Study on the Adequacy of the Information to be Disclosed under Article 89(1) of the Capital Requirements Directive IV. Final Report

Member States have (almost) literally transposed Article 89(1) CRD IV in the national legislation. Nevertheless, there are significant differences in the practical implementation. Many credit institutions are not reporting at all, or are not reporting the information for each of the jurisdictions separately. Activities of branches are not always covered. Similarly, the credit institutions use different definitions for turnover, number of employees, tax on profit or loss and public subsidies. The total administrative costs are insignificant, estimated at about EUR 2 million per annum in total for the more than 4,000 credit institutions in the EU, meaning that these costs are on average EUR 450 per credit institution every year.

The incremental costs are estimated to be only about a quarter or EUR 0.5 million, due to other requirements and practices, including segment reporting and reporting to tax authorities under DAC (Council Directive 2016/881 amending Directive 2011/16/EU, which is the EU implementation of OECD BEPS Action 13). CBCR is further still relevant as trust in the financial sector has still not fully recovered to the levels before the 2007-09 global financial crisis.