. EXPOSURE DRAFT MARCH 2024 4 IFRS Foundation Proposals in this exposure draft The proposals in this exposure draft supplement those in the 2022 Exposure Draft to amend the requirements in the IFRS for SMEs Accounting Standard. The supplementary amendments would require an SME a to disclose for its supplier finance arrangements i their terms and conditions ii the amount of the liabilities that are part of the arrangements, disclosing separately the amounts for which the suppliers have already received payment from the finance providers, and stating where the liabilities are presented in the statement of financial position iii the range of payment due dates and iv the type and effect of non-cash changes and b to apply a consistent approach in i assessing whether a currency can be exchanged into another currency and ii estimating the exchange rate to use and the disclosures to provide when a currency cannot be exchanged into another currency. The proposed amendments to Section 7 of the IFRS for SMEs Accounting Standard respond to users’ concerns that information about some supplier finance arrangements is not sufficiently transparent in SMEs’ financial statements, hindering users’ analysis. The proposed amendments are intended to enable users to obtain the information that they need to understand the effects of supplier finance arrangements on an SME’s financial statements and to compare one SME with another. The proposed amendments to Section 30 of the IFRS for SMEs Accounting Standard respond to stakeholder feedback and concerns about diversity in determining whether a currency can be exchanged into another currency and, when it cannot, in estimating the exchange rate to use. The IASB expects the proposed amendments to help SMEs and the users of their financial statements by addressing these matters they are not covered in the current edition of the Standard. Who would be affected by the proposals The proposed amendments to Section 7 of the IFRS for SMEs Accounting Standard would affect an SME that, as a buyer, enters into one or more supplier finance arrangements as described in the proposals, under which the SME, or its suppliers, can access financing for amounts the SME owes its suppliers. The proposed amendments to Section 30 of the IFRS for SMEs Accounting Standard would affect an SME IN5 IN6 IN7 IN8 IN9 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 5 a that has transactions in non- exchangeable foreign currencies b that has a foreign operation with a non-exchangeable functional currency or c whose presentation or functional currency is non-exchangeable. Next steps The IASB will consider the comments it receives on the proposals in this exposure draft and will decide whether to proceed with the proposed amendments to the IFRS for SMEs Accounting Standard. The IASB plans to include any resulting amendments in the third edition of the IFRS for SMEs Accounting Standard. IN10 IN11 EXPOSURE DRAFT MARCH 2024 6 IFRS Foundation Invitation to comment The IASB invites comments on the proposals in this exposure draft, particularly on Questions 1 4. Comments are most helpful if they a respond to the questions as stated b specify the paragraphs to which they relate c contain a clear rationale d identify any wording in the proposals that is difficult to translate and e include any alternative approach the IASB should consider, if applicable. The IASB requests that comments are confined to the proposals in this exposure draft. Respondents need not answer all the questions in this invitation to comment. Questions for respondents Question 1 Supplier finance arrangements Scope and disclosure requirements proposed new paragraphs 7.19B 7.19C Proposed new paragraph 7.19B describes the characteristics of an arrangement about which an SME would be required to disclose the information described in this exposure draft. Paragraph 7.19B also sets out examples of the various forms of such arrangements that would be within the scope of the proposals. The IASB proposes an SME disclose in aggregate for its supplier finance arrangements a the terms and conditions but disclosing separately the terms and conditions of arrangements with dissimilar terms and conditions b as at the beginning and end of the reporting period i the carrying amounts, and associated line items presented in the SME’s statement of financial position, of the financial liabilities that are part of a supplier finance arrangement ii the carrying amounts, and associated line items, of the financial liabilities required to be disclosed as described in the preceding subparagraph for which suppliers have already received payment from the finance providers and iii the range of payment due dates for both the financial liabilities that would be required to be disclosed as described in i and comparable trade payables that are not part of the supplier finance arrangement and c the type and effect of non-cash changes in the carrying amounts of the financial liabilities that would be required to be disclosed as described in bi. Paragraphs BC1 BC12 of the Basis for Conclusions explain the IASB’s rationale for these proposals. Do you have comments or suggestions on the proposed amendments to Section 7 Please explain the reasons for your suggestions. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 7 Question 2 Supplier finance arrangements Costs of applying proposed new paragraph 7.19Cbii Some stakeholders informed the IASB that some information about supplier finance arrangements might not be readily available and might be costly to obtain. In particular, information about the carrying amounts, and associated line items, of the financial liabilities that are part of such arrangements and for which suppliers have already received payment from the finance providers proposed new paragraph 7.19Cb ii might not be readily available. Paragraphs BC13 BC15 of the Basis for Conclusions provide information about the potential costs of complying with the proposed disclosure requirement and explain the IASB’s rationale for this proposal. Do you agree that the benefits for users of SMEs’ financial statements would outweigh the potential costs for SMEs to provide the information required by proposed new paragraph 7.19Cbii Please explain the reasons for your view. Question 3 Lack of exchangeability proposed new paragraphs 30.5A, 30.28 30.29 and 30A.1 30A.18 Section 30 of the IFRS for SMEs Accounting Standard generally requires the use of a spot exchange rate when an SME reports foreign currency transactions or a foreign operation’s results and financial position in its financial statements. However, it does not specify the exchange rate to use when there is a lack of exchangeability between two currencies. To address this deficiency, the IASB proposes to amend Section 30 of the Standard a to specify when a currency is exchangeable into another currency b to set out the factors an SME is required to consider in assessing exchangeability and to specify how those factors affect the assessment c to specify how an SME determines the spot exchange rate when a currency is not exchangeable into another currency and d to require an SME to disclose information that would enable users of its financial statements to understand how a lack of exchangeability between two currencies affects, or is expected to affect, its financial performance, financial position and cash flows. Paragraphs 30A.1 30A.11 of draft Appendix A to Section 30 of the Standard set out the factors an SME would be required to consider in assessing exchangeability and specify how those factors would affect the assessment. Paragraphs 30A.12 30A.18 of draft Appendix A to Section 30 of the Standard provide application guidance that would help an SME estimate the spot exchange rate when a currency is not exchangeable into another currency. Paragraphs BC18 BC39 of the Basis for Conclusions explain the IASB’s rationale for these proposals. continued... EXPOSURE DRAFT MARCH 2024 8 IFRS Foundation ...continued Do you have comments or suggestions on the proposed amendments to Section 30 Please explain the reasons for your suggestions. Do you agree that the proposals in paragraphs 30A.1 30A.18 of draft Appendix A to Section 30 would provide sufficient application guidance for SMEs If you disagree with these proposals, please explain what you would suggest instead and why. Question 4 Effective date and transition proposed new paragraph A37A The IASB proposes a that the amended Section 7 and Section 30 of the IFRS for SMEs Accounting Standard have the same effective date as that of the third edition of the Standard4 b no transition relief in relation to the amendments to Section 7 of the Standard and c specific transition requirements in relation to the amendments to Section 30 of the Standard. Proposed new paragraph A37A of Appendix A to the Standard sets out transition requirements for the amendments to Section 30 of the Standard. Paragraphs BC16 BC17 and paragraphs BC40 BC44 of the Basis for Conclusions explain the IASB’s rationale for these proposals. Do you agree with these proposals Why or why not If you disagree with these proposals, please explain what you would suggest instead and why. Deadline The IASB will consider all written comments received by 31 July 2024. How to comment Please submit your comments electronically Online httpswww.ifrs.orgprojectsopen-for-comment By email commentlettersifrs.org Your comments will be on the public record and posted on our website unless you request confidentiality and we grant your request. We do not normally grant such requests unless they are supported by a good reason, for example, commercial confidence. Please see our website for details on this policy and on how we use your personal data. If you would like to request confidentiality, please contact us at commentlettersifrs.org before submitting your letter. 