EBA Reporting Framework 4.4: what institutions should expect

Its implementation will follow a phased timeline, with Phase 1 requirements becoming applicable from March 2027 (notably IFRS 18-driven FINREP changes), followed by Phase 2 in September 2027, which introduces the broader set of supervisory reporting enhancements across COREP, FINREP, Liquidity, ESG and stress testing.

Key takeaways

Integration of Basel III reforms into reporting

Framework 4.4 integrates the next phase of Basel III reforms into supervisory reporting, with updates to COREP, FINREP, Liquidity and related modules.

As these reporting templates are directly derived from revised risk calculation methodologies, institutions will need to ensure integration between risk engines and reporting systems, along with improved traceability and consistency across datasets.

Credit risk: granularity, benchmarking and IFRS 9

Credit risk reforms, particularly refinements to standardised approaches and constraints on internal models, are reflected in 4.4 through enhanced COREP and benchmarking reporting. The framework introduces new shadow banking templates to the COREP Large Exposures report along with enhanced credit risk benchmarking to include elements such as IFRS 9 data into supervisory reporting.

Institutions should expect a stronger linkage between IFRS 9 accounting data and prudential reporting, with benchmarking exercises increasingly relying on consistent inputs across both domains. This is likely to drive enhanced reconciliation between expected credit loss (ECL) calculations, staging and prudential risk parameters. As a result, firms will need to strengthen alignment between finance and risk systems, improve data quality controls around IFRS 9 outputs and establish robust governance over adjustments between accounting and regulatory figures.

Market risk: fundamental review of the trading book (FRTB) expansion

Market risk changes reflect the completion of FRTB implementation. The framework includes additional detail on Alternative Standardised Approach (ASA) and Alternative Internal Model Approaches (AIMA).

As a result, institutions will need to capture highly granular trading data, including sensitivities and model outputs. Reporting will rely much more heavily on front-office risk systems, requiring firms to strengthen data aggregation and ensure consistency between trading, risk and reporting platforms.

Operational risk: standardised and data-intensive

Operational risk reforms, most notably the move to a standardised approach, are implemented through new COREP requirements. The framework introduces enhanced reporting of operational losses, transitional arrangements and simplified structures.

Institutions should expect a stronger reliance on internal loss data and business indicators. This will require robust and well-governed operational risk databases, improved data quality controls and alignment with financial reporting data, especially where links to FINREP are required.

FINREP and liquidity: structural changes and simplification

A key feature of Framework 4.4 is the implementation of IFRS 18 in FINREP (phase 1), alongside the integration of stress testing into financial reporting. As part of the EBA’s overall simplification agenda, certain reporting templates will also be streamlined. Liquidity reporting is revised, with updates to ALMM, asset encumbrance, LCR and leverage ratio reporting, reflecting both simplification and lessons learned from recent market developments.

For institutions, this implies significant changes to financial data structures and chart-of-accounts mappings. Firms will need to adapt systems to handle revised accounting definitions, while also improving Liquidity data capabilities and ensuring consistency across multiple Liquidity metrics.

ESG and stress testing: integrated reporting

A major new area within Framework 4.4 is the expansion of ESG supervisory reporting. ESG metrics and related stress testing data will become a key feature in supervisory reporting.

Institutions will need to incorporate non-financial and forward-looking data into reporting processes. This will require new data sources, stronger governance over ESG metrics and the ability to integrate scenario-based data into standard reporting cycles.

How Forvis Mazars can help

Our prudential risk specialists recognise that evolving frameworks such as EBA 4.4 are becoming central to the strategic and operational priorities of financial institutions. We support clients in navigating the growing complexity of regulatory reporting by translating regulatory requirements under CRR, Pillar 3 and supervisory reporting frameworks into practical, implementable solutions.

Our team offers end‑to‑end support across the reporting lifecycle – from interpreting regulatory obligations and designing data and control frameworks, to delivering XBRL-based reporting solutions for efficient preparation, validation and submission of disclosures. By working closely with institutions, we help establish scalable reporting architectures, strengthen data governance and ensure full, sustainable compliance in an increasingly integrated regulatory environment.