EBA Discussion Paper on the Pillar 3 Data Hub process to SNCIs (EBA/DP/2026/02)
Tag: S-2026-06-08-eba-p3dh-sncis Type: paper (regulator discussion paper / consultation) Author(s): European Banking Authority Date of source: 2026-06-08 (publication date on the discussion paper) Date ingested: 2026-06-10 Authority weight: high — primary EU prudential regulator; official consultation document (preliminary, non-binding). Raw file: S-2026-06-08-eba-p3dh-sncis.md. External URLs: https://www.eba.europa.eu/publications-and-media/publications (listing); https://www.eba.europa.eu/sites/default/files/2026-06/571e1ec7-2e50-42db-9035-1c2b21f75004/Discussion%20paper%20-%20P3DH%20SNCIs.pdf (PDF).
What it claims
The EBA’s Pillar 3 Data Hub (P3DH) is a centralised platform on the EBA website that provides a single access point to banks’ Pillar 3 prudential disclosures. It went live for large and other institutions on 26 January 2026, with data available from the June 2025 reference date; for those institutions the EBA simply publishes the Pillar 3 reports they submit, “without any transformation.” This discussion paper (EBA/DP/2026/02, 8 June 2026, comments due 20 July 2026) sets out how the P3DH will be extended to Small and Non-Complex Institutions (SNCIs) — a structurally different model. Under the CRR3 mandate (CRR Article 434, introduced by Regulation (EU) 2024/1623), and because SNCIs report rather than self-publish, the EBA will itself prepare and publish the Pillar 3 disclosures on behalf of SNCIs, calculated from the supervisory reporting data those institutions already submit to competent authorities under Article 430. The paper proposes the calculation methodology (a mapping tool plus an internal calculation engine; EU KM1 formulas in Annex I), publication dates, and a transition path.
Key proposals: ~2,300 SNCIs are in scope (listed SNCIs ≈4%, ~90 institutions). A staggered launch — first publication in Q4 2026 (reference date December 2025) covering only template EU KM1 (the sole template applicable to non-listed SNCIs as of end-2025), with the full set of SNCI Pillar 3 requirements envisaged for 2028 (reference date December 2027), conditional on the supervisory reporting framework carrying the necessary data points. Steady-state publication is proposed at end-September for non-listed SNCIs and end-April (or possibly end-June) for listed SNCIs. Crucially for governance, the paper proposes that an institution’s existing sign-off of its supervisory reporting submission constitutes formal sign-off of the disclosed data — “full responsibility and ownership of the data remain with the reporting institutions,” with the EBA’s role “limited to ensuring that the simple calculations … run correctly.” The initiative is framed as proportionality and compliance-cost reduction (no individual disclosure channels) and as improving transparency, comparability and market discipline. It is tightly coupled to the open Consultation Paper on revisions to the ITS on supervisory reporting (Commission Implementing Regulation (EU) 2024/3117), “Module 8 – Alignment of P3 for SNCIs”, published 10 April 2026 and closing 10 July 2026, which bridges remaining data gaps.
Notable quotes
“The EBA is now implementing the extension of the P3DH process to Small and Non-Complex Institutions (SNCIs). For these institutions, the EBA is mandated to prepare and publish the Pillar 3 disclosures based on supervisory reporting data submitted to competent authorities.” — EBA/DP/2026/02, Executive Summary (8 June 2026)
“the submission of that information through the regular supervisory reporting channels, which is approved by the institution, constitutes the institution’s formal sign-off of the data to be disclosed … full responsibility and ownership of the data remain with the reporting institutions.” — EBA/DP/2026/02, §4.2 (Supervisory reporting), para 9
What’s speculative vs. asserted
- Asserted: publication and identity of the discussion paper (EBA/DP/2026/02, 8 June 2026, comments due 20 July 2026); the P3DH go-live for large/other institutions on 26 January 2026; the CRR3/Article 434 and Article 430 mandates; the centralised-calculation model for SNCIs; the supervisory-reporting sign-off mechanism; the coupling to the ITS-on-supervisory-reporting consultation (closes 10 July 2026).
- Speculative / proposed (non-binding): all proposed dates (Q4 2026 first publication, end-September / end-April-or-June steady state, 2028 full set), the staggered scope, the calculation formulas in Annex I, and Options A/B for the 2027 (reference Dec 2026) publication. The paper states its views “are preliminary and will not bind in any way the EBA” and are intended to elicit discussion.
Topics this feeds
Open questions raised
- Whether the proposed steady-state publication date for listed SNCIs should be end-April (aligned to the Transparency Directive) or end-June (to allow audited supervisory data to stabilise).
- Whether industry prefers Option A (EU KM1 only) or Option B (additional templates where data is available) for the second publication (2027, reference Dec 2026).
- How the SNCI “sign-off via supervisory reporting” model interacts with Article 432 CRR omissions (non-material/proprietary/confidential information), which must be flagged to the EBA at least one month before publication.