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IFR&IFD: Catching up with the EBA timeline

In June of the previous year, the EBA published a roadmap showing the “way to go” in implementing the new regime for investment firms, referred to as the IFR&IFD. Now, approximately two months before the “go-live” date, we take a look at what is coming in the next months. The Investment Firms Regulation becomes applicable on June 26th, 2021 and EU Member States are required to publish measures necessary to comply with the Investment Firms Directive by the same date.

In June 2020, the EBA specified that it would roll out the new investment firms’ regime in the following phases:

What has happened, what’s coming in the new regime for investment firms?

What does this mean for reporting requirements under the new regime?

The final draft ITS

The final draft ITS on new supervisory reporting and disclosures framework set out the main aspects of the reporting framework regarding the calculation of own funds, level of minimum capital, concentration risk, liquidity requirements and the level of activity regarding small and non-interconnected investment firms, as well as a set of templates for the disclosure of own funds.

Read more here: https://www.eba.europa.eu/eba-issues-new-supervisory-reporting-and-disclosures-framework-investment-firms

The public consultation on RTS on disclosure of investment policy by investment firms

The draft RTS presents templates and tables for the disclosure of information on the investment firm’s issues regarding voting: voting behaviour, explanation of votes, and the ratio of approved proposal. The draft RTS concerns class 2 investment firms with total assets over 100 million. According to the EBA, class 2 firms will be obliged to disclose the aforementioned information in relation to those companies whose shares are admitted to trading on a regulated market and in which the proportion of voting rights exceeds 5 % of all voting rights issued by the company. 

The EBA has stated that interested parties can send comments on the consultation by the 1st of July and take part in a public hearing on the 6th of May.

Read more here: https://www.eba.europa.eu/eba-launched-public-consultation-regulatory-technical-standards-disclosure-investment-policy

The first reporting reference dates are:

  1. September 2021 (for quarterly reports) with first submissions filed by November 11, 2021 
  2. December 2021 (for annual reports) with first submissions filed by February 11, 2022

What should be on your checklist?

  • Are your data management and IT systems ready for the new reporting requirements?
  • Is your team aware of the implications of IFR&IFD on data reporting?
  • Do you have a validation tool in place?