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First name and last name:(organisation-identity-public)
Name of your organisation:([ID2])
Name of the public authority:([ID3])
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Type of organisation:(organisation-type)
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Where are you based and/or where do you carry out your activity?(country)
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Field of activity or sector (if applicable):(activity-field)
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a) financial stability (i.e. monitoring systemic risk)([ID15])
Please elaborate and provide examples to justify your answer to question 1.1.a):([ID58])
b) market integrity (i.e. surveillance of market abuse and orderly functioning of the markets)([ID15])
Please elaborate and provide examples to justify your answer to question 1.1.b):([ID58])
c) investor protection (i.e. ensuring proper conduct by firms to ensure that investors are not disadvantaged/negatively impacted)([ID15])
Please elaborate and provide examples to justify your answer to question 1.1.c):([ID58])
1.2 Are all of the existing supervisory reporting requirements relevant for maintaining financial stability and upholding market integrity and investor protection?([ID15])
If you do not think that all of the requirements are relevant, please provide specific examples of any requirements which in your view are superfluous and explain why you believe they are not necessary:([ID58])
1.3 Is there information that should be reported but which currently is not (i.e. there are reporting requirements that should be added)?([ID15])
If you answered yes to question 1.3, please provide specific examples of reporting requirements which in your view should be added and explain why you believe they are needed:([ID58])
1.4 To what extent are supervisory reporting requirements across different EU level reporting frameworks coherent (e.g. in terms of scope, content, methodology, timing/frequency of submission, etc.)?([ID15])
Please provide specific examples of reporting requirements which in your view are inconsistent and explain why you believe they are inconsistent:([ID58])
1.5 To what extent is supervisory reporting in its current form efficient?([ID15])
If you think that supervisory reporting is not fully efficient, please provide specific examples and explain why you believe it is not efficient:([ID58])
1.6 How well are the supervisory reporting requirements adapted to developments in the fields of modern information and communication technologies (ICT) and digital processes?([ID15])
Please elaborate and provide examples to justify your answer to question 1.6:([ID58])
1.7 To what extent has the adoption of supervisory reporting requirements at EU level facilitated supervisory reporting in areas where previously only national requirements existed?([ID15])
Please elaborate and provide examples to justify your answer to question 1.7:([ID58])
1.8 To what extent have options left to Member States in terms of implementing EU level supervisory reporting requirements (e.g. due to their adoption as Directives rather than Regulations) increased the compliance cost?([ID15])
If you think divergent Member State implementation has increased the compliance cost, please provide specific examples of reporting frameworks or requirements where you believe this to be the case and explain your suggestions:([ID58])
1.9 Are there any challenges in terms of processing the data, either prior to (i.e. within the reporting entity) or subsequent to (i.e. within the receiving/processing entity) it being reported?([ID15])
If you answered yes to question 1.9, please elaborate and provide specific examples:([ID58])
1.10 Are there any negative environmental and/or social impacts related to supervisory reporting stemming from EU legislation?([ID15])
If you answered yes to question 1.10, please elaborate and provide specific examples:([ID58])
2.1 Is supervisory reporting in its current form unnecessarily costly for its intended purposes (i.e. ensuring financial stability, market integrity, and investor protection)?([ID15])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Too many requirements ([ID77])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Need to report under several different reporting frameworks ([ID78])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Need to report to too many different entities ([ID79])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Lack of interoperability between reporting frameworks and/or between receiving/processing entities or supervisory authorities ([ID80])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Need to report too frequently ([ID81])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Overlapping requirements ([ID82])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Redundant requirements ([ID83])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Inconsistent requirements ([ID85])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Unclear/vague requirements ([ID86])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Insufficient use of (international) standards ([ID87])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Need to introduce/update IT systems ([ID89])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Need for additional human resources ([ID90])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Too many/too frequent amendments in the relevant legislation ([ID91])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Lack of a common financial language ([ID93])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Insufficient use of ICT Note: use of ICT is understood as presenting data in an electronic format rather than on paper and/or submitting it using electronic means (e.g. by email, via an online template) rather than by post or in person. ([ID150])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Insufficient level of automation of the reporting process Note: automation is understood as reducing or even fully eliminating human intervention from the supervisory reporting process. ([ID151])
