Presentation on theme: "Filing rules and extensions of EBA/EIOPA taxonomies"— Presentation transcript:
1Filing rules and extensions of EBA/EIOPA taxonomies CEN/WS XBRL RecapFiling rulesand extensions of EBA/EIOPA taxonomies5 May, 2013Katrin Heinze, Bundesbank (currently working for the ECB)CWA1
2EU principles of transparency and non-discrimination Fundamental principles of the EC LawIncreasing the competitiveness and support the movement of servicesMember states must transpose the EU Directives with precision, clarity and transparency to enable individuals to ascertain their obligationsProviding significant impulses for harmonization in different business areasOne of them: ICT - information and communication technologiesICT provides services for the industrial society which are essential to be competitive against markets in and outside of the EUICT contribute to the overall business successPreconditionICT applications must be interoperable to provide efficient access to information and their distributionIn this sense: The harmonization of the supervisory reporting in Europe by using DPM and XBRL is an important field of activity.
3Technical background for the definition of filing rules XBRL is a framework for the definition of data formatsprovides a high degree of flexibility for the creation of taxonomies and instance documentsflexibility requires complex IT systems to react appropriately on all possible variants that the standard allows,like definition of units, accuracy of values, usage of footnotes, periods, identifiers etc.
4Definition and Advantages Rules to be followed for the preparation and validation of instance documents in a XBRL filing process whichplace additional constraints on XBRL instance documents.AdvantagesProvide harmonization on a technical levelEnhance the interoperability of IT systemsEase the comparison of reporting dataEase the validation of instance documentsGive rules to reporting entities as guidanceDecrease the reporting burden for reporting entitiesEnable automated tests on the rule setXBRL Filing?
5Filing Rules based on Best Practices ApproachYearStatusPublisherCoverageRules onFRIS12004PWD2XII3XBRL onlyXBRL instancesGlobal Filing Manual2010Best PracticesSEC, FSA Japan, IFRSXBRL StandardXBRL instances and taxonomiesEDGAR Filer Manual2013U.S. Securities and Exchange CommissionPart of the CWA1 deliverables of the standardization process of CEN/WS XBRLoriented to reporting entities preparing the filings on basis of EIOPA and EBA taxonomiesRecommendations to be adopted by NCAs and European Supervisory AuthoritiesEFLFRISGFMFinancial Reporting Instance StandardsPublic Working DraftXBRL International Inc.
6Structure of the Deliverable Currently 34 rules and descriptions separated in two chapters12 Filing syntax rulesRules for the complete document to be filed22 Instance syntax rulesSyntax rules for the instance document and its subordinated objectsContextsFactsUnitsFootnotesExample:
7Modeling the European Filing Rules Meta modelObject systemmodelingModel systemObject system comprises the clearly delimited real system and also its relevant environment.The object system is the XBRL instance document and the constraints defined on the preparation of XBRL instance documents. The constraints are based on the objects contained in an instance document and the relations among each other.Meta model provides model components, rules on how to combine components and the meaning (semantic) for the components and relations.UML class diagram to describe the structure of the XBRL instance by showing the classes, their attributes and possible methods.OCL (Object Constraint Language) is a formal language for specifications, which refers to an UML model to describe constraints about the objects in the model.Model system must be consistent and complete. It must reflect the structure of the object system.
10Analysis based on the following publications CEN: European Filing Rules. December 2013 (after approval by the stakeholders)EBA: XBRL Filing Rules COREP and FINREP Taxonomy v2. March https://www.eba.europa.eu/documents/10180/502670/EBA+XBRL+Filing+Rules+for+v2.0.0.pdfFiling Manuals of the NCAs in Denmark, United Kingdom and GermanyDanmarks Nationalbank: Danish XBRL Filing Rules. February 2014https://www.finanstilsynet.dk/~/media/Temaer/2014/Fremtidige- indberetninger/Indberetningsregler_fiona.ashxFCA: COREP/FINREP Reporting Filing Manual. February 2014Bundesbank: Regeln der Bundesbank für das bankaufsichtliche XBRL-Meldewesen. March 2014 (only in German)_filing_rules.pdf?__blob=publicationFile…
12Level of harmonisation CEN <-> EBA CEN rules adopted by EBAMarch 20148 of 32 define a different severityNumber of CEN rules: 34Number of EBA rules: 39CENEBA
13Issues identified CEN <-> EBA First set of rules was reduced from 48 to 35 rulesSome previously rejected rules have been added to the EBA rule setOne rule seems to have a lack of detailsThe indication of the severity is unclearis required = MUSTis recommended = SHOULD; sometimes MAY
14Level of harmonisation EBA <-> NCAs EBA rules adopted by DE, DK, UKMarch 2014EBANCAs
16Problems identified EBA <-> NCAs Harmonisation on technical level is not reachedInternational acting reporting entities have to be prepared for the different validation requirementsSome based on national language-dependent descriptionNCAs might need to amend the file for transmitting it to ECB or EBA (i.e. duplicate facts are not restricted)Software prepared for the validation of the EBA Filing Rules does not cover all rules defined across Europe
17Possible counter-measures Amending the CEN Filing Rules according to the amendments introduced by EBAInterested parties?Define a clear severity for each ruleEase the description of the rule (too technical?)Raise awareness in the Eurofiling communityEurofiling workshop (Done!)Conference callPublication of the analysis results at eurofiling.infoRaise the issue at EBA level
18Thanks for your attention Comments or questions?Page 18CWA118