4 In the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard the IASB proposed that the effective date of the third edition of the Standard be a minimum of two years from the issue date, with early application permitted. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 9 Draft Amendments to the Third edition of the IFRS for SMEs Accounting Standard ... Section 7 Statement of Cash Flows Paragraphs 7.19B 7.19C including their related heading are added. New text is underlined. Supplier finance arrangements Supplier finance arrangements are characterised by one or more finance providers offering to pay amounts an entity owes its suppliers and the entity agreeing to pay according to the terms and conditions of the arrangements at the same date as, or a date later than, suppliers are paid. These arrangements provide the entity with extended payment terms, or the entity’s suppliers with early payment terms, compared to the related invoice payment due date. Supplier finance arrangements are often referred to as supply chain finance, payables finance or reverse factoring arrangements. An entity shall disclose in aggregate for its supplier finance arrangements a the terms and conditions of the arrangements for example, extended payment terms and security or guarantees provided. However, an entity shall disclose separately the terms and conditions of arrangements that have dissimilar terms and conditions. b as at the beginning and end of the reporting period i the carrying amounts, and associated line items presented in the entity’s statement of financial position, of the financial liabilities that are part of a supplier finance arrangement. ii the carrying amounts, and associated line items, of the financial liabilities disclosed in accordance with i for which suppliers have already received payment from the finance providers. iii the range of payment due dates for example, 30 40 days after the invoice date for both the financial liabilities disclosed in accordance with i and comparable trade payables that are not part of the supplier finance arrangement. Comparable trade payables are, for example, trade payables of the entity within the same line of business or jurisdiction as the financial liabilities disclosed in accordance with i. If ranges of payment due dates are wide, an entity shall disclose explanatory information about those ranges or divide them into narrower ranges. 7.19B 7.19C EXPOSURE DRAFT MARCH 2024 10 IFRS Foundation c the type and effect of non-cash changes in the carrying amounts of the financial liabilities disclosed in accordance with bi. Examples of non- cash changes include the effect of business combinations, exchange differences and other transactions that do not require the use of cash or cash equivalents see paragraph 7.18. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 11 Section 30 Foreign Currency Translation Paragraph 30.5A including its related heading and paragraphs 30.28 30.29 are added. New text is underlined. Estimating the spot exchange rate when a currency is not exchangeable paragraphs 30A.12 30A.18 If, at a measurement date, a currency is not exchangeable into another currency as described in paragraphs 30A.2 30A.11, an entity shall estimate the spot exchange rate at that date. An entity’s objective in estimating the spot exchange rate is to reflect the rate at which an orderly exchange transaction would take place at the measurement date between market participants under prevailing economic conditions. ... Disclosures ... When an entity estimates a spot exchange rate because a currency is not exchangeable into another currency see paragraph 30.5A, the entity shall disclose a the currency and a description of the restrictions that result in that currency not being exchangeable into the other currency b a description of affected transactions c the carrying amount of affected assets and liabilities d the spot exchange rates used and whether those rates are i observable exchange rates without adjustment see paragraphs 30A.13 30A.17 or ii spot exchange rates estimated using another estimation technique see paragraph 30A.18 and e information about the estimation process, including qualitative and quantitative information about the inputs and assumptions used. When a foreign operation’s functional currency is not exchangeable into an entity’s presentation currency or the presentation currency is not exchangeable into a foreign operation’s functional currency, an entity shall disclose a the name of the foreign operation whether the foreign operation is a subsidiary, joint arrangement, associate or branch and its principal place of business b summarised financial information about the foreign operation and 30.5A 30.28 30.29 EXPOSURE DRAFT MARCH 2024 12 IFRS Foundation c the nature and terms of any contractual arrangements that could require the entity to provide financial support to the foreign operation, including events or circumstances that could expose the entity to a loss. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 13 Appendix A to Section 30 is added. New text is underlined. Appendix A to Section 30 Application guidance This application guidance is an integral part of Section 30. Exchangeability The purpose of this application guidance is to help entities assess whether a currency is exchangeable see paragraphs 30A.2 30A.11 and estimate the spot exchange rate when a currency is not exchangeable see paragraphs 30A.12 30A.18. Step I Assessing whether a currency is exchangeable A currency is exchangeable into another currency when an entity is able to obtain the other currency within a time frame that allows for a normal administrative delay and through a market or exchange mechanism in which an exchange transaction would create enforceable rights and obligations. An entity assesses whether a currency is exchangeable into another currency a at a measurement date and b for a specified purpose. If an entity is able to obtain no more than an insignificant amount of the other currency at the measurement date for the specified purpose, the currency is not exchangeable into the other currency. An entity might determine that a currency is not exchangeable into another currency, even though that other currency might be exchangeable in the other direction. For example, an entity might determine that currency PC is not exchangeable into currency LC, even though currency LC is exchangeable into currency PC. Time frame A spot exchange rate is the exchange rate for immediate delivery. However, an exchange transaction might not always complete instantaneously because of legal or regulatory requirements, or for practical reasons such as public holidays. A normal administrative delay in obtaining the other currency does not preclude a currency from being exchangeable into that other currency. What constitutes a normal administrative delay depends on the facts and circumstances surrounding the exchange transaction. Ability to obtain the other currency In assessing whether a currency is exchangeable into another currency, an entity shall consider its ability to obtain the other currency either directly or indirectly, instead of its intention or decision to do so. For example, subject to the other requirements in paragraphs 30A.2 30A.11, regardless of whether the entity intends or decides to obtain currency PC, currency LC is 30A.1 30A.2 30A.3 30A.4 30A.5 30A.6 EXPOSURE DRAFT MARCH 2024 14 IFRS Foundation exchangeable into currency PC if the entity is able either directly to exchange LC for PC, or indirectly to exchange LC for another currency FC and then exchange FC for PC. Markets or exchange mechanisms In assessing whether a currency is exchangeable into another currency, an entity shall consider only markets or exchange mechanisms in which a transaction to exchange the currency for the other currency would create enforceable rights and obligations. Enforceability is a matter of law. Whether an exchange transaction in a market or exchange mechanism would create enforceable rights and obligations depends on the facts and circumstances surrounding the exchange transaction. Purpose of obtaining the other currency Exchange rates might vary depending on how the currency is to be used. For example, the relevant authorities of a jurisdiction might set a preferential exchange rate for imports of specific goods and a penalty’ exchange rate for dividend payments to other jurisdictions. Accordingly, whether a currency is exchangeable into another currency could depend on the purpose for which an entity obtains or hypothetically might need to obtain the other currency. In assessing exchangeability, an entity shall assume its purpose in obtaining the other currency is a to realise or settle individual foreign currency transactions, assets or