2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting? : Lack of (adequate) technical guidance/specifications ([ID98])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 1([ID145]) : Factors([ID106])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 1([ID145]) : Rate from 0 to 4([ID140])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 2([ID146]) : Factors([ID106])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 2([ID146]) : Rate from 0 to 4([ID140])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 3([ID147]) : Factors([ID106])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 3([ID147]) : Rate from 0 to 4([ID140])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 4([ID148]) : Factors([ID106])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 4([ID148]) : Rate from 0 to 4([ID140])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 5([ID149]) : Factors([ID106])
Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting: Factor 5([ID149]) : Rate from 0 to 4([ID140])
2.3 To what extent have the following types of legislative/regulatory requirements been a source of excessive compliance costs in terms of supervisory reporting? : Supervisory reporting requirements imposed by EU Regulations and/or Directives ([ID102])
2.3 To what extent have the following types of legislative/regulatory requirements been a source of excessive compliance costs in terms of supervisory reporting? : Different Member State implementation of EU financial legislation, resulting in diverse national supervisory reporting requirements for the same financial entity/product ([ID103])
2.3 To what extent have the following types of legislative/regulatory requirements been a source of excessive compliance costs in terms of supervisory reporting? : National supervisory reporting requirements in addition to those in EU legislation for a specific financial entity/product ([ID104])
2.3 To what extent have the following types of legislative/regulatory requirements been a source of excessive compliance costs in terms of supervisory reporting? : Other supervisory reporting requirements in addition to those in EU legislation for a specific financial entity/product ([ID105])
Please specify what other supervisory reporting requirements in addition to those in EU legislation for a specific financial entity/product have been a source of excessive compliance costs:([ID58])
Please elaborate and provide examples to justify your answers to question 2.3:([ID58])
2.4 Does the obligation to use structured reporting1 and/or predetermined data and file formats2 for supervisory reporting increase or decrease the compliance cost of supervisory reporting? 1 (i.e. templates or forms in which specific data elements to be reported are listed). 2 (i.e. (i) the exact way in which the individual data elements are to be encoded or (ii) the file format in which the information to be reported is exchanged/submitted).([ID15])
Please provide specific examples to substantiate your answer to question 2.4:([ID58])
2.5 Please specify the supervisory reporting frameworks to which you are subject (or, in the case of entities receiving and/or processing the data or supervisory authorities, which you deal with or make use of):([ID58])
a i) please estimate its average initial implementation cost (i.e. one-off cost) in euro for your supervisory reporting frameworks:([ID15])
Average initial implementation cost in euro:([ID112])
Please explain why you cannot estimate the average initial implementation cost:([ID58])
a ii) please estimate the average initial implementation cost (i.e. one-off cost) as a percentage of total assets/turnover/other:([ID15])
Average initial implementation cost as a percentage of total assets:([ID112])
Average initial implementation cost as a percentage of turnover:([ID112])
Please specify on which other basis you are able to estimate the proportion of the average initial implementation:([ID58])
Average initial implementation cost as a percentage of the above-mentioned basis:([ID112])
Please elaborate on why you cannot estimate the average initial implementation cost as a percentage of total assets/turnover/other:([ID58])
b i) please estimate annual running cost in 2016 in euro:([ID15])
c ii) please estimate the average annual running cost over the last 5 years (i.e. recurrent cost) as a percentage of operating cost:([ID15])
Annual running cost in 2016 in euro:([ID112])
Please elaborate on why you cannot estimate the annual running cost in 2016:([ID58])
b ii) please estimate the annual running cost in 2016 (i.e. recurrent cost) as a percentage of operating cost:([ID15])
