Filing rules and extensions of EBA/EIOPA taxonomies CEN/WS XBRL Recap Filing rules and extensions of EBA/EIOPA taxonomies 5 May, 2013 Katrin Heinze, Bundesbank (currently working for the ECB) CWA1

EU principles of transparency and non-discrimination Fundamental principles of the EC Law Increasing the competitiveness and support the movement of services Member states must transpose the EU Directives with precision, clarity and transparency to enable individuals to ascertain their obligations Providing significant impulses for harmonization in different business areas One of them: ICT - information and communication technologies ICT provides services for the industrial society which are essential to be competitive against markets in and outside of the EU ICT contribute to the overall business success Precondition ICT applications must be interoperable to provide efficient access to information and their distribution In this sense: The harmonization of the supervisory reporting in Europe by using DPM and XBRL is an important field of activity.

Technical background for the definition of filing rules XBRL is a framework for the definition of data formats provides a high degree of flexibility for the creation of taxonomies and instance documents flexibility requires complex IT systems to react appropriately on all possible variants that the standard allows, like definition of units, accuracy of values, usage of footnotes, periods, identifiers etc.

Definition and Advantages Rules to be followed for the preparation and validation of instance documents in a XBRL filing process which place additional constraints on XBRL instance documents. Advantages Provide harmonization on a technical level Enhance the interoperability of IT systems Ease the comparison of reporting data Ease the validation of instance documents Give rules to reporting entities as guidance Decrease the reporting burden for reporting entities Enable automated tests on the rule set XBRL Filing ?

Filing Rules based on Best Practices Approach Year Status Publisher Coverage Rules on FRIS1 2004 PWD2 XII3 XBRL 2.1 - only XBRL instances Global Filing Manual 2010 Best Practices SEC, FSA Japan, IFRS XBRL Standard XBRL instances and taxonomies EDGAR Filer Manual 2013 U.S. Securities and Exchange Commission Part of the CWA1 deliverables of the standardization process of CEN/WS XBRL oriented to reporting entities preparing the filings on basis of EIOPA and EBA taxonomies Recommendations to be adopted by NCAs and European Supervisory Authorities EFL FRIS GFM Financial Reporting Instance Standards Public Working Draft XBRL International Inc.

Structure of the Deliverable Currently 34 rules and descriptions separated in two chapters 12 Filing syntax rules Rules for the complete document to be filed 22 Instance syntax rules Syntax rules for the instance document and its subordinated objects Contexts Facts Units Footnotes Example:

Modeling the European Filing Rules Meta model Object system modeling Model system Object system comprises the clearly delimited real system and also its relevant environment. The object system is the XBRL instance document and the constraints defined on the preparation of XBRL instance documents. The constraints are based on the objects contained in an instance document and the relations among each other. Meta model provides model components, rules on how to combine components and the meaning (semantic) for the components and relations. UML class diagram to describe the structure of the XBRL instance by showing the classes, their attributes and possible methods. OCL (Object Constraint Language) is a formal language for specifications, which refers to an UML model to describe constraints about the objects in the model. Model system must be consistent and complete. It must reflect the structure of the object system.

Meta model of the CEN Filing Rules

European Reporting Frameworks Achievements so far Reporting entity XBRL Data Format & XBRL Filing Data Point Model ? Harmonised Harmonised Harmonised? European Reporting Frameworks First level reporting: reporting entities are banks and insurance companies, supervisors are NSAs Second level reporting: reporting entities are national supervisors, European supervisorsa are EBA and EIOPA European Supervisor © cundus AG

Analysis based on the following publications CEN: European Filing Rules. December 2013 (after approval by the stakeholders) EBA: XBRL Filing Rules COREP and FINREP Taxonomy v2. March 2014 https://www.eba.europa.eu/documents/10180/502670/EBA+XBRL+Filing+Rules+for+v2.0.0.pdf Filing Manuals of the NCAs in Denmark, United Kingdom and Germany Danmarks Nationalbank: Danish XBRL Filing Rules. February 2014 https://www.finanstilsynet.dk/~/media/Temaer/2014/Fremtidige- indberetninger/Indberetningsregler_fiona.ashx FCA: COREP/FINREP Reporting Filing Manual. February 2014 http://www.fca.org.uk/static/documents/corep-finrep-filing-manual.pdf Bundesbank: Regeln der Bundesbank für das bankaufsichtliche XBRL-Meldewesen. March 2014 (only in German) http://www.bundesbank.de/Redaktion/DE/Downloads/Service/Meldewesen/Bankenaufsicht/PDF/bundesbank _filing_rules.pdf?__blob=publicationFile …

Comparison of the Filing Manuals

Level of harmonisation CEN <-> EBA CEN rules adopted by EBA March 2014 8 of 32 define a different severity Number of CEN rules: 34 Number of EBA rules: 39 CEN EBA

Issues identified CEN <-> EBA First set of rules was reduced from 48 to 35 rules Some previously rejected rules have been added to the EBA rule set One rule seems to have a lack of details The indication of the severity is unclear is required = MUST is recommended = SHOULD; sometimes MAY

Level of harmonisation EBA <-> NCAs EBA rules adopted by DE, DK, UK March 2014 EBA NCAs

Decrease in harmonisation

Problems identified EBA <-> NCAs Harmonisation on technical level is not reached International acting reporting entities have to be prepared for the different validation requirements Some based on national language-dependent description NCAs might need to amend the file for transmitting it to ECB or EBA (i.e. duplicate facts are not restricted) Software prepared for the validation of the EBA Filing Rules does not cover all rules defined across Europe

Possible counter-measures Amending the CEN Filing Rules according to the amendments introduced by EBA Interested parties? Define a clear severity for each rule Ease the description of the rule (too technical?) Raise awareness in the Eurofiling community Eurofiling workshop (Done!) Conference call Publication of the analysis results at eurofiling.info Raise the issue at EBA level

Thanks for your attention Comments or questions? Page 18 CWA1 18