Using standards to reduce the filing burden_____________Eric JARRY – Banque de France

eric.jarry@banque-france.fr

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Preparing for CRD IV ReportingLondon 2013-06-17

……

JurisdictionsReporters NSAs ESAs

Europe

Joint Committee

CSDBCentral

SecuritiesDataBase

CEBS

CESR

CEIOPS

European System of Financial Reporting

XBRL

XBRLXBRL

XBRL

XBRL

XBRL

XBRL, a standard?

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• XBRL is developed by a not-for-profit association: XBRL International (http://www.xbrl.org).

• XBRL International is linked to a network of national "jurisdictions" in most industrial countries (in Europe: UK, Germany, Belgium, Denmark, Finland, France, Italy, Luxembourg, Netherlands, Norway, Spain, Sweden, Norway…).

• Institutions like National Bank of Belgium, Banque de France, Banco d’España, … are members of the XBRL associations.

• XBRL Europe handles common topics: European Business Register, IFRS and securities taxonomies and COREP, FINREP and Solvency II.

• XBRL International does not publish standards, like ISO, but recommendations.

XBRL in ACP / Banque de France

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• Before 2007: the French banking regulator, Commission bancaire, bound to Banque de France, uses a proprietary format for the French banking reporting since 1993, BAFI

• 2005-2006: CEBS (now EBA) chooses XBRL for the Basel II / CRD and Financial reporting: COREP and FINREP taxonomies

• 2006: Banque de France decides that XBRL will be the only format accepted for COREP and FINREP data, a new application is developed: COFINREP. Reception of XBRL reports in 2007

• 2008: New French regulations, complete change of the reporting system : SURFI (Unified FInancial Reporting System), all banking reporting for prudential and statistical needs of Banque de France, will be done in XBRL, the SURFI taxonomy and SURFI application are developed

• 2010: The French authorities for Banking and Insurance supervision are merged, giving ACP (Prudential Supervisory Authority), bound to Banque de France

• EBA uses another implementation of the SURFI sytem, IPEBA – IT Platform for EBA. EBA accepts XBRL, XML and CSV reports for KRI (Key Risk Indicators) data

• 2011: Decision of EIOPA to use XBRL for the reporting, from undertakings to NSAs and from NSAs to EIOPA

• 2012-2013: SURFI application adapted to support Solvency II and new EBA taxonomies

• 2014: First filings of COREP, COREP_LE and FINREP data• 2014: First filings of Solvency II data (in XBRL, voluntary reporting,

specific to France)

XBRL in ACP / Banque de France

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

SMTP

HTTP

Transferprotocols

Web dataentry

Taxonomies

XBRLvalidatio

n(not

formula)

Filetransfer

Webforms

Formshandling

Signature

Encryption

AuthenticationAuthorization

Certificats mgt

Security

TimestampingConversions

(IPEBA)

OneGate

Other flows

Messages

Excel

XBRL

XMLCSV

SURFI

XBRLvalidatio

n(with

formula)

Due timemanagement

Outputprocessing

Registry

RegistryApplication

Taxonomies

Reportingdatabase(XBRL)

Viewsgeneration

Excel

XBRL

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

A S S U R A N C E S

Excel

Messages

Instances and errors processing

XML

Excel

PDF

Common portal of Banque de France(from National Bank of Belgium)

XBRL

XML

CSV

EDI

Formsgeneration

SASApplicationXBRL

XML

KRI instances (to EBA)

XBRL

XBRL

The SURFI system

Otherapplications

• XBRL is more and more used in the world, specially for regulatory and supervisory reporting:– Reporting to US SEC– HMRC filings– Business register reporting– IFRS (XBRL representation)– COREP and FINREP reporting– Solvency II reporting– GRI (sustainability reporting)– …

• XBRL may be considered as a de-facto standard 7

XBRL, a de-facto standard

• XBRL has been developped for business reporting• XBRL offers a lot of features over plain XML reporting:

– Extensibility (XLink overriding)

– Evolutivity with ongoing compatibility (flat XML)

– Labels expressed in several language (Label linkbase)

– References to regulatory documents (Reference linkbase)

– Support of dimensions, rejecting invalid combinations (Dimensions)

– Assertions for business checks and type validation (XBRL formula)

– Rendering of data in a tabular form (Table linkbase)

– Support of XBRL data in HTML documents (Inline XBRL)

– Definition of characteristics with Data Point Modelling

– … 8

XBRL, features

• A lot of software providers support XBRL in the world• Major supervisory agencies are involved in the XBRL

community• Eurofiling (http://www.eurofiling.info) is a forum where it is

possible to discuss and share experience• The COREP, FINREP and Solvency II XBRL Europe group may

also be used• National XBRL jurisdiction may help filers through

presentation, training, demonstration of tools, commercial information

• Regulators organize technical meetings with IT staff of filers / software providers 9

XBRL, community

• New reporting (e.g. COREP / FINREP or Solvency II)=> new IT system (or important refactoring)

=> budget may be used to modernize the system and use the format dedicated to financial reporting: XBRL

• Software providers may provide common solutions across Europe

• Using XBRL may simplify the life of cross-border (multi-country) or cross-sector (banking and insurance) institutions

• XBRL taxonomies are used to describe the reporting (dictionary) and for level 2 reporting (NSAs to ESA – EBA or EIOPA)– not using XBRL would lead to conversion costs for every version of the

reporting10

XBRL, mandatory?

• No major difficulties encountered (“XBRL has not been the major problem for COREP – FINREP reporting”)– All taxonomies used in France: SURFI, COREP and FINREP include

assertions (XBRL formula) since 2010

– Some software providers use available XBRL processing engines

– A software provider has developed its own XBRL processing engine, including formula processing

– Some software providers developed ad hoc solutions (not generic) to validate XBRL and assertions

– Few institutions developed ad hoc converters to XBRL=> few errors are still strange (meaning that instances are not validated at reporting side)

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XBRL, difficulties?

• Data modelling and semantic definition at business / regulatory level

• (More) commonalities between taxonomies• Displayable taxonomies / templates with direct links to regulations

(in XML)• Defining the reporting format is not enough for a common

solution, differences still exist for:– Communication protocols

– Security options (e.g.: digital signature and relevant options)

– Format and contents of the errors notifications (XBRL and other errors, like “Deadline not met”)

• The CEN XBRL Workshop aims at defining good practices in Europe(http://cen.eurofiling.info)

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XBRL, enough?

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Thank you.

Questions ?eric.jarry@banque-france.fr