1. 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

2. 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.

3. 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.

4. 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 ?

5. Filing Rules based on Best Practices
Approach
Year
Status
Publisher
Coverage
Rules on
FRIS1
2004
PWD2
XII3
XBRL 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.

6. 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:

7. 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.

8. Meta model of the CEN Filing Rules

9. 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

10. 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
Filing Manuals of the NCAs in Denmark, United Kingdom and Germany
Danmarks Nationalbank: Danish XBRL Filing Rules. February 2014
indberetninger/Indberetningsregler_fiona.ashx
FCA: COREP/FINREP Reporting Filing Manual. February 2014
Bundesbank: Regeln der Bundesbank für das bankaufsichtliche XBRL-Meldewesen. March 2014 (only in German)
_filing_rules.pdf?__blob=publicationFile …

11. Comparison of the Filing Manuals

12. 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

13. 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

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

15. Decrease in harmonisation

16. 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

17. 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

18. Thanks for your attention
Comments or questions?
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