EBF comments on the consultation on guidelines on disclosure requirements under part eight of the regulation

Publication date: 15 September 2016

Key points:

• The draft Guidelines fail short of achieving their outspoken objective and the EBA initiative lacks, moreover, any legal basis. The document should be presented as a mere (non-binding) opinion of the European Banking Authority.


• The level of granularity of the proposed templates is overwhelming whilst a careful detailed cost-benefit analysis is lacking. To meet EU Better Regulation Principles, the EBA may be expected to carefully explain on a template-by-template basis how the excessive detail of the disclosures would be contributing to market discipline.


• The suggested early implementation date of a subset of 11 templates by year end 2016 is not feasible.


• With regards to the details of the proposals, definitions are unclear in many cases and various templates would benefit from a review as well.

Document no longer available.