The EACB welcomes the opportunity to comment on the EBA Draft ITS amending Commission Implementing Regulation (EU) 2024/3117 regarding Credit Risk and IFRS 9 Benchmarking reporting.
In our response, we point out that the draft ITS would require IFRS 9 benchmarking data to be gathered annually instead of every four years, implying a fourfold increase in the data points delivered. This could contradict the simplification objective. In addition, IFRS 9 models have reached a significant degree of maturity, so the supervisory value of substantially more frequent data collection is likely to be limited.
We therefore suggest that the EBA carefully evaluate the benefit of requesting any additional information against the burden for banks.