The European Banking Authority (EBA) today published a Discussion Paper which proposes a simplified process for small and non-complex institutions (SNCIs) when implementing the Pillar 3 Data Hub (P3DH). The objective is to gather stakeholder feedback on a streamlined approach under which the EBA would collect and perform the calculation and publication of Pillar 3 disclosures for SNCIs, thereby reducing the burden for the latter.
The Discussion Paper outlines the proposed approach for SNCIs, including the methodology for calculating Pillar 3 disclosures on behalf of the institutions. This process is designed to reduce the operational burden currently borne by institutions in managing their own disclosure processes. By providing a single access point to Pillar 3 information, the P3DH is expected to significantly improve transparency, comparability, and accessibility of data for all users, including institutions and supervisors. The Discussion Paper also provides detailed information on the next steps and the expected timeline for the first publication of Pillar 3 information to SNCIs.
The EBA also published a new P3DH FAQ and related IT solutions addressed to large and other institutions. This FAQ provides clarification on IT solutions related to the nomination of contacts persons within institutions who will receive automatic notifications upon the publication of Pillar 3 information.
Consultation process
Responses to the consultation can be submitted using the dedicated survey (EU Survey). Unless requested otherwise, all contributions received will be published after the consultation closes.
The deadline for submitting comments is 20 July 2026, cob.
The EBA will hold a public hearing on 1 July 2026, 15:00 to 16:30 CEST. Please register here by 26 June 2026, 16:00 CEST.
Legal basis, background and next steps
The P3DH is a centralised platform on the EBA website that facilitates the access to Pillar 3 information by all users, covering the full set of requirements under the Pillar 3 disclosure framework. On 26 January 2026, the P3DH went live for large and other institutions. A dedicated page to the P3DH is available on the EBA website, where related FAQs are published on a regular basis.
The EBA is now extending the P3DH framework to Small and Non-Complex Institutions (SNCIs). Under Article 434(4) of the Capital Requirements Regulation (CRR), the EBA is mandated to prepare and publish the Pillar 3 disclosures for these institutions based on supervisory reporting data submitted to competent authorities.
The classification of institutions as large, other or SNCI follows the definitions under Article 4 of the CRR (large institution under paragraph 1(146); small and non-complex institution under paragraph 1(145); other institution classification corresponds to those institutions that do not fall in any of the other two categories).
The feedback received from this consultation will be considered in finalising and implementing the SNCIs process and calculation methodology. This Discussion Paper shall be read in conjunction with the Consultation Paper on the revisions to the ITS on supervisory reporting – module “Alignment with P3 disclosures for SNCIs”.
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Discussion paper on Pillar 3 Data Hub process to SNCIs
