Launching the 2023 ex-ante contributions cycle
The Single Resolution Board (“SRB”) announced the start of the 2023 ex-ante contributions cycle for the calculation and collection of ex-ante contributions to the Single Resolution Fund (“SRF”).
As always, the first phase of the cycle is the collection of data pertaining to the institutions under the obligation to contribute to the SRF, which is used to determine their 2023 ex-ante contributions. The SRB has provided the 2023 Data Reporting Form and the related documentation to the National Resolution Authorities (“NRAs”), which in turn distribute the data collection package to the institutions under their remit.
For an overview of the key steps and the preliminary timeline of the 2023 ex-ante contributions cycle, you can consult the 2023 cycle Kick-off letter (link below).
In the context of the start of the 2023 cycle, institutions are requested to take note of the fact that the SRB has been informed by the European Commission that it is considering amending Article 5(3) of the Commission Delegated Regulation (EU) 2015/63 as regards the methodology to be used for the value adjustment of liabilities arising from derivatives.
Article 5(3) Commission Delegated Regulation (EU) 2015/63 requires institutions to apply the leverage ratio methodology reflected in Article 429c Regulation (EU) 575/203. However, the substantial changes introduced to this methodology by Regulation (EU) 2019/876 of 20 May 2019, which amended CRR, raises difficulties of application and warrants reflections as to whether to reinstate the former leverage ratio methodology for the purposes of valuating derivatives in the context of calculation of ex-ante contributions to the SRF.
Therefore, the Commission considers an amendment of Article 5(3) Commission Delegated Regulation (EU) 2015/63 accordingly.
In light of such envisaged amendment, for the purposes of the 2023 contributions cycle, the institutions are to apply the so-called “Derivatives Adjustment Method” (reflecting the former leverage ratio methodology) for the derivatives adjustment, which is included in the 2023 Guidance document that NRAs will provide to institutions.
As regards the impact thereof on the 2023 SRF Taxonomy and the remaining of the technical documents, institutions can find more information in the next section.
In line with Article 14 of Commission Delegated Regulation 2015/63, the SRB will collect the data needed for the calculation of 2023 ex-ante contributions to the SRF. NRAs are responsible for collecting such data from the institutions under their remit and for providing it to the SRB.
Data format accepted by the SRB
In the 2023 ex-ante contributions cycle, the NRAs can provide the data of the institutions to the SRB exclusively in XBRL-XML (eXtensible Business Reporting Language) format.
In order to facilitate the choice of the XBRL format and in line with the common practice for XBRL-based data collections, the SRB provides the following material:
- The SRF taxonomy for the 2023 data collection
- The SRF taxonomy complete package (2016-2023) data collection
- The SRB XBRL filing rules
- The SRF validation rules in a user-friendly format
- Example of valid XBRL instance
- The 2023 SRF reporting form
- The data privacy statement of the 2023 SRF reporting form
Note that, following the changes to the derivatives adjustment methodology, as highlighted above, the labels in some of the documents needed to be amended. This impacts the SRF taxonomy, the description of the error message of the SRF validation rules as well as the targeted textual representations of the SRF reporting form previously shared. You can find the updated documents above. The taxonomy hotfix corrects the rendering of some labels when converting the XBRL instance to an Excel file. The schema, the taxonomy version, the naming convention, the Data Point Model as well as the layout of the SRF Taxonomy is not impacted. Hence, the work done so far with the previously published taxonomy remains valid.
Public consultation procedure
As in previous cycles, the SRB grants the institutions the opportunity to make their views known on the main elements of the preliminary 2023 ex-ante contributions calculation decision. The consultation is to be launched on the 23 March. The consultation will give banks required to pay into to the SRF the chance to understand how much they are being required to pay this year and how that amount was calculated by the SRB. The consultation is a preliminary step before adoption of the final decision on the amount each and every bank has to pay.
Via the following link, institutions can access EU Survey from 23 March 2023 in the morning to 5 April 2023 18:00 CET.
Institutions will access the EU Survey via the password they received in the SRB Kick-off letter sent in October 2022.