The Pillar 3 Data Hub: what financial institutions need to know

The transition period for trial reporting ends for all Pillar 3 disclosures with a reference date from March 2026. From that point forward, firms must submit disclosures to the P3DH before publishing them elsewhere — including on their own websites.

This new requirement represents a significant operational shift for many institutions and will require changes to internal reporting, governance and data management processes.

Scope of the Pillar 3 Data Hub

The publicly accessible Data Hub acts as a single access point for Pillar 3 disclosures made by banks. By centralising disclosure information, it strengthens market discipline, improves data accessibility and supports consistent supervisory oversight across the European Economic Area (EEA).

The first phase of the submission process differs depending on the type of institution.

• Large and Other Institutions: As defined under Regulation (EU) No 575/2013 of the Capital Requirements Regulation (CRR), large and other institutions must submit all Pillar 3 disclosure requirements directly to the EBA. These include:
  • Quantitative data submitted in XBRL-CSV format: risk exposure and assessment disclosures, capital adequacy disclosure reports, leverage ratio disclosures, liquidity, credit risk and market risk-related metrics.
  • Qualitative disclosures in PDF format: management discussion, risk governance narratives, strategies and policy explanations required under Pillar 3.
• Small and Non-Complex Institutions (SNCIs): As defined under Regulation (EU) No 575/2013 of the CRR, the supervisory reporting data serves as the basis for SNCIs' Pillar 3 disclosures. The EBA will obtain this data from the appropriate competent authorities through their platform and calculate the Pillar 3 figures available under Article 430 of the CRR. The required disclosure data will then be published by the EBA on its website. A separate Implementing Technical Standard (ITS) for SNCIs is expected to take place at a later stage.
• Voluntary Disclosures: Voluntary Pillar 3 quantitative and qualitative disclosures are accepted and follow the same format requirements as mandatory submissions.

The onboarding process

The onboarding for P3DH follows four main steps:

1. Collection of institution representative details
The National Competent Authority, such as the Central Bank of Ireland for Irish institutions, contacts firms to obtain details of the Chair of the Management Body. These details are passed to the EBA.

2. Letter issued by the EBA
The EBA writes to the Chair with:

• Instructions on how to nominate three operational representatives
• Information on data submission processes, deadlines and templates
• A Data Protection Notice

Institutions must return the completed letter electronically.

3. User account setup
The EBA creates three user accounts on the EUCLID platform for the nominated representatives.

4. Login activation and platform access
Once accounts are created, login invitations are emailed to users.

How Forvis Mazars supports clients

Our prudential risk specialists help institutions navigate the operational, technical and regulatory challenges associated with the P3DH. We support clients with interpreting disclosure rules, assessing readiness, producing and validating XBRL submissions and integrating Pillar 3 requirements with broader CRR reporting frameworks. Our team works closely with clients to determine their specific obligations and establish effective, sustainable compliance strategies.