Pillar 3 Disclosure under CRR/CRD

CRR Part 8 (Articles 431–455) requires credit institutions to disclose information on own funds, capital requirements, credit risk, market risk, operational risk, remuneration and governance. Disclosure uses standardised EBA templates – quantitative tables (e.g. EU OV1, EU CR1–CR5, EU MR1–MR4) and qualitative narratives. Since CRR II, expanded requirements cover TLAC/MREL disclosure and interest rate risk in the banking book. ADVISORI supports full coverage of all disclosure tables and narratives.

The EBA Pillar 3 Data Hub is a centralised electronic platform through which institutions submit their disclosure reports. The EBA published final ITS for technical implementation in 2025. Onboarding follows five steps: registration, technical connectivity, test submission, validation and production submission. Large institutions have been required to report via the Data Hub since late 2025; from Framework 4.2 (reference date March 2026) expanded taxonomy requirements apply. ADVISORI supports the entire onboarding process.

The CRR distinguishes three proportionality tiers: large institutions (Article 433a) must disclose comprehensively on a semi-annual basis. Other institutions (Article 433b) disclose a reduced scope annually. Small and non-complex institutions (SNCI, Article 433c) have only minimal requirements. The proportionality assessment determines which EBA templates must be completed and at what frequency. ADVISORI conducts the classification and ensures your institution discloses exactly the required – but no more than the required – scope.

Article 449a CRR requires large institutions with listed securities to disclose ESG risks. The EBA ITS define ten templates covering transition risk, physical climate risk, Green Asset Ratio (GAR), Banking Book Taxonomy Alignment Ratio (BTAR) and ESG risk management. From 2025, these requirements apply to all EU banks, including around 2,000 Less Significant Institutions. ADVISORI supports data collection (CO2 emissions, NACE codes, taxonomy alignment), template population and integration into the overall Pillar 3 report.

The EBA provides a comprehensive set of templates in the Technical Package. Key templates include: EU OV1 (overview of total risk amount), EU CR1–CR5 (credit risk), EU MR1–MR4 (market risk), EU OR1 (operational risk), EU LR1–LR3 (leverage ratio), EU LIQ1–LIQ2 (liquidity), EU REM1–REM5 (remuneration) and the ESG templates (Tables 1–10). Each table has specific instructions and validation rules. The EBA Mapping Tool (versions 3.0–4.2) facilitates the mapping. ADVISORI has developed automated population processes for all templates.

CRR III (in force from January 2025, full application from 2028) introduces major changes: the output floor (72.5% standardised approach) must be disclosed, new templates for the Fundamental Review of the Trading Book (FRTB), expanded credit risk disclosure and stronger ESG integration. The EBA Pillar 3 Data Hub becomes the central submission platform. Institutions must adapt their reporting processes, IT systems and data models. ADVISORI supports the CRR III migration with a structured transition project.

Consistency between disclosure, COREP submissions and financial statements is one of the greatest challenges. The EBA explicitly requires reconcilability – table EU LI1 compares balance sheet values with regulatory exposure values. Deviations must be explained in EU LI2. ADVISORI establishes central data sources (golden source), automated consistency checks and documented reconciliation processes, ensuring that the disclosure report, COREP and financial statements are demonstrably consistent.