Annual running cost in 2016 as a percentage of operating cost:([ID112])
Please elaborate, as applicable, on the annual running cost in 2016 as a percentage of operating cost:([ID58])
Please elaborate on why you cannot estimate the annual running cost in 2016 as a percentage of operating cost:([ID58])
c i) please estimate average annual running cost over the last 5 years in euro:([ID15])
Average annual running cost over the last 5 years in euro:([ID112])
Please elaborate on why you cannot estimate the average annual running cost over the last 5 years in euro:([ID58])
Average annual running cost over the last 5 years as a percentage of operating cost:([ID112])
Please elaborate, as applicable, on the average annual running cost over the last 5 years as a percentage of operating cost:([ID58])
Please elaborate on why you cannot estimate the average annual running cost over the last 5 years as a percentage of operating cost:([ID58])
d i) please estimate average annual running cost over the last 10 years in euro:([ID15])
Average annual running cost over the last 10 years in euro:([ID112])
Please elaborate on why you cannot estimate the average annual running cost over the last 10 years in euro:([ID58])
d ii) please estimate the average annual running cost over the last 10 years (i.e. recurrent cost) as a percentage of operating cost:([ID15])
Average annual running cost over the last 10 years as a percentage of operating cost:([ID112])
Please elaborate, as applicable, on the average annual running cost over the last 10 years as a percentage of operating cost:([ID58])
Please elaborate on why you cannot estimate the average annual running cost over the last 10 years as a percentage of operating cost:([ID58])
2.5.2 Please indicate whether the above figures concern your entity as a whole or only a part thereof (i.e. a department, a subsidiary, a branch, a regional division, etc.).:([ID58])
2.6 Which reporting frameworks contribute the most to the cost of compliance with supervisory reporting requirements? Please indicate as many frameworks as necessary and explain your answer.([ID58])
2.7 Does your entity deal with supervisory reporting directly in-house or has this task been outsourced to an external provider?([ID15])
Please elaborate on your answer to question 2.7 and, if possible, explain the reasons for your business choice:([ID58])
2.8.1 a) at the end of 2016:([ID15])
Number of full-time equivalents:([ID112])
Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting in full-time equivalents (FTE) for 2016:([ID58])
2.8.1 b) in 2009:([ID15])
Number of full-time equivalents:([ID112])
Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting in full-time equivalents (FTE) for 2009:([ID58])
2.8.2 a) at the end of 2016:([ID15])
Percentage of the compliance work force:([ID112])
Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the compliance work force for 2016:([ID58])
2.8.2 b) in 2009:([ID15])
Percentage of the compliance work force:([ID112])
Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the compliance work force for 2009:([ID58])
2.8.3 a) at the end of 2016:([ID15])
Percentage of the total work force:([ID112])
Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the total work force for 2016:([ID58])
2.8.3 b) in 2009:([ID15])
Percentage of the total work force:([ID112])
Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the total work force for 2009:([ID58])
2.8.4 Please indicate whether the figures you provided in your answers to questions 2.8.1, 2.8.2 and 2.8.3 concern your entity as a whole or only a part thereof (i.e. a department, a subsidiary, a branch, a regional division, etc.):([ID58])
2.9 Have any of the EU level reporting frameworks brought (or partially brought) cost-saving benefits (e.g. simplified regulatory reporting, facilitated internal data management processes, improved risk management, increased operational efficiencies, etc.)?([ID15])
If you answered yes to question 2.9, please indicate which frameworks, explain in what way they have contributed to cost-savings, and if possible quantify the savings (with respect to previous or other similar reporting frameworks):([ID58])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Reduction of the number of data elements ([ID122])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Clarification of the content of the data elements ([ID123])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Greater alignment of reporting requirements ([ID124])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Greater standardisation/use of international standards ([ID125])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Development of a common financial language ([ID126])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Ensuring interoperability between reporting frameworks and/or receiving/processing entities or supervisory authorities ([ID127])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Greater use of ICT ([ID128])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Greater automation of the reporting process ([ID129])
3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved: : Other ([ID99])
Please specify what other elements could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved:([ID58])
Please elaborate, in particular explaining how you believe the answer(s) you selected for question 3.1 could be achieved in practice:([ID58])
