11.6.2025 - Summary of minutes

Meeting of the small working group on IReF

Time:                                               11 June 2025 at 10:00 am

Place:                                              Microsoft Teams / Bank of Finland

Present:                                         Officials of the Bank of Finland (BoF) and Financial Supervisory Authority (FIN-FSA). Industry representatives from OP Financial Group, Aktia, Savings Banks' Union Coop, Nordea and S-Bank.

1 Schedule and progress of preparations for the Regulation

·         Working groups in the ECB's various statistical domains are currently commenting on the Regulation. The working groups will complete their process by early July.

·         The ECB's Statistics Committee (STC) will likely discuss the draft IReF Regulation after the Central European holiday season in September

·         The ECB Governing Council will discuss the IReF in its September meeting and decide on progressing to the implementation phase

2 Highlights from the draft Regulation

·         Test reporting will not be mandatory

·         Counterparty data

o   Use of the RIAD code has become mandatory for counterparties that must be identifiable with complete information

o   Mandatory counterparty data validations would occur at the latest by the deadline for other reporting

o   Validation of counterparty data is planned to be relaxed at least for counterparties with combined exposures below EUR 25,000

o   Counterparties without a national identifier are considered challenging to identify and are therefore subject to reduced reporting requirements. Detailed specifications have not yet been released

o   On the securities side, no derogations are planned for counterparty data reporting

·         Parallel reporting

o   Will begin on or around 15 January 2030, aligned with current RATI schedule for monthly data (t+10 from reference date). The first deadline for quarterly data aligns with the FinRep schedule, i.e., 11 February 2030 (t+42 calendar days). Additionally, there is a separate submission with monthly frequency, including, for example, risk data

o   Migration from current reporting to IReF is a complex process, to be governed by a separate regulation

§  Cessation of parallel reporting for RATI will be reviewed at national level using multiple quality indicators based on BSI and MIR statistics. When a sufficient number of these indicators have been met for six months, RATI reporting can be discontinued

§  LuoTi reporting will cease six months after the start of parallel reporting

·         Reporting derogations largely mirror current RATI arrangements, i.e. those with a derogation will report quarterly instead of monthly

·         Household loans

o   The national central bank may choose to request reporting loan-by-loan in 2033 and aggregated data in 2030, or on a loan-by-loan basis from 2030

o   Many industry representatives in the small working group preferred starting with aggregated data collection in 2030. The BoF had assumed the industry would prefer a direct migration to loan-by-loan data collection to avoid two separate development phases. The BoF will consider the industry's preference in its decision

·         Non-profit organisations are treated in the draft Regulation similarly to the household sector, i.e., by allowing aggregated reporting

·         The draft Regulation permits reporters to change loan identifiers

·         Minimum reserve calculations will be generated directly within the IReF system, maintaining the current approach in Finland