liabilities when the entity reports foreign currency transactions in its functional currency see paragraphs 30.6 30.11 and 30.14 30.16. b to realise or settle its net assets or net liabilities when the entity uses a presentation currency other than its functional currency see paragraphs 30.17 30.21. The entity’s net assets might be realised by, for example, the payment of dividends to its shareholders or disposal of the investment in the entity by its shareholders. c to realise or settle its net investment in the foreign operation when the entity translates the results and financial position of a foreign operation into a presentation currency see paragraphs 30.22 30.23. The entity’s net investment in a foreign operation might be realised by, for example, receipt of dividends from the foreign operation or disposal of the investment in the foreign operation. An entity shall assess whether a currency is exchangeable into another currency separately for each purpose specified in paragraph 30A.9. Ability to obtain only limited amounts of the other currency A currency is not exchangeable into another currency at the measurement date if, for a purpose specified in paragraph 30A.9, an entity is able to obtain no more than an insignificant amount of the other currency. For example, an entity with a functional currency of LC has liabilities denominated in currency FC. The entity assesses whether the total amount of FC it can obtain for the purpose of settling those liabilities is no more than an insignificant amount 30A.7 30A.8 30A.9 30A.10 30A.11 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 15 compared with the aggregated amount the sum of its liability balances denominated in FC. Step II Estimating the spot exchange rate when a currency is not exchangeable paragraph 30.5A This Standard does not specify how an entity estimates the spot exchange rate when a currency is not exchangeable. In estimating the spot exchange rate to meet the objective in paragraph 30.5A, an entity is permitted to use either a an observable exchange rate without adjustment see paragraphs 30A.13 30A.17 or b another estimation technique see paragraph 30A.18. Using an observable exchange rate without adjustment Examples of an unadjusted observable exchange rate include a a spot exchange rate for a purpose other than that for which an entity assesses exchangeability see paragraphs 30A.14 30A.15 and b the first exchange rate at which an entity is able to obtain the other currency for the specified purpose after exchangeability of the currency is restored first subsequent exchange rate see paragraphs 30A.16 30A.17. Using an observable exchange rate for another purpose A currency that is not exchangeable into another currency for one purpose might be exchangeable into that currency for another purpose. For example, an entity might be able to obtain a currency to import specific goods but not to pay dividends. In such situations, the entity might conclude that an observable exchange rate for another purpose meets the objective described in paragraph 30.5A. An observable exchange rate for another purpose might not reflect the prevailing economic conditions when, for example a it includes an incentive’ or penalty’ set to encourage, or deter, entities from obtaining the other currency for particular purposes b an entity is able to obtain the other currency only for limited purposes such as to import emergency supplies c it is set through regular interventions by the relevant authorities or d it is unchanged over time instead of being updated daily or even more frequently. 30A.12 30A.13 30A.14 30A.15 EXPOSURE DRAFT MARCH 2024 16 IFRS Foundation Using the first subsequent exchange rate A currency that is not exchangeable into another currency at the measurement date for a specified purpose might subsequently become exchangeable into that currency for that purpose. In such situations, an entity might conclude that the first subsequent exchange rate meets the objective described in paragraph 30.5A. The first subsequent exchange rate might not reflect the prevailing economic conditions when, for example a the date at which exchangeability is restored is long after the measurement date or b an economy is subject to hyperinflation or high inflation and prices often change quickly, perhaps several times a day. Using another estimation technique An entity using another estimation technique is permitted to use any observable exchange rate including rates from exchange transactions in markets or exchange mechanisms that do not create enforceable rights and obligations and adjust that rate, as necessary, to meet the objective described in paragraph 30.5A. 30A.16 30A.17 30A.18 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 17 Appendix A Effective date and transition This Appendix is an integral part of the Standard. Paragraph A37A is added. New text is underlined. ... Transition ... Foreign currency translation ... In applying paragraph 30.5A, an entity shall not restate comparative information. Instead a when the entity reports foreign currency transactions in its functional currency, and, at the date of initial application, concludes that its functional currency is not exchangeable into the foreign currency or, if applicable, the foreign currency is not exchangeable into its functional currency, the entity shall at the date of initial application i translate affected foreign currency monetary items, and non- monetary items measured at fair value in a foreign currency, using the estimated spot exchange rate at that date and ii recognise any effect of initially applying the amendments as an adjustment to the opening balance of retained earnings. b when the entity uses a presentation currency other than its functional currency, or translates the results and financial position of a foreign operation, and, at the date of initial application, concludes that its functional currency or the foreign operation’s functional currency is not exchangeable into its presentation currency or, if applicable, its presentation currency is not exchangeable into its functional currency or the foreign operation’s functional currency, the entity shall at the date of initial application i translate affected assets and liabilities using the estimated spot exchange rate at that date ii translate affected equity items using the estimated spot exchange rate at that date if the entity’s functional currency is hyperinflationary and iii recognise any effect of initially applying the amendments as an adjustment to the cumulative amount of translation differences accumulated in a separate component of equity. A37A EXPOSURE DRAFT MARCH 2024 18 IFRS Foundation Appendix B Glossary of terms This Appendix is an integral part of the Standard. The Glossary of terms is amended. New text is underlined and deleted text is struck through. ... severe hyperinflation The currency of a hyperinflationary economy is subject to severe hyperinflation if it has both of the following characteristics a a reliable general price index is not available to all entities with transactions and balances in the currency and b exchangeability between the currency is not exchangeable into and a relatively stable foreign currency does not exist. Exchangeability is assessed in accordance with Section 30. ... ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 19 Approval by the IASB of Exposure Draft Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard published in March 2024 The Exposure Draft Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard was approved for publication by all 14 members of the International Accounting Standards Board. Andreas Barckow Chair Linda Mezon-Hutter Vice-Chair Nick Anderson Patrina Buchanan Tadeu Cendon Florian Esterer Zach Gast Hagit Keren Jianqiao Lu Bruce Mackenzie Bertrand Perrin Rika Suzuki Ann Tarca Robert Uhl EXPOSURE DRAFT MARCH 2024 20 IFRS Foundation Basis for Conclusions on Exposure Draft Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard This Basis for Conclusions accompanies, but is not part of, the Exposure Draft Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard Addendum Exposure Draft. It summarises the considerations of the International Accounting Standards Board IASB in developing the Addendum Exposure Draft. Individual IASB members gave greater weight to some factors than to others. Supplier finance arrangements paragraphs 7.19B 7.19C Background In May 2023 the IASB issued Supplier Finance Arrangements, which amended IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments Disclosures to require an entity to provide additional disclosures about its supplier finance arrangements. Supplier Finance Arrangements complements the disclosure requirements in full IFRS Accounting Standards. These requirements were identified by the Agenda Decision Supply Chain Financing Arrangements Reverse Factoring, which was published in December 2020 by the IFRS Interpretations Committee in response to feedback from users of financial statements about the limitations of those requirements. The main requirements in full IFRS Accounting Standards except for the disclosure requirements in IFRS 7 referred to in the Agenda Decision are already replicated in the IFRS for SMEs Accounting Standard or would be introduced by the proposed requirement to reconcile