“Type of impairment” according to EBA reporting framework 3.0
Question
The European Banking Authority (EBA) has released version 3.0 of its reporting framework, which requires institutions under IFRS to report instruments separately by impairment stage except where they are deemed credit-impaired at initial recognition in line with the definition of purchased or originated financial assets in IFRS 9 Appendix A. Please clarify how banks should report the attribute “type of impairment” in AnaCredit for instruments that were credit-impaired at initial recognition.
Answer
According to the AnaCredit Regulation, the data attribute “type of impairment” for institutions applying IFRS only includes impairment stages 1, 2 and 3 in accordance with EBA reporting framework 2.8.
The IFRS category “purchased or originated credit-impaired financial asset” (POCI) was included in EBA reporting framework 3.0 in June 2020 and became applicable for reports as of 30 June 2021. Changes in this reporting framework are linked to the revised Capital Requirements Regulation (CRR 2) (Regulation (EU) 2019/876 amending Regulation (EU) No 575/2013) and the new implementing technical standards (ITS) (Implementing Regulation (EU) 2021/451). In particular, the amendments include a separate category to classify FINREP POCIs in addition to other instruments classified in impairment stages 1, 2 or 3.
Given the new inclusion, we would like to clarify the reporting of the data attribute “type of impairment” under AnaCredit as follows:
Currently no specific category exists that allows POCIs to be captured explicitly under the data attribute “type of impairment”. Instead, the value “Stage 3 (IFRS)” is reported by banks applying IFRS for all POCIs which are impaired at the reference date, while the value “Stage 2 (IFRS)” is reported when the POCIs are not impaired at the reference date.
On this basis, the AnaCredit reporting schemes will be updated by introducing a new value “POCI (IFRS)” for the data attribute “type of impairment” to distinguish POCIs from other instruments subject to impairment in accordance with the EBA reporting framework methodology. To provide enough lead time for national central banks (NCBs) to inform their reporting agents on the specific values to be used, the first reference date as of which the new category “POCI (IFRS)” is to be used is 30 September 2022. In the meantime, for reference dates up to and including 30 June 2022, the POCIs are to be classified in “Stage 2 (IFRS)” or “Stage 3 (IFRS)”, depending on whether the POCI is impaired or not, as indicated above. The changes to the instructions do not require revisions of past data to be sent to AnaCredit.