3.2 To what extent would the development of a common financial language help reduce the compliance cost of supervisory reporting?([ID15])
Please elaborate on your answer to question 3.2:([ID58])
3.3 To what extent would the development of a common financial language help improve the management (i.e. reporting or processing) of supervisory data required to be reported?([ID15])
Please elaborate on your answer to question 3.3:([ID58])
3.4 Are there any prerequisites for the development of a common financial language?([ID15])
If you answered yes to question 3.4, please elaborate and provide specific examples:([ID58])
3.5 Are there any obstacles to the development of a common financial language in the short term (i.e. 2 years or less)?([ID15])
If you answered yes to question 3.5, please elaborate and provide specific examples:([ID58])
3.6 To what extent would ensuring interoperability between reporting frameworks and/or receiving entities help reduce the compliance cost of supervisory reporting?([ID15])
Please elaborate on your answer to question 3.6:([ID58])
3.7 To what extent would ensuring interoperability between reporting frameworks and/or receiving entities help improve the management (i.e. reporting or processing) of supervisory data required to be reported?([ID15])
Please elaborate on your answer to question 3.7:([ID58])
3.8 Are there any prerequisites for introducing greater interoperability between reporting frameworks and/or receiving entities?([ID15])
If you answered yes to question 3.8, please elaborate and provide specific examples:([ID58])
3.9 Are there any obstacles to introducing greater interoperability between reporting frameworks and/or receiving entities in the short term (i.e. 2 years or less)?([ID15])
If you answered yes to question 3.9, please elaborate and provide specific examples:([ID58])
3.10 To what extent would greater use of ICT help reduce the compliance cost of supervisory reporting?([ID15])
Please elaborate on your answer to question 3.10:([ID58])
3.11 To what extent would greater use of ICT help improve the management (i.e. reporting or processing) of supervisory data required to be reported?([ID15])
Please elaborate on your answer to question 3.11:([ID58])
3.12 Are there any prerequisites for the greater use of ICT in supervisory reporting?([ID15])
If you answered yes to question 3.12, please elaborate and provide specific examples:([ID58])
3.13 Are there any obstacles to the greater use of ICT in supervisory reporting in the short term (i.e. 2 years or less)?([ID15])
If you answered yes to question 3.13, please elaborate and provide specific examples:([ID58])
3.14 To what extent would greater automation of the reporting process help reduce the compliance cost supervisory reporting?([ID15])
Please elaborate on your answer to question 3.14:([ID58])
3.15 To what extent would greater automation of the reporting process help improve the management (i.e. reporting and/or processing) of supervisory data required to be reported?([ID15])
Please elaborate on your answer to question 3.11:([ID58])
3.16 Are there any prerequisites for a greater automation of supervisory reporting?([ID15])
If you answered yes to question 3.16, please elaborate and provide specific examples:([ID58])
3.17 Are there any obstacles to a greater automation of supervisory reporting in the short term (i.e. 2 years or less)?([ID15])
If you answered yes to question 3.17, please elaborate and provide specific examples:([ID58])
3.18 What role can EU regulators play in facilitating or stimulating greater use of ICT in supervisory reporting?([ID15])
Please elaborate on your answer to question 3.18 and provide specific examples of where and how you believe EU regulators could help:([ID58])
3.19 What role can EU regulators play in facilitating or stimulating greater automation of the reporting process?([ID15])
Please elaborate on your answer to question 3.19 and provide specific examples of where and how you believe EU regulators could help:([ID58])
3.20 What else could be done to simplify supervisory reporting while ensuring that regulated entities continue to fulfil their supervisory reporting requirements?([ID58])
3.21 Can you provide any practical example of improvements to data management processes that could be applied to supervisory reporting with a view to reducing the compliance cost and/or improving the management of supervisory reporting?([ID15])
If you answered yes to question 3.21, please specify and explain your suggestions:([ID58])
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:(file-upload)
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a private individual
an organisation or a company
a public authority or an international organisation
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Academic institution
Company, SME, micro-enterprise, sole trader
Consultancy, law firm
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Industry association
Media
Non-governmental organisation
Think tank
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Other
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International or European organisation
Regional or local authority
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Other public authority
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Austria
Belgium
