Question
Please clarify whether this reporting exercise requires also the submission of data at sub-consolidated level, apart from consolidated and solo level.
Background on the question
In accordance to guidance received so far, we would be required to submit data at individual entity as much as at consolidated level; it remains nevertheless unclear to us as to whether we would also have to submit data at 1cTeilkonzern 1d-level", sub-consolidated level.
Answer
The reporting requirements to the competent authority apply at the same level as own funds requirements and the Draft ITS on Supervisory Reporting for Institutions for benchmarking the internal approaches (ITS on benchmarking) is based on Article 78 of the Directive 2013/36/EU (CRD IV). Hence, if an institution is required to calculate own funds requirements at a sub-consolidated level, reporting requirements will also be applicable. A check against own funds reporting requirements as specified in Regulation (EU) No. 680/2014 - ITS on reporting could be performed to establish whether or not benchmarking reporting requirements apply (template C 08.01 of Annex I of the ITS on reporting for credit risk internal approaches and template C 24.00 for market risk internal approaches). DISCLAIMER: The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal, which may differ from the text of the draft ITS to which this Q&A relates.