Using standards to reduce the filing burden

Report
Using standards to reduce the filing burden
_____________
Eric JARRY – Banque de France
[email protected]
Preparing for CRD IV Reporting
London 2013-06-17
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European System of Financial Reporting
Europe
Jurisdictions
Reporters
NSAs
ESAs
XBRL
XBRL
CEBS
XBRL
XBRL
XBRL
CEIOPS
CSDB
Central
Securities
DataBase
XBRL
…
…
CESR
Joint Committee
XBRL, a standard?
• XBRL is developed by a not-for-profit
International (http://www.xbrl.org).
association:
XBRL
• 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
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recommendations.
XBRL in ACP / Banque de France
• 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
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XBRL in ACP / Banque de France
• 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)
The SURFI system
KRI instances (to EBA)
OneGate
XBRL
XML
SURFI
XBRL
Output
processing
AS S U R AN C E S
Security
Authentication
Authorization
Certificats mgt
AS S U R AN C E S
AS S U R AN C E S
AS S U R AN C E S
A S S U R A N C E S
Web data
entry
Transfer
protocols
Web
forms
Forms
handling
Forms
generation
Encryption
AS S U R AN C E S
Excel
Messages
XBRL
HTTP
XBRL
XML
Taxonomies
XBRL
Timestamping
Messages
XBRL
validation
(with
formula)
Reporting
database
(XBRL)
XBRL
XBRL
validation
(not
formula)
Conversions
(IPEBA)
XML
CSV
Excel
Common portal of Banque de France
(from National Bank of Belgium)
Taxonomies
Due time
management
Other flows
SAS
Application
Other
applications
Instances
and errors
processing
XML
EDI
SMTP
Views
generation
Excel
PDF
Excel
Signature
CSV
File
transfer
ASSURANCES
AS S U R AN C E S
Registry
Application
Registry
XBRL, a de-facto standard
• 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
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XBRL, features
• 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
– …
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XBRL, community
• 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 /
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software providers
XBRL, mandatory?
• 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
reporting
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XBRL, difficulties?
• 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, enough?
• 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
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(http://cen.eurofiling.info)
Thank you.
Questions ?
[email protected]
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