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France
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Italy
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Norway
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Spain
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Accounting
Auditing
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Insurance
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Investment management (e.g. ucits, hedge funds, private equity funds, venture capital funds, money market funds)
Market infrastructure / operators (e.g. CCPs, CSDs, Stock exchanges)
Non-Financial / Corporate enterprise
Law firm / Consultancy
Trade Association
Other
Not applicable
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Very significantly
Significantly
Moderately
Marginally
Not at all
Don’t know / not applicable
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Very significantly
Significantly
Moderately
Marginally
Not at all
Don’t know / not applicable
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Very significantly
Significantly
Moderately
Marginally
Not at all
Don’t know / not applicable
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Yes, they are all relevant
Most of them are relevant
Some of them are relevant
Very few are relevant
Don’t know / not applicable
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Yes
No
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Fully coherent
Mostly coherent (a few or minor inconsistencies)
Somewhat coherent (numerous inconsistencies)
Not coherent (mostly or totally inconsistent)
Don’t know / not applicable
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Very efficient
Quite efficient
Rather inefficient
Very inefficient
Don’t know / not applicable
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Very well
Fairly well
Not very well
Not at all
Don’t know / not applicable
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Very significantly
Significantly
Moderately
Marginally
Not at all
It has made supervisory reporting more complicated
Don’t know / not applicable
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Very significantly
Significantly
Moderately
Marginally
Not at all
Don’t know / not applicable
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Yes
No
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Yes, both environmental and social
Yes, environmental only
Yes, social only
No
Don’t know / not applicable
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Yes
No, it is at an appropriate level
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
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0 (not contributed at all)
1.
2.
3.
4 (contributed greatly)
Don’t know / not applicable.
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0 (not at all a source of costs)
1.
2.
3.
4 (very significant source of costs)
Don’t know / not applicable.
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0 (not at all a source of costs)
1.
2.
3.
4 (very significant source of costs)
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0 (not at all a source of costs)
1.
2.
3.
4 (very significant source of costs)
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0 (not at all a source of costs)
1.
2.
3.
4 (very significant source of costs)
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Increases the compliance cost
Decreases the compliance cost
Does not impact the compliance cost
Don’t know / not applicable
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate as a percentage of total assets
I am able to provide an estimate as a percentage of turnover
I am able to provide an estimate as a percentage of another basis
Not possible to estimate
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate
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I am able to provide an estimate
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I am able to provide an estimate
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I am able to provide an estimate
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Fully in-house
Partially outsourced
Fully outsourced
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate
Not possible to estimate
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I am able to provide an estimate
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I am able to provide an estimate
Not possible to estimate
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Yes
No
Don’t know / not applicable
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Short term(2 years or less)
Long term(more than 2 years)
Don’t know / not applicable.
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Are you replying as:
First name and last name:
Name of your organisation:
Name of the public authority:
Is your organisation included in the Transparency Register?
(If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)
If so, please indicate your Register ID number:
Type of organisation:
Please specify the type of organisation:
Type of public authority
Please specify the type of public authority:
Where are you based and/or where do you carry out your activity?
Please specify your country:
Field of activity or sector (if applicable):
Please specify your activity field(s) or sector(s):
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
(see specific privacy statement PDF)

