The Pillar 3 Data Hub is coming: set the course now for a smooth transition.

On February 12, 2025, the European Banking Authority (EBA) published a new Implementing Technical Standard (ITS) for banks' disclosure obligations. The most important changes concern the central collection and publication of disclosure data in the so-called "Pillar 3 Data Hub" (P3DH). This innovation is intended to improve the transparency, comparability and accessibility of data.

With the adoption of Regulation (EU) 2024/1623 (CRR 3) and Directive (EU) 2024/1619 (CRD VI), new requirements for disclosure obligations were defined. In future, banks will have to submit their Pillar 3 data directly to the EBA, which will then publish it centrally. The previous individual publications on the banks' websites will be replaced by a central platform.

From June 30, 2025, all large and complex banks will send their disclosure data to the EBA, which will publish it in the P3DH. A separate process will be developed for small and non-complex institutions (SNCIs). This will be specified via a separate ITS and introduced downstream (probably from 31.12.2025).

The most important advantages:

• Uniform access to regulatory data for all stakeholders.
• Increased comparability of banks within the EU.
• Reduction of administrative effort through standardized processes.

Technical implementation and requirements:

The disclosure data is submitted via the EBA's EUCLID system. Banks must submit their quantitative data in XBRL csv format and qualitative information as machine-readable PDF files. They must also name contact persons for data exchange. As a rule, half-yearly disclosure is planned for the reporting dates 30.06. and 31.12.

Certain information, e.g. on the remuneration policy, can be submitted up to two months after the main publication.

Transition phase and first submissions:

• Large and complex banks must transfer their first disclosure reports to the new system by June 2025.
• During the transition period, banks must publish their disclosures both on their websites and in the P3DH.
• Disclosure will be made exclusively via the P3DH from March 2026 at the latest.

Challenges and recommendations

• 1. IT integration: Banks should ensure at an early stage that their systems are compatible with the EBA requirements.
• 2. process adjustments: The new deadlines require early data preparation. In addition, the internal control and compliance processes must be adapted to the new disclosure obligations.
• 3. training: Employees should be trained in the use of the new submission system.

Conclusion

For banks, these new EBA requirements mean a comprehensive adjustment of internal disclosure procedures. Early preparation and strategic implementation are crucial to minimize regulatory risks and ensure a smooth transition. CURENTIS AG supports you in adapting your disclosure processes to the new technical and regulatory standards at an early stage. Take the opportunity to optimize your IT infrastructure and minimize compliance risks.