EBA proposes Pillar 3 Data Hub for small banks
The European Banking Authority (EBA) has launched a discussion paper on extending its Pillar 3 Data Hub process to Small and Non-Complex Institutions (SNCIs). The paper outlines the calculation methodology and timeline for centralizing their disclosure requirements.
Centralizing SNCI disclosures
The Pillar 3 Data Hub (P3DH) is a centralized platform on the EBA website that provides access to Pillar 3 information.
It went live for large and other institutions on January 26, 2026, making their June 2025 disclosures available.
The EBA is now implementing the extension of this process to SNCIs.
For these institutions, the EBA is mandated to prepare and publish Pillar 3 disclosures based on supervisory reporting data submitted to competent authorities, a process that differs from the self-submission model for larger entities.
This discussion paper focuses on the process for SNCIs, including the calculation methodology for preparing these disclosures.
An ongoing public consultation until July 10, 2026, addresses supervisory data not yet available for Pillar 3 computation, with the calculation methodology currently undergoing testing.
The EBA aims to conduct a final round of consultation with the industry through this paper, building on largely positive feedback received so far.
Reducing burden, enhancing transparency
A centralized calculation and publication process for SNCI Pillar 3 information through the EBA P3DH is intended to significantly reduce operational costs for institutions by eliminating the need for individual disclosure channels.
This single access point is also expected to substantially improve transparency, comparability, and data accessibility for all P3DH users, including institutions and supervisors, thereby supporting market discipline.
The EBA emphasizes that the number of requirements applicable to SNCIs is considerably lower than for large and other institutions, with non-listed SNCIs currently subject to only a single reporting template (EU KM1) under Article 447 CRR, though ESG disclosures will apply from December 2027.
A pilot exercise will be launched with volunteering SNCIs to refine the framework ahead of broader implementation.
The first publication for SNCIs is planned for Q4 2026, covering a reduced set of requirements for listed SNCIs with a December 2025 reference date.
A complete publication of all applicable Pillar 3 requirements for SNCIs is envisaged in 2028, with a December 2027 reference date.
Simplification's inherent complexities
Centralizing Pillar 3 disclosures for SNCIs promises cost savings, yet standardizing diverse reporting across numerous small institutions remains a formidable challenge.
Reliance on supervisory data, some still under consultation, introduces uncertainty regarding the completeness and accuracy of the final published information.
This well-intentioned initiative demands robust validation to prevent merely shifting data reconciliation burdens.