changes in liabilities arising from financing activities in paragraph 7.19A of the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard. Consequently, SMEs are already required to provide some information about financial liabilities and cash flows related to supplier finance arrangements. However, the IASB noted that users of SMEs’ financial statements might not be able to obtain some other information necessary to understand fully the effects of supplier finance arrangements on an SME’s liabilities and cash flows. In considering whether and how to amend the IFRS for SMEs Accounting Standard in the light of a new or amended full IFRS Accounting Standard, the IASB uses its alignment approach.5 The SME Implementation Group SMEIG was consulted about the relevance of supplier finance arrangements and the related amendments to IAS 7 in Supplier Finance Arrangements to SMEs. Feedback from the SMEIG was that Supplier Finance Arrangements are relevant to SMEs. Consequently, the IASB amended the scope of the Second Comprehensive Review of the IFRS for SMEs Accounting Standard to include the amendments to full IFRS Accounting Standards for supplier finance arrangements. BC1 BC2 BC3 5 The alignment approach has three principles relevance to SMEs, simplicity and faithful representation. See paragraphs BC27BC37 of the Basis for Conclusions on the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 21 Scope of disclosure requirements paragraph 7.19B In developing the requirements in full IFRS Accounting Standards, the IASB considered various types of supplier finance arrangements and noted that an entity might enter into arrangements with varying structures and for various reasons. Two typical examples of such arrangements are where a an entity obtains extended payment terms from the finance providers. The finance providers pay suppliers the amount they are due on the invoice due date, and the entity pays the finance providers an amount greater than the invoice amount at a date later than the related invoice date. b an entity does not obtain extended payment terms from the finance providers, but the entity might have negotiated extended payment terms with its suppliers in the light of existing supplier finance arrangements. Suppliers that are part of the supplier finance arrangement can choose to be paid a discounted amount by the finance providers earlier than the invoice due date. In relation to the proposals set out in this exposure draft, the IASB decided to use the term supplier finance arrangements’ to refer to the type of arrangements to which the corresponding amendments to full IFRS Accounting Standards apply. The IASB developed the scope of the proposed requirements a to capture all supplier finance arrangements, irrespective of i the reason an SME entered into those arrangements ii the form or labelling of the arrangements and iii the presentation of the related liabilities and cash flows in an SME’s statement of financial position and statement of cash flows b to remain operable as new practices and arrangements evolve and c to include only arrangements that finance amounts an SME owes its suppliers’ see proposed paragraph 7.19B.6 The proposals exclude finance arrangements that might have some but not all of the characteristics of supplier finance arrangements, as described in proposed paragraph 7.19B. Examples of arrangements that are not supplier finance arrangements within the meaning of the proposed new requirements include a arrangements that are solely credit enhancements for an SME such as financial guarantees including letters of credit used as guarantees and BC4 BC5 BC6 6 Like Supplier Finance Arrangements, the proposals in this exposure draft would not apply to arrangements that finance receivables or inventory. EXPOSURE DRAFT MARCH 2024 22 IFRS Foundation b instruments used by an SME to settle directly with a supplier the amounts owed such as a situation in which an SME uses a credit card to settle the amount owed to a supplier and then has an obligation to pay the issuing bank instead. Disclosure requirements paragraph 7.19C Using its alignment approach, the IASB took the disclosure requirements in Supplier Finance Arrangements as a starting point. It then considered whether to propose any simplifications based on users’ needs and the principles for reducing disclosures set out in paragraph BC157 of the Basis for Conclusions on the IFRS for SMEs Accounting Standard. In particular, paragraphs BC157a and BC157b state that users of SMEs’ financial statements are interested in information about a short- term cash flows and about obligations, commitments or contingencies and b liquidity and solvency. The IFRS for SMEs Accounting Standard generally omits the disclosure objectives from full IFRS Accounting Standards. The objectives are omitted because applying the principles for reducing disclosures for SMEs, only some of the disclosure requirements from full IFRS Accounting Standards are included in the IFRS for SMEs Accounting Standard.7 The inclusion of disclosure objectives in the IFRS for SMEs Accounting Standard might result in the perception that SMEs are required to provide the same disclosures that they would have provided in accordance with full IFRS Accounting Standards. Furthermore, the IASB stated that the amendments to the application guidance on IFRS 7 and Guidance on implementing IFRS 7 are not relevant to SMEs because they relate to financial instrument risk disclosure requirements that are not in the IFRS for SMEs Accounting Standard. Having considered its principles for reducing disclosures, and the disclosure requirements in Supplier Finance Arrangements, the IASB proposes to require an SME to disclose a the terms and conditions of the SME’s supplier finance arrangements paragraph 7.19Ca. This disclosure would inform users of its financial statements that such arrangements are in place and explain their nature. b the carrying amounts of financial liabilities that are part of a supplier finance arrangement and associated line items paragraphs 7.19Cbi. This disclosure would show the magnitude of the SME’s supplier finance arrangements and the line items in which financial liabilities that are part of those arrangements are presented. BC7 BC8 BC9 7 See paragraph BC157 of the Basis for Conclusions on the IFRS for SMEs Accounting Standard. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 23 c the carrying amounts of financial liabilities that are part of a supplier finance arrangement for which suppliers have already received payment from the finance providers paragraph 7.19Cbii. This disclosure would enable users of the SME’s financial statements i to analyse its liabilities and their effects on operating and financing cash flows and ii to understand how supplier finance arrangements affect its exposure to liquidity risk and how it might be affected if the arrangements were no longer available to it. d the range of payment due dates of i financial liabilities that are part of a supplier finance arrangement and ii comparable trade payables of the SME that are not part of such an arrangement. These disclosures would enable users of the SME’s financial statements to assess how the arrangements affect its cash flows. e the information described in proposed paragraph 7.19Cb as at the beginning and end of each reporting period. This disclosure would enable users of the SME’s financial statements to assess changes in the financial liabilities that are part of a supplier finance arrangement and to understand how these changes affect the SME’s cash flows during that period. f the type and effect of non-cash changes in the carrying amounts of the financial liabilities that the SME would be required to disclose in accordance with proposed paragraph 7.19Cbi. These non-cash changes include the effect of business combinations, exchange differences and other transactions that do not require the use of cash or cash equivalents. For example, an SME that buys goods and services from suppliers would typically classify the cash outflows to settle amounts owed to its suppliers as cash outflows from operating activities. If the SME owes its suppliers an amount that becomes part of a supplier finance arrangement, the SME having considered the terms and conditions of the arrangement might classify the cash outflow to settle the amount owed as a cash flow from financing activities. In such a circumstance, the SME might not have reported any cash inflow from financing activities, in which case the outcome is a non-cash change in liabilities arising from financing activities. The SME would be required to disclose information about non-cash changes in accordance with proposed paragraph 7.19Cc that information would enable users of its financial statements i to assess the carrying amounts of financial liabilities on a more comparable basis from one reporting period to another and ii to understand how these non-cash changes affect the SME’s cash flows. EXPOSURE DRAFT MARCH 2024 24 IFRS Foundation Aggregated information The IASB proposes to require an SME to aggregate the information it provides about its supplier finance arrangements. In the IASB’s view, in most cases, aggregated information about an SME’s supplier finance arrangements would satisfy the information needs of users of its financial