a) financial stability (i.e. monitoring systemic risk)

Please elaborate and provide examples to justify your answer to question 1.1.a):

b) market integrity (i.e. surveillance of market abuse and orderly functioning of the markets)

Please elaborate and provide examples to justify your answer to question 1.1.b):

c) investor protection (i.e. ensuring proper conduct by firms to ensure that investors are not disadvantaged/negatively impacted)

Please elaborate and provide examples to justify your answer to question 1.1.c):

1.2 Are all of the existing supervisory reporting requirements relevant for maintaining financial stability and upholding market integrity and investor protection?

If you do not think that all of the requirements are relevant, please provide specific examples of any requirements which in your view are superfluous and explain why you believe they are not necessary:

1.3 Is there information that should be reported but which currently is not (i.e. there are reporting requirements that should be added)?

If you answered yes to question 1.3, please provide specific examples of reporting requirements which in your view should be added and explain why you believe they are needed:

1.4 To what extent are supervisory reporting requirements across different EU level reporting frameworks coherent (e.g. in terms of scope, content, methodology, timing/frequency of submission, etc.)?

Please provide specific examples of reporting requirements which in your view are inconsistent and explain why you believe they are inconsistent:

1.5 To what extent is supervisory reporting in its current form efficient?

If you think that supervisory reporting is not fully efficient, please provide specific examples and explain why you believe it is not efficient:

1.6 How well are the supervisory reporting requirements adapted to developments in the fields of modern information and communication technologies (ICT) and digital processes?

Please elaborate and provide examples to justify your answer to question 1.6:

1.7 To what extent has the adoption of supervisory reporting requirements at EU level facilitated supervisory reporting in areas where previously only national requirements existed?

Please elaborate and provide examples to justify your answer to question 1.7:

1.8 To what extent have options left to Member States in terms of implementing EU level supervisory reporting requirements (e.g. due to their adoption as Directives rather than Regulations) increased the compliance cost?

If you think divergent Member State implementation has increased the compliance cost, please provide specific examples of reporting frameworks or requirements where you believe this to be the case and explain your suggestions:

1.9 Are there any challenges in terms of processing the data, either prior to (i.e. within the reporting entity) or subsequent to (i.e. within the receiving/processing entity) it being reported?

If you answered yes to question 1.9, please elaborate and provide specific examples:

1.10 Are there any negative environmental and/or social impacts related to supervisory reporting stemming from EU legislation?

If you answered yes to question 1.10, please elaborate and provide specific examples:

2.1 Is supervisory reporting in its current form unnecessarily costly for its intended purposes (i.e. ensuring financial stability, market integrity, and investor protection)?

2.2 To what extent have the following factors contributed to the excessive cost of supervisory reporting?

Too many requirements
Need to report under several different reporting frameworks
Need to report to too many different entities
Lack of interoperability between reporting frameworks and/or between receiving/processing entities or supervisory authorities
Need to report too frequently
Overlapping requirements
Redundant requirements
Inconsistent requirements
Unclear/vague requirements
Insufficient use of (international) standards
Need to introduce/update IT systems
Need for additional human resources
Too many/too frequent amendments in the relevant legislation
Lack of a common financial language
Insufficient use of ICT Note: use of ICT is understood as presenting data in an electronic format rather than on paper and/or submitting it using electronic means (e.g. by email, via an online template) rather than by post or in person.
Insufficient level of automation of the reporting process Note: automation is understood as reducing or even fully eliminating human intervention from the supervisory reporting process.
Lack of (adequate) technical guidance/specifications

Please specify what other factors, if any, contributed to the excessive cost of supervisory reporting:

Factors Rate from 0 to 4
Factor 1
Factor 2
Factor 3
Factor 4
Factor 5

2.3 To what extent have the following types of legislative/regulatory requirements been a source of excessive compliance costs in terms of supervisory reporting?

Supervisory reporting requirements imposed by EU Regulations and/or Directives
Different Member State implementation of EU financial legislation, resulting in diverse national supervisory reporting requirements for the same financial entity/product
National supervisory reporting requirements in addition to those in EU legislation for a specific financial entity/product
Other supervisory reporting requirements in addition to those in EU legislation for a specific financial entity/product

Please specify what other supervisory reporting requirements in addition to those in EU legislation for a specific financial entity/product have been a source of excessive compliance costs:

Please elaborate and provide examples to justify your answers to question 2.3:

2.4 Does the obligation to use structured reporting1 and/or predetermined data and file formats2 for supervisory reporting increase or decrease the compliance cost of supervisory reporting?

1 (i.e. templates or forms in which specific data elements to be reported are listed).

2 (i.e. (i) the exact way in which the individual data elements are to be encoded or (ii) the file format in which the information to be reported is exchanged/submitted).

