5 March 2025 - Summary of minutes

Place: Microsoft Teams

Present:   Officials of the Bank of Finland (BoF) and Financial Supervisory Authority (FIN-FSA). Industry representatives from OP Financial Group, Aktia, Savings Banks' Union Coop, Nordea and S-Bank.

1 ECB's recent IReF policy lines

• Pilot reporting and parallel reporting
  • Pilot reporting will be mandatory, starting in December 2028
  • Parallel reporting will begin in December 2029
    • LuoTi reporting (credit data) will end at any rate 6 months thereafter
    • RATI reporting (MFI data) will end at the earliest 8 months thereafter
  • As a preparatory effort, both the ECB and BoF have already been developing various cross-checks for time series of current statistics
• Reporting derogations
  • As a reporting derogation, there is a quarterly reporting frequency instead of the monthly one, similar to RATI
  • Voluntary full reporting will remain an option
  • The availability of the reporting derogation reflects loan volumes, similar to BSI, and, on the SHSS side, securities holdings
  • In the future, holdings managed by banks functioning as securities custodians must be reported in IReF reporting, whereas other custodians will be covered by separate reporting
• Reporting format
  • The reporting format to be used is XBRL-CSV
• Data collection service
  • Data collection will be implemented in the ETS service on the ECB's upcoming CDM platform
• Threshold values
  • A borrower-specific threshold of EUR 25,000 will apply
    • Identification of counterparties falling below the threshold will not necessarily be required
  • Counterparty data
    • Reporting of the RIAD code will be required in addition to a national identifier and/or LEI code
  • National requirements
    • Migration to loan-by-loan reporting will reduce the BoF's need for national requirements
    • However, at a minimum, there will be a national requirement to report Statistics Finland's national sector classification
    • Data diverging from IReF's core part will be collected in national additional tables