statements. Supplier finance arrangements share the characteristics described in proposed paragraph 7.19B, and it is those characteristics that give rise to the information needs of users of financial statements. Therefore, users of an SME’s financial statements do not need information about each individual supplier finance arrangement. However, to avoid material information from being omitted or obscured when aggregated, the IASB proposes to require an SME to disclose a separately the terms and conditions of arrangements that have dissimilar terms and conditions. Disaggregated information would enable users of the SME’s financial statements to assess the various types of arrangements into which it has entered. b explanatory information about the ranges of payment due dates, or additional ranges, if those ranges are wide. The additional information would enable users of the SME’s financial statements to assess the effect of arrangements on its cash flows. As described in paragraph BC9f, proposed new paragraph 7.19Cc would require an SME to disclose non-cash changes in the carrying amounts of the financial liabilities that it would disclose in accordance with proposed paragraph 7.19Cbi.8 In the IASB’s view, these non-cash changes might not be apparent without additional disclosure. Section 3 of the IFRS for SMEs Accounting Standard requires an SME to apply its judgement to determine whether and how it aggregates or disaggregates information in its financial statements to avoid omitting or obscuring material information. Therefore, the IASB decided it was unnecessary to propose developing disaggregation requirements in addition to those described in paragraph BC10. Costs of complying with the disclosure requirements In responding to the IASB’s November 2021 Exposure Draft Supplier Finance Arrangements, stakeholders informed the IASB that the information an entity would be required to disclose in accordance with paragraphs 44Ha, 44Hbi and 44Hbiii of IAS 7 is generally available to entities. Therefore, the IASB’s view is that applying the equivalent requirements in proposed paragraphs 7.19Ca, 7.19Cbi and 7.19Cbiii, as set out in this exposure draft, would not result in substantial costs for an SME. BC10 BC11 BC12 BC13 8 The proposed requirement in paragraph 7.19Cc would not conflict with the requirement in proposed paragraph 7.19A for an SME to disclose a reconciliation between the opening and closing balances in the statement of financial position for liabilities arising from financing activities. ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 25 Some stakeholders informed the IASB that the information about the carrying amounts, and associated line items, of financial liabilities that are part of supplier finance arrangements for which suppliers have already received payment from the finance providers proposed new paragraph 7.19Cbii might not be readily available. In making this disclosure an SME might incur costs a amending contractual terms and conditions to access the required information from finance providers b developing processes and controls to collect and validate the information to be disclosed and c having the information audited. Other stakeholders, particularly users of financial statements, informed the IASB that, without the requirement in proposed paragraph 7.19Cbii, an entity would disclose incomplete information that would fail to satisfy users’ information needs see paragraph BC9c. The IASB evaluated the costs and benefits for preparers and users of financial statements and concluded that the benefits for users of the information that would be required by paragraph 7.19Cbii would outweigh the potential costs for preparers of providing this information. The IASB has decided to ask a specific question in the invitation to comment on this exposure draft to help it evaluate the costs and benefits of this proposed requirement for SMEs and users of their financial statements. Transition The IASB aims to finalise the proposed amendments and include them in the third edition of the IFRS for SMEs Accounting Standard.9 The IASB proposes no specific transition relief because SMEs would have enough time to provide the required information for comparative periods. The IASB proposes no specific transition requirements for a first-time adopter of the third edition of the IFRS for SMEs Accounting Standard because of the disclosure-only nature of the proposed amendments. Lack of Exchangeability Background The IASB had been informed that stakeholders hold diverse views on how to determine whether a currency is exchangeable into another currency, and the exchange rate to use if it is not. Although circumstances in which a currency is not exchangeable into another currency might arise relatively infrequently, when they do arise, they are generally accompanied by deteriorating economic conditions. In those circumstances, the diverse views about how to apply full IFRS Accounting Standards could lead to material differences in affected entities’ financial statements. Consequently, in August 2023, the IASB issued BC14 BC15 BC16 BC17 BC18 9 See footnote 4 on page 9. EXPOSURE DRAFT MARCH 2024 26 IFRS Foundation Lack of Exchangeability, which amended IAS 21 The Effects of Changes in Foreign Exchange Rates. The IASB consulted the SMEIG about the relevance of the amendments to IAS 21 to SMEs. The IASB considered the SMEIG’s feedback and assessed these amendments to be relevant to SMEs. Therefore, the IASB decided to amend the scope of its Second Comprehensive Review of the IFRS for SMEs Accounting Standard to include the amendments to full IFRS Accounting Standards for lack of exchangeability. Using its alignment approach, the IASB took the requirements and application guidance in Lack of Exchangeability as a starting point, and then considered whether to propose any simplifications. In considering possible simplifications, the IASB sought to achieve a balance between the costs that would be incurred by SMEs in applying any new requirements and the information needs of users of SMEs’ financial statements. Specifically, the IASB considered a how to keep Section 30 of the IFRS for SMEs Accounting Standard structurally consistent with the other sections of that Standard and how to keep the overall length of Section 30 in proportion with it b how to simplify the drafting of any new requirements c whether some of the application guidance included in Appendix A to IAS 21 which is an integral part of IAS 21 could be included in Section 30 of the IFRS for SMEs Accounting Standard instead of as an appendix to that section and d which disclosure requirements might be onerous for SMEs or unnecessary for users of SMEs’ financial statements bearing in mind the principles for reducing disclosures set out in paragraph BC157 of the Basis for Conclusions on the IFRS for SMEs Accounting Standard. Assessing whether a currency is exchangeable Many factors influence whether a currency is exchangeable into another currency. To make the definition of exchangeable’ operational and to help SMEs apply that definition consistently, the IASB proposes to specify the circumstances in which, for the purposes of the IFRS for SMEs Accounting Standard, an SME is able to exchange a currency for another currency. In developing the proposals in this Exposure Draft, the IASB decided these questions considered when it developed the amendments to IAS 21 applied equally to SMEs a what time frame for obtaining the other currency does an SME consider see paragraphs BC23 BC24 b what happens if an SME is able to obtain the other currency, but does not intend to do so see paragraph BC25 c which markets or exchange mechanisms for obtaining the other currency does an SME consider see paragraph BC26 BC19 BC20 BC21 BC22 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 27 d what is the purpose for which an SME obtains the other currency see paragraphs BC27 BC30 e what happens if an SME is able to obtain only limited amounts of the other currency see paragraphs BC31 BC32 Time frame Proposed paragraph 30A.5 reflects the IASB’s conclusion that a normal administrative delay in obtaining the other currency a does not contradict the notion of immediate delivery’ embodied in a spot exchange rate. The IASB concluded that the notion of immediate delivery’ includes a short period to meet administrative, legal or regulatory requirements in exchanging currencies. b does not preclude a currency from being exchangeable into that other currency. The IASB concluded that acknowledging the existence of normal administrative delays in currency exchanges would improve the operability of the proposed requirements. If an SME cannot consider a normal administrative delay in its assessment of the necessary time frame to exchange a currency for another currency, the SME might inappropriately conclude that a currency is not exchangeable into another currency. The IASB proposes not to develop application guidance on what constitutes a normal administrative delay’ this assessment would depend on the facts and circumstances surrounding an exchange transaction. Ability to obtain the other currency The IASB decided that whether a currency is exchangeable into another currency depends on an SME’s ability to obtain the other currency and not on its intention or decision to