CRR/CRD Reporting & Communication with Supervisory Authorities

Under CRR/CRD, banks must regularly submit COREP reports on own funds, large exposures and leverage ratio, as well as FINREP reports for financial reporting to ECB and BaFin. Additional ad-hoc reporting obligations apply for material events, liquidity reports (LCR, NSFR) and, since CRR III, extended ESG risk data requirements. Submissions use standardised XBRL taxonomies and must reach the competent supervisory authorities within the prescribed deadlines.

The Supervisory Review and Evaluation Process (SREP) is the annual comprehensive assessment of an institution by supervisory authorities. For significant institutions, Joint Supervisory Teams (JSTs) of the ECB conduct the SREP; for less significant institutions, BaFin and Bundesbank share this responsibility. Preparation includes a self-assessment of capital planning, risk-bearing capacity and governance, compilation of all relevant documentation, and alignment of the communication strategy for the supervisory dialogue. A proactive, transparent approach demonstrably improves SREP outcomes.

A Joint Supervisory Team (JST) is the combined supervisory team of ECB representatives and national supervisors (BaFin/Bundesbank) responsible for the ongoing supervision of a significant institution. JST communication encompasses regular supervisory meetings, data requests, thematic reviews and the SREP assessment. Key success factors include a single point of contact within the institution, proactive information sharing, professional preparation of documentation and a consistent communication approach across all hierarchical levels.

Data quality in regulatory reporting requires a systematic approach: automated plausibility checks before each submission, reconciliation between COREP/FINREP data and internal accounting, clear data governance structures with defined data owners, and a four-eyes principle for report preparation. The ECB has repeatedly identified poor data quality as a frequent finding in supervisory examinations. A data quality framework with KPIs, regular validation runs and documented correction processes significantly reduces supervisory queries.

A special examination under Section 44 of the German Banking Act (KWG) is ordered by BaFin and conducted by external auditors or Bundesbank staff. It may focus on specific themes — such as credit risk, IT security or governance — or be event-driven. Preparation includes identifying the examination focus, assembling an internal project team, compiling all relevant documentation and establishing a communication matrix for engagement with examiners. Professional examination support from experienced consultants shortens examination duration and minimises supervisory findings.

COREP (Common Reporting) and FINREP (Financial Reporting) are the EU-wide harmonised reporting frameworks for banks. COREP covers reports on own funds, capital ratios, large exposures, leverage ratio and liquidity metrics. FINREP addresses supervisory financial reporting including balance sheet, P&L, asset quality and provisions. Since CRR III implementation, reporting requirements have increased in granularity and frequency. An efficient COREP/FINREP infrastructure with automated data flows and integrated validation rules is key to timely and error-free submissions.

Strategic supervisory communication starts with defining a clear communication strategy: who communicates which topics through which channels to which supervisory authority. Central elements include a dedicated regulatory affairs team, standardised processes for ad-hoc requests, an escalation framework for critical issues, and regular proactive updates to supervisors. Building a trust-based dialogue — particularly in the JST context — requires transparency, consistency and professional preparation. Institutions that communicate proactively and in a structured manner experience fewer supervisory interventions and gain greater flexibility on regulatory discretionary matters.