EBA Reporting Framework 4.4: How Banks Can Prepare in 3 Steps

EBA Reporting Framework 4.4: How Banks Can Prepare in 3 Steps

The European Banking Authority (EBA) published the final package for Phase 1 of Reporting Framework 4.4 this week, bringing a two-phase set of reporting and disclosure changes.

Its phased amendments touch financial, prudential and disclosure reporting, influencing banks to examine whether the data behind their submissions is consistent, controlled and reusable. The EBA had publicly highlighted issues such as excessive reporting complexity, overlapping data requests across frameworks, rising compliance costs, multiple parallel collections and lack of proportionality.

The finalization of Reporting Framework 4.4 is another milestone in the regulator’s journey to creating a simpler, more proportionate supervisory reporting ecosystem that reduces duplication and expands regulatory insight through improved data quality.

The changes in EBA 4.4 could help banks strengthen significantly their data foundation and readiness for future initiatives from European authorities, such as the approaching Integrated Reporting Framework (IReF), as common data assets and reusability become a greater priority.

These enhancements are aligned with the EBA's transition towards DPM 2.1, which promotes improved semantic consistency, increased reuse of data concepts, richer metadata and greater interoperability across regulatory reporting frameworks. They lay the groundwork for a more integrated and data-centric supervisory reporting ecosystem.  

What should banks be doing now to prepare for EBA 4.4?

While the scale of implementation will vary across institutions, EBA Framework 4.4 has implications for all banks subject to EBA reporting requirements. Firms will need to focus on data quality to maintain data consistency, support cross-domain reporting requirements and enable greater data reusability.

Here are three recommended steps for banks to take:

1. Align regulatory change initiatives through a common roadmap

Historically, many firms approached reporting as a downstream activity. But now, the changes introduced by Framework 4.4 increasingly favor a more integrated operating model—notably between Finance, Risk, Regulatory Reporting and Data Governance—as reporting will reuse data from multiple domains.

Banks should establish greater alignment with a common roadmap between these members and their respective priorities:

• CFO: Ensure financial reporting remains consistent while reducing reconciliation effort and implementation costs. 
• CRO: Gain greater confidence that risk data is accurate, traceable and consistently reused across prudential, stress testing and supervisory reporting requirements. 
• Risk committees: Strengthen oversight by receiving more consistent, transparent and reliable regulatory reporting built on governed enterprise data. 
• Regulatory reporting leadership: Help reduce implementation complexity and future-proof reporting operations by establishing a scalable foundation for ongoing regulatory change. 
• Internal audit: Improve assurance over data lineage, controls and reporting processes, helping demonstrate compliance and readiness for regulatory scrutiny.

2. Conduct a cross-framework data and reporting impact assessment

Firms need to identify where EBA 4.4 changes affect source systems, data models, reporting processes and controls.

Particular attention should be paid to DORA-related amendments, Pillar 3 disclosures and the growing reuse of data across FINREP, COREP, ESG reporting, stress testing and resolution planning.

Another key additional consideration is the transition to IFRS 18. While EBA 4.4 introduces IFRS 18-related FINREP reporting from the March 2027 reference date, it doesn’t expressly address whether national competent authorities may permit continued use of IAS 1-based FINREP templates during the transition period. Any divergence in national implementation approaches could introduce additional operational complexity for firms.

The assessment should also map shared data elements, calculations and controls across these obligations, helping firms identify where a change in one framework may create downstream impacts elsewhere. Mapping common data requirements and dependencies across EBA 4.4 submissions can identify opportunities to consolidate fragmented processes and develop governed, reusable data assets, laying stronger foundations for future initiatives such as IReF.

By evaluating these dependencies collectively, rather than requirement by requirement, banks can reduce duplicated implementation work, prioritize remediation and establish reusable data assets.

3. Test data, controls and reporting processes

Once key impacts and dependencies have been identified, banks should begin testing affected data flows, calculation logic, validation rules and reporting controls against the phased EBA 4.4 requirements.

Early testing can help firms identify data quality issues, control gaps and inconsistencies across related submissions, while providing sufficient time to assign remediation owners and address issues before the applicable reporting changes take effect.

Here are key questions to consider:

Integrated Data Controls: Do our data quality controls, validations and regulatory reporting processes integrate effectively to identify issues before submission or do gaps remain across our systems and teams?

Data Quality Governance and Modernization: Do our data quality rules, analytics and exception management processes have the agility and traceability required to support evolving reporting requirements?

Data Reusability: Can our data be reconciled consistently across source systems, reporting frameworks and regulatory exercises to support efficient data reusability across FINREP, COREP, ESG reporting, Pillar 3 disclosures, stress testing and resolution planning? 

IReF Readiness: A More Integrated Operating Model for Greater Data Reusability

As banks prepare efforts for Reporting Framework 4.4, many may view the initiative not merely as another compliance exercise, but as an opportunity to modernize their broader regulatory reporting architecture.

Through the closer alignment of cross-functional stakeholders toward a more integrated operating model, firms can better establish the single regulatory data layer that enables greater data reusability. It’s this reusability that can create a more scalable foundation for future regulatory change. This will become particularly valuable as the European Central Bank (ECB)'s IReF moves closer to implementation.

With IReF expected to place even greater emphasis on granular, reusable data and integrated reporting processes, banks that approach EBA 4.4 as a catalyst for simplifying their data architecture today may be better positioned to proactively respond to new compliance initiatives quicker and reduce future implementation effort. 

_{© [2026] Nasdaq, Inc. The Nasdaq logo and the Nasdaq ‘ribbon’ logo are the registered and unregistered trademarks, or service marks, of Nasdaq, Inc. in the U.S. and other countries. All rights reserved. This communication and the content found by following any link herein are being provided to you by Nasdaq Financial Technology, a business of Nasdaq, Inc. and certain of its subsidiaries (collectively, “Nasdaq”), for informational purposes only. Nothing herein shall constitute a recommendation, solicitation, invitation, inducement, promotion, or offer for the purchase or sale of any investment product, nor shall this material be construed in any way as investment, legal, or tax advice, or as a recommendation, reference, or endorsement by Nasdaq.}  

_{Nasdaq makes no representation or warranty with respect to this communication or such content and expressly disclaims any implied warranty under law. At the time of publication, the information herein was believed to be accurate, however, such information is subject to change without notice. This information is not directed or intended for distribution to, or use by, any citizen or resident of, or otherwise located in, any jurisdiction where such distribution or use would be contrary to any law or regulation or which would subject Nasdaq to any registration or licensing requirements or any other liability within such jurisdiction. By reviewing this material, you acknowledge that neither Nasdaq nor any of its third-party providers shall under any circumstance be liable for any lost profits or lost opportunity, direct, indirect, special, consequential, incidental, or punitive damages whatsoever, even if Nasdaq or its third-party providers have been advised of the possibility of such damages.}

_{Information set forth in this article contains forward-looking statements that involve a number of risks and uncertainties. Nasdaq cautions readers that any forward-looking information is not a guarantee of future performance and that actual results could differ materially from those contained in the forward-looking information.}