do so. For example, a currency might be exchangeable into another currency for the purpose of realising an SME’s net investment in a foreign operation even if the SME has no intention of entering into a transaction that would result in realising that net investment. Markets or exchange mechanisms The nature and type of markets or exchange mechanisms can vary by jurisdiction. The IASB discussed whether to require an SME to consider specified markets or exchange mechanisms for example, government- administered exchange mechanisms in assessing exchangeability. The IASB decided that, in assessing whether a currency is exchangeable into another currency, an SME would be required to consider only markets or exchange mechanisms in which a transaction to exchange that currency into the other currency would create enforceable rights and obligations. BC23 BC24 BC25 BC26 EXPOSURE DRAFT MARCH 2024 28 IFRS Foundation Purpose of obtaining the other currency In many jurisdictions particularly those in which exchange rates are free- floating, only one exchange rate exists between two currencies. In such jurisdictions, the purpose for which an SME intends to use the other currency would neither change the exchange rate nor affect the SME’s ability to obtain that other currency. However, for some currencies, exchange rates might vary depending on how the currency is to be used, which could affect the SME’s ability to obtain those currencies. The IASB therefore concluded that it is important for an SME to consider the purpose for which it obtains or hypothetically might need to obtain the other currency. The IASB considered, separately, situations in which an SME a reports foreign currency transactions in its functional currency see paragraph BC29 and b uses a presentation currency other than its functional currency or translates the results and financial position of a foreign operation see paragraph BC30. The requirements in paragraphs 30.6 30.11 and 30.14 30.16 of the IFRS for SMEs Accounting Standard specify how an SME reports foreign currency transactions in its functional currency. These requirements apply to individual foreign currency transactions, and monetary and non-monetary items relating to such transactions. The IASB decided that, when reporting foreign currency transactions, an SME is required to assess a currency’s exchangeability separately for each individual transaction, asset or liability. An SME would therefore assess whether it is able to obtain the other currency to realise or settle the transaction, or the asset or liability related to that transaction. The requirements in paragraphs 30.17 30.23 of the IFRS for SMEs Accounting Standard specify how an SME uses a presentation currency other than its functional currency and how it translates the results and financial position of a foreign operation. These requirements apply to all assets and liabilities of an SME or its foreign operation. The IASB therefore proposes to require an SME to assess exchangeability from the perspective of a transaction that would result in realising or settling its net assets or net liabilities or net investment in the foreign operation instead of individual assets or liabilities. The IASB noted that a an SME considers its ability to realise its net assets or net investment in a foreign operation in a single transaction at the measurement date for example, by disposal of the investment and not over time for example, by receiving a stream of dividends even if it might often be unable to realise its net assets or net investment in a foreign operation in a single transaction. b delays in remitting dividends might reflect a normal administrative delay. BC27 BC28 BC29 BC30 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 29 Ability to obtain only limited amounts of the other currency An SME might be able to obtain only limited amounts of the other currency. The IASB proposes to specify that, in such circumstances, a currency is exchangeable into another currency if an SME is able to obtain more than an insignificant amount of that other currency. In other words, if the activity in the market in which an SME obtains the other currency is so low that the SME is able to obtain only an insignificant amount of that other currency, the SME would estimate the spot exchange rate in accordance with proposed paragraph 30.5A of the IFRS for SMEs Accounting Standard in which case the SME is permitted to depart from using the observable exchange rate. In developing its proposals, the IASB considered the degree to which an SME assesses the significance of the amount of the other currency it is able to obtain for example, whether an SME carries out this assessment for each transaction and balance separately, or on an aggregated basis. The IASB proposes to require an SME to assess the significance of the amount of the other currency it is able to obtain for a specified purpose using the aggregate method described in proposed paragraph 30A.11 of the IFRS for SMEs Accounting Standard. Instead of requiring an SME to consider each transaction or balance separately, the aggregate method would require it to compare the amount of the other currency it is able to obtain with the aggregated amount the sum of the transactions or balances it needs to recover or settle. Estimating the spot exchange rate when a currency is not exchangeable The IASB proposes that when a currency is not exchangeable into another currency at a measurement date, an SME be required to estimate the spot exchange rate at that date. The objective described in proposed paragraph 30.5A of the IFRS for SMEs Accounting Standard is for an SME to estimate the rate at which an orderly exchange transaction hypothetically would take place at the measurement date between market participants under prevailing economic conditions. This approach is similar to although not the same as that of an SME measuring an asset or liability at fair value by estimating the price at which an orderly transaction to sell the asset or transfer the liability hypothetically would take place at the measurement date. The IASB proposes not to provide any detailed requirements specifying how an SME would estimate a spot exchange rate because a estimation of a spot exchange rate can be complicated and depends on SME-specific and jurisdiction-specific facts and circumstances. b an SME might use various economic models to estimate a spot exchange rate. These models vary in complexity and in the economic factors they use as inputs for example, inflation, interest rates, the balance of payments or a jurisdiction’s productivity. The IASB decided not to prescribe one particular estimation technique or approach because any one technique or approach would be unlikely to capture BC31 BC32 BC33 BC34 EXPOSURE DRAFT MARCH 2024 30 IFRS Foundation all relevant factors for all possible situations without being overly burdensome. c the requirements for assessing exchangeability are expected to result in an SME estimating the spot exchange rate in only a narrow set of circumstances. d the uncertainties inherent in estimating a spot exchange rate are similar to those that relate to other financial information based on estimates. An SME would be required to disclose relevant information about the estimated spot exchange rate and the estimation process see paragraphs BC36 BC39. e such an approach is consistent with the measurement requirements in other sections of the IFRS for SMEs Accounting Standard. The IASB noted that when a currency is not exchangeable into another currency, an SME does not necessarily need to use a complex estimation technique. To reduce complexity, the IASB proposes a to specify that an SME is permitted to use an observable exchange rate without adjustment as the estimated spot exchange rate, if that observable exchange rate meets the objective described in proposed paragraph 30.5A of the IFRS for SMEs Accounting Standard see also proposed paragraph 30A.13. b to set out a non-exhaustive list of factors to help SMEs assess whether those observable exchange rates would meet the objective described in paragraph 30.5A of the IFRS for SMEs Accounting Standard see proposed paragraphs 30A.14 30A.17. c to specify that an SME using another estimation technique could, for example, start with an observable exchange rate including a rate from an exchange transaction in a market or exchange mechanism that does not create enforceable rights and obligations and adjust that rate, as necessary, to estimate the spot exchange rate as required by paragraph 30.5A of the IFRS for SMEs Accounting Standard see proposed paragraph 30A.18. Disclosure An SME’s estimation of a spot exchange rate when a currency is not exchangeable into another currency could materially affect its financial statements. In making that estimation it would be necessary for the SME to make judgements and assumptions. When the IASB was developing the corresponding requirements in full IFRS Accounting Standards, users of financial statements told the IASB that they are interested not only in the effect on an entity’s financial statements of estimating the spot exchange rate, but also in understanding an entity’s exposure to a currency that is not exchangeable into another currency. Users said that information about the nature and financial effects of a