Please provide specific examples to substantiate your answer to question 2.4:

2.5 Please specify the supervisory reporting frameworks to which you are subject (or, in the case of entities receiving and/or processing the data or supervisory authorities, which you deal with or make use of):

a i) please estimate its average initial implementation cost (i.e. one-off cost) in euro for your supervisory reporting frameworks:

Average initial implementation cost in euro:

Please explain why you cannot estimate the average initial implementation cost:

a ii) please estimate the average initial implementation cost (i.e. one-off cost) as a percentage of total assets/turnover/other:

Average initial implementation cost as a percentage of total assets:

Average initial implementation cost as a percentage of turnover:

Please specify on which other basis you are able to estimate the proportion of the average initial implementation:

Average initial implementation cost as a percentage of the above-mentioned basis:

Please elaborate on why you cannot estimate the average initial implementation cost as a percentage of total assets/turnover/other:

b i) please estimate annual running cost in 2016 in euro:

c ii) please estimate the average annual running cost over the last 5 years (i.e. recurrent cost) as a percentage of operating cost:

Annual running cost in 2016 in euro:

Please elaborate on why you cannot estimate the annual running cost in 2016:

b ii) please estimate the annual running cost in 2016 (i.e. recurrent cost) as a percentage of operating cost:

Annual running cost in 2016 as a percentage of operating cost:

Please elaborate, as applicable, on the annual running cost in 2016 as a percentage of operating cost:

Please elaborate on why you cannot estimate the annual running cost in 2016 as a percentage of operating cost:

c i) please estimate average annual running cost over the last 5 years in euro:

Average annual running cost over the last 5 years in euro:

Please elaborate on why you cannot estimate the average annual running cost over the last 5 years in euro:

Average annual running cost over the last 5 years as a percentage of operating cost:

Please elaborate, as applicable, on the average annual running cost over the last 5 years as a percentage of operating cost:

Please elaborate on why you cannot estimate the average annual running cost over the last 5 years as a percentage of operating cost:

d i) please estimate average annual running cost over the last 10 years in euro:

Average annual running cost over the last 10 years in euro:

Please elaborate on why you cannot estimate the average annual running cost over the last 10 years in euro:

d ii) please estimate the average annual running cost over the last 10 years (i.e. recurrent cost) as a percentage of operating cost:

Average annual running cost over the last 10 years as a percentage of operating cost:

Please elaborate, as applicable, on the average annual running cost over the last 10 years as a percentage of operating cost:

Please elaborate on why you cannot estimate the average annual running cost over the last 10 years as a percentage of operating cost:

2.5.2 Please indicate whether the above figures concern your entity as a whole or only a part thereof (i.e. a department, a subsidiary, a branch, a regional division, etc.).:

2.6 Which reporting frameworks contribute the most to the cost of compliance with supervisory reporting requirements? Please indicate as many frameworks as necessary and explain your answer.

2.7 Does your entity deal with supervisory reporting directly in-house or has this task been outsourced to an external provider?

Please elaborate on your answer to question 2.7 and, if possible, explain the reasons for your business choice:

2.8.1 a) at the end of 2016:

Number of full-time equivalents:

Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting in full-time equivalents (FTE) for 2016:

2.8.1 b) in 2009:

Number of full-time equivalents:

Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting in full-time equivalents (FTE) for 2009:

2.8.2 a) at the end of 2016:

Percentage of the compliance work force:

Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the compliance work force for 2016:

2.8.2 b) in 2009:

Percentage of the compliance work force:

Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the compliance work force for 2009:

2.8.3 a) at the end of 2016:

Percentage of the total work force:

Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the total work force for 2016:

2.8.3 b) in 2009:

Percentage of the total work force:

Please elaborate on why you cannot estimate the size of your entity’s department dealing with supervisory reporting as a percentage of the total work force for 2009:

2.8.4 Please indicate whether the figures you provided in your answers to questions 2.8.1, 2.8.2 and 2.8.3 concern your entity as a whole or only a part thereof (i.e. a department, a subsidiary, a branch, a regional division, etc.):

2.9 Have any of the EU level reporting frameworks brought (or partially brought) cost-saving benefits (e.g. simplified regulatory reporting, facilitated internal data management processes, improved risk management, increased operational efficiencies, etc.)?