currency not being exchangeable into another currency, the spot exchange rate used, the estimation process and the risks to which the entity is exposed would help their analyses. BC35 BC36 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 31 The IFRS for SMEs Accounting Standard generally omits the disclosure objectives from full IFRS Accounting Standards see paragraph BC8. In addition, the Standard does not require the same disclosures about an SME’s exposure to specific risks as required by full IFRS Accounting Standards. Therefore, the IASB proposes not to require an SME to provide information about the specific risks to which the SME is exposed because of the currency not being exchangeable. However, the IASB concluded that requirements akin to the other specific disclosure requirements included in IAS 21 would provide users of SMEs’ financial statements with useful information. The IASB concluded that it was unnecessary to include specific disclosure requirements regarding significant judgements made by an SME in assessing exchangeability. Paragraph 8.6 of the IFRS for SMEs Accounting Standard already requires disclosure of such judgements to the extent they are part of the judgements an SME’s management has made that have the most significant effect on the amounts recognised in the financial statements. The IASB noted that, for an SME applying proposed new paragraphs 30.28 30.29, as set out in this exposure draft, disclosures would be required when a currency is not exchangeable into another currency at the end of the reporting period and also when a currency is not exchangeable into another currency during part of the reporting period even if that is no longer the case at the end of the reporting period. Transition Entities already applying the IFRS for SMEs Accounting Standard The IASB proposes the same transition requirements as those for entities applying the corresponding amendments to IAS 21 to ensure that the requirements for lack of exchangeability are no more onerous for SMEs applying them for the first time than they are for entities applying full IFRS Accounting Standards. When developing the transition requirements in Lack of Exchangeability, the IASB concluded that the expected benefits of requiring entities to apply the amendments retrospectively would not outweigh the costs of doing so. In particular a an entity applying the amendments retrospectively would be required to assess exchangeability in prior periods and then estimate spot exchange rates for those prior periods. In many cases, retrospective application would be likely to require the use of hindsight and, even if possible without hindsight, would be costly. b a currency not being exchangeable into another currency is generally accompanied by high inflation and other economic events that make trend information less useful for users than in other situations. Users said that, if a currency is not exchangeable into another currency, they would be interested in understanding an entity’s exposure to that currency at the reporting date. BC37 BC38 BC39 BC40 EXPOSURE DRAFT MARCH 2024 32 IFRS Foundation The IASB therefore proposes to require an SME to apply the amendments from the date of initial application without restating comparative information. The IASB proposes a to require an SME to translate items using the estimated spot exchange rate at the date of initial application if the related requirement in the IFRS for SMEs Accounting Standard requires an SME to translate that item using the closing rate. b to prohibit an SME from retranslating other items, even though they might have been translated using a spot exchange rate that is not aligned with the amendments. The expected benefits of requiring an SME to identify those items and then estimate an appropriate exchange rate would not outweigh the costs of doing so. c to require an SME to recognise any effect of initially applying the amendments as an adjustment to i the opening balance of retained earnings when the SME reports foreign currency transactions. For these transactions, an SME generally recognises exchange differences in profit or loss. Requiring SMEs to track separately any exchange differences recognised in other comprehensive income would introduce unnecessary complexity. ii the cumulative amount of translation differences in equity when the SME uses a presentation currency other than its functional currency or translates the results and financial position of a foreign operation. In these situations, an SME generally recognises exchange differences in other comprehensive income and accumulates those differences in a separate component of equity. First-time adopters The IASB concluded that a specific exemption from retrospective application of the amendments would be unnecessary for a first-time adopter of the IFRS for SMEs Accounting Standard because a Section 35 Transition to the IFRS for SMEs does not provide any exemption for a first-time adopter that reports foreign currency transactions in its financial statements. The SME therefore applies all the applicable requirements in Section 30 retrospectively when reporting foreign currency transactions. b paragraph 35.10e of the Standard already permits a first-time adopter to deem the cumulative translation differences for all foreign operations to be zero at its date of transition to the Standard. The IASB proposes to amend the definition of severe hyperinflation’ in Appendix B to the IFRS for SMEs Accounting Standard for consistency with the proposed requirements in Section 30. BC41 BC42 BC43 ADDENDUM TO THE EXPOSURE DRAFT THIRD EDITION OF THE IFRS FOR SMES ACCOUNTING STANDARD IFRS Foundation 33 Effective date The IASB proposes that the effective date of the requirements for supplier finance arrangements and lack of exchangeability be the same as the effective date of the third edition of the IFRS for SMEs Accounting Standard that is, a minimum of two years from the date when the third edition of the Standard is issued, with early application permitted. BC44 EXPOSURE DRAFT MARCH 2024 34 IFRS Foundation Columbus Building 7 Westferry Circus Canary Wharf London E14 4HD, UK Tel 44 0 20 7246 6410 Email customerservicesifrs.org ifrs.org International Financial Reporting Standards, IFRS Foundation, IFRS, IAS, IFRIC, SIC, IASB, ISSBTM, IFRS for SMEs

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27 March 2024 ESMA74-1049116225-623 ESMA - 201-203 rue de Bercy - CS 80910 - 75589 Paris Cedex 12 - France - www.esma.europa.eu 1 Public statement Deprioritisation of supervisory actions on the EMIR clearing obligation for third-country pension scheme arrangements in light of the agreement on the EMIR review The European Commission published a proposal to amend EMIR on 7 December 2022, a.k.a. EMIR 3. Following a series of negotiations on the EMIR 3 text proposal, the Council and the European Parliament reached a provisional agreement on 7 February 2024. The political agreement on the EMIR 3 text was confirmed by the Committee of Permanent Representatives of the Governments of the Member States of the European Union COREPER, subject to further legal linguistic revision, which was then published1 on 14 February 2024. Taking into account the standard process that legislative proposals follow until finalisation and adoption, it is reasonable to expect that the final EMIR 3 text could be adopted and published in the Official Journal before the end of 2024 and enter into force 20 days thereafter. The published EMIR 3 text includes, among others, a provision in relation to pension scheme arrangements established in a third-country TC PSA. This measure provides for an exemption regime from the EMIR clearing obligation when the TC PSA is exempted from the clearing obligation under that third country’s national law. This would also mean that under EMIR 3, counterparties entering into OTC derivatives with such TC PSAs would not be required to clear these OTC derivative transactions. Stakeholders have expressed concerns that having to clear such OTC derivative transactions now while this requirement would no longer apply in a few months, where the relevant conditions are met when EMIR 3 enters into force, would expose them to operational and execution challenges. From a legal perspective, neither ESM nor the national competent authorities possess any formal power to dis-apply a directly applicable EU legal text in exceptional circumstances. ESMA also does not currently possess any appropriate tools or powers to grant forbearance to deal with such exceptional circumstances that warrant a temporary dis-application of requirements under EU Law. Therefore, any change to the application of the EU rules, such as the creation of an exemption or granting specific suspension powers, would need to be implemented through EU legislation. 1 Capital markets Union Council and Parliament agree on improvements to EU clearing services - Consilium europa.eu 2 However, in view of the challenges that stakeholders would face if they have to comply with the requirement until EMIR 3 enters into force, ESMA would expect national competent authorities not to prioritise their supervisory actions in relation to the clearing obligation for transactions conducted with TC PSAs exempted from the clearing obligation under their third country’s national law, and to generally apply their risk-based supervisory powers in their day- to- day enforcement of applicable legislation in this area in a proportionate manner.

EN EN EUROPEAN COMMISSION Brussels, 27.3.2024 C2024 2083 final ANNEX ANNEX to the Communication to the Commission Approval of the content of a draft Commission Notice on the interpretation and implementation of the transitional provision laid down in Regulation EU 2024791 of the European Parliament and of the Council of 28 February 2024 amending Regulation EU No 6002014 as regards enhancing data transparency, removing obstacles to the emergence of consolidated tapes, optimising the trading obligations and prohibiting receiving payment for order flow 1 Draft Commission Notice on the interpretation and implementation of the transitional provision laid down in Regulation EU 2024791 of the European Parliament and of the Council of 28 February 2024 amending Regulation EU No 6002014 as regards enhancing data transparency, removing obstacles to the emergence of consolidated tapes, optimising the trading obligations and prohibiting receiving payment for order flow 1. SCOPE OF THIS NOTICE Regulation EU No 6002014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation EU No 6482012 MiFIR is amended by Regulation EU 2024791 the MiFIR review. This interpretative notice aims to clarify the transitional arrangement set out in Article 543 of MiFIR as amended by the MiFIR review. The below references refer to Articles in MiFIR as amended by the MiFIR review. The notice does not extend in any way the rights and obligations deriving from the MiFIR review nor does it introduce any additional requirements for the operators concerned and competent authorities. Statements and opinions provided in this document reflect the view of the European Commission. According to the Treaty on the Functioning of the EU, the Court of Justice has the sole jurisdiction to interpret the acts of the institutions of the European Union. 2. THE COMMISSION’S READING OF ARTICLE 543 MiFIR The MiFIR review will enter into force on 28 March and apply as of that date. Several provisions in the MiFIR review need to be supplemented by Commission delegated regulations to become fully operational. For the transitional period, Article 543 MiFIR provides that the provisions of the delegated acts adopted pursuant to Regulation EU No 6002014 i.e. MiFIR as applicable before 28 March 2024 shall continue to apply until the date of application of the delegated acts adopted pursuant to Regulation EU No 6002014 i.e. MiFIR as amended by the MiFIR review as applicable from that date. Article 543 MiFIR aims to ensure continuity for market participants while the new Commission delegated regulations are being prepared. Pursuant to Article 543 MiFIR, the existing Commission delegated regulations continue to apply. In some cases, the new MiFIR provisions are to be supplemented by new or amended Commission delegated regulations to become fully operational and cannot be supplemented adequately by the existing Commission delegated regulations, due to the differences between the new MiFIR provisions and the MiFIR provisions that the existing Commission delegated regulations supplement, as applicable before 28 March 2024. In those cases, it follows from Article 543 MiFIR that the existing delegated regulations continue to apply together with the MiFIR provisions that they supplement, as applicable before 28 March 2024. For the areas identified below this means the following The volume cap mechanism Article 5 MiFIR Article 5 MiFIR on the single volume cap mechanism sets the threshold below which equity trading under the reference price waiver is allowed. Article 5 MiFIR is to be supplemented by 2 a Commission delegated regulation defining how ESMA collates, calculates and publishes the transaction data required to calculate the single volume cap1. As the single volume cap is calculated on the basis of a data set that is different from the data set used for the calculation of the double volume cap, the new single volume cap cannot be supplemented adequately by Commission delegated regulation EU 2017577 RTS 3. In consequence, pursuant to Article 543 MiFIR, the rules on the double volume cap, as specified in RTS 3, continue to apply. The single volume cap will become applicable as from the date of application of the Commission delegated regulation adopted pursuant to Article 59 MiFIR. Deferred publication of the details of transactions in respect of bonds, structured finance products or emission allowances and deferred publication of the details of transactions in respect of derivatives Articles 11 and 11a MiFIR Articles 11 and 11a MiFIR set out rules concerning the deferred publication of the details of transactions executed in respect of bonds, structured finance products, emission allowances and derivatives. Articles 11 and 11a MiFIR are to be supplemented by Commission delegated regulations defining the calibration of the deferral schedules2. As the MiFIR review has significantly amended the criteria to define such calibration, Articles 11 and 11a MiFIR cannot be supplemented adequately by Commission delegated regulation EU 2017583 RTS 2. In consequence, pursuant to Article 543 MiFIR, the deferral rules as applicable before 28 March 2024, as specified in RTS 2, continue to apply. The new deferral schedules for bonds, structured finance products, emission allowances and derivatives will apply as of entry into application of the Commission delegated regulations adopted pursuant to Articles 114 and 11a3 MiFIR respectively. Obligation to make pre-trade and post-trade data available on a reasonable commercial basis Article 13 MiFIR Article 13 MiFIR requires market operators, investment firms operating a trading venue, approved publication arrangements, consolidated tapes and systematic internalisers SIs to make the pre-trade and post-trade information on transactions in financial instruments available to the public on a reasonable commercial basis and to ensure non-discriminatory access to that information. Article 13 MiFIR is to be supplemented by a Commission delegated regulation specifying a number of elements, in particular what is to be included in the calculation of cost and reasonable margin 3. As the MiFIR review introduces a new principle according to which users cannot be charged based on the value that the data represents to them, Article 13 MiFIR cannot be supplemented adequately by Commission delegated regulation EU 2017565 and Commission delegated regulation EU 2017567. In consequence, pursuant to Article 543 MiFIR, the obligation to make pre- and post-trade data available on a reasonable commercial basis as applicable before 28 March 2024, as specified in the relevant provisions of Commission delegated regulation EU 2017565, Commission delegated regulation EU 2017567 and ESMA guidelines ESMA70-156-4263, continues to apply. The amended obligation to make pre-trade and post-trade data available on a reasonable commercial basis will apply as of entry into application of the Commission delegated regulation adopted pursuant to Article 135 MiFIR. 1 Article 59 MiFIR. 2 Articles 114 and 11a3 MiFIR. 3 Article 135 MiFIR. 3 Quotation rules for SIs in equity instruments Article 14 MiFIR Article 14 MiFIR delegates to a new Commission delegated regulation the definition of the minimum quote size as well as of the threshold below which pre-trade transparency rules apply to SIs in equity instruments4. Commission delegated regulation EU 2017587 only defines the methods to determine the standard market size. However, it does not contain any indication as to the minimum quote size and the threshold below which pre-trade transparency rules apply to equity SIs both elements being defined in Article 14 as applicable before 28 March. Article 14 MiFIR therefore cannot be supplemented adequately by Commission delegated regulation EU 2017587. In consequence, pursuant to Article 543 MiFIR, the quotation rules for SIs in equity instruments, as applicable before 28 March 2024, as specified in the relevant provisions of Commission delegated regulation EU 2017587, continue to apply. The new quotation rules for SIs will apply as of entry into application of the Commission delegated regulation adopted pursuant to Article 147 MiFIR. The obligation to report transactions Article 26 MiFIR Article 26 MiFIR sets out rules on the obligation for investment firms which execute transactions in financial instruments to report the details of such transactions to the competent authority. Article 26 MiFIR is to be supplemented by a Commission delegated regulation that will specify which financial instruments that have an index as the underlying need to be reported as well as modify certain details of the transactions to be reported5. Article 26 MiFIR therefore cannot be supplemented adequately by Commission delegated regulation EU 2017590 RTS 22. In consequence, pursuant to Article 543 MiFIR, the rules on transaction reporting as applicable before 28 March 2024, as specified in RTS 22, continue to apply. The new transaction reporting rules apply as of entry into force of the Commission delegated regulation adopted pursuant to Article 269 MiFIR. 4 Article 147 MiFIR. 5 Article 269 MiFIR.

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