If you answered yes to question 2.9, please indicate which frameworks, explain in what way they have contributed to cost-savings, and if possible quantify the savings (with respect to previous or other similar reporting frameworks):

3.1 Please indicate which of the following could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved:

Reduction of the number of data elements
Clarification of the content of the data elements
Greater alignment of reporting requirements
Greater standardisation/use of international standards
Development of a common financial language
Ensuring interoperability between reporting frameworks and/or receiving/processing entities or supervisory authorities
Greater use of ICT
Greater automation of the reporting process
Other

Please specify what other elements could reduce the compliance cost while maintaining a sufficient level of supervisory reporting to ensure that the intended objectives are achieved:

Please elaborate, in particular explaining how you believe the answer(s) you selected for question 3.1 could be achieved in practice:

3.2 To what extent would the development of a common financial language help reduce the compliance cost of supervisory reporting?

Please elaborate on your answer to question 3.2:

3.3 To what extent would the development of a common financial language help improve the management (i.e. reporting or processing) of supervisory data required to be reported?

Please elaborate on your answer to question 3.3:

3.4 Are there any prerequisites for the development of a common financial language?

If you answered yes to question 3.4, please elaborate and provide specific examples:

3.5 Are there any obstacles to the development of a common financial language in the short term (i.e. 2 years or less)?

If you answered yes to question 3.5, please elaborate and provide specific examples:

3.6 To what extent would ensuring interoperability between reporting frameworks and/or receiving entities help reduce the compliance cost of supervisory reporting?

Please elaborate on your answer to question 3.6:

3.7 To what extent would ensuring interoperability between reporting frameworks and/or receiving entities help improve the management (i.e. reporting or processing) of supervisory data required to be reported?

Please elaborate on your answer to question 3.7:

3.8 Are there any prerequisites for introducing greater interoperability between reporting frameworks and/or receiving entities?

If you answered yes to question 3.8, please elaborate and provide specific examples:

3.9 Are there any obstacles to introducing greater interoperability between reporting frameworks and/or receiving entities in the short term (i.e. 2 years or less)?

If you answered yes to question 3.9, please elaborate and provide specific examples:

3.10 To what extent would greater use of ICT help reduce the compliance cost of supervisory reporting?

Please elaborate on your answer to question 3.10:

3.11 To what extent would greater use of ICT help improve the management (i.e. reporting or processing) of supervisory data required to be reported?

Please elaborate on your answer to question 3.11:

3.12 Are there any prerequisites for the greater use of ICT in supervisory reporting?

If you answered yes to question 3.12, please elaborate and provide specific examples:

3.13 Are there any obstacles to the greater use of ICT in supervisory reporting in the short term (i.e. 2 years or less)?

If you answered yes to question 3.13, please elaborate and provide specific examples:

3.14 To what extent would greater automation of the reporting process help reduce the compliance cost supervisory reporting?

Please elaborate on your answer to question 3.14:

3.15 To what extent would greater automation of the reporting process help improve the management (i.e. reporting and/or processing) of supervisory data required to be reported?

Please elaborate on your answer to question 3.11:

3.16 Are there any prerequisites for a greater automation of supervisory reporting?

If you answered yes to question 3.16, please elaborate and provide specific examples:

3.17 Are there any obstacles to a greater automation of supervisory reporting in the short term (i.e. 2 years or less)?

If you answered yes to question 3.17, please elaborate and provide specific examples:

3.18 What role can EU regulators play in facilitating or stimulating greater use of ICT in supervisory reporting?

Please elaborate on your answer to question 3.18 and provide specific examples of where and how you believe EU regulators could help:

3.19 What role can EU regulators play in facilitating or stimulating greater automation of the reporting process?

Please elaborate on your answer to question 3.19 and provide specific examples of where and how you believe EU regulators could help:

3.20 What else could be done to simplify supervisory reporting while ensuring that regulated entities continue to fulfil their supervisory reporting requirements?

3.21 Can you provide any practical example of improvements to data management processes that could be applied to supervisory reporting with a view to reducing the compliance cost and/or improving the management of supervisory reporting?

If you answered yes to question 3.21, please specify and explain your suggestions:

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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