EBA Framework 4.4:

Resolution Planning, MREL, FINREP IFRS 18, AMLA and Pillar 3

The next EBA reporting cycle is bringing a number of changes for banks. Under Reporting Framework 4.4, the first phase starts with reference dates in December 2026 and covers Resolution Planning, MREL decisions, AMLA reporting and Pillar 3 disclosures. It also adds a new FINREP entry point for IFRS 18, with a first reference date in March 2027.

For reporting teams, the key point is to understand which requirements apply in the first phase and which ones come later. The second phase, in 2027, is much broader: it brings changes to COREP, FINREP, asset encumbrance, ESG, supervisory benchmarking and DORA reporting, as well as a new IMMV module.

Framework 4.4 at a glance

Phase 1

Dec 2026 → Mar 2027

Resolution Planning
MREL decisions
AMLA eligibility & risk assessment
Pillar 3 disclosures
FINREP IFRS 18

Phase 2

Jun 2027 → Dec 2027

COREP, FINREP, AE, ESG
New IMMV module
Supervisory benchmarking
DORA

What is changing with Framework 4.4?

Framework 4.4 updates the EBA reporting and disclosure framework through changes to the Data Point Model (DPM), XBRL taxonomies, validation rules and reporting requirements.

The framework is being introduced in two phases. The first phase covers requirements with reference dates from December 2026 to March 2027. The second phase follows in 2027 and covers most of the core supervisory reporting modules.

For institutions, the work is not limited to updating reporting templates. New requirements can also mean changes to source data, mappings, validation, reporting workflows and internal controls.

Draft vs final taxonomy.

The EBA first published the 4.4 technical package as a draft, ahead of the final version. Institutions can start their impact analysis on the draft, but configuration and testing should be based on the final taxonomy.

Phase 1: what starts from December 2026?

Resolution Planning – Dec 2026

Framework 4.4 includes technical amendments to the Resolution Planning reporting framework. The changes are reflected in the EBA Data Point Model and XBRL taxonomy, with a first reference date in December 2026.

Institutions will need to make sure that the relevant information is available and can be mapped to the updated reporting structure. Where data comes from several systems or legal entities, consistent definitions and traceability become particularly important.

The implementation work may therefore involve reviewing data mappings, validation rules, reporting templates and the way information is consolidated before submission.

MREL decisions – Dec 2026

Framework 4.4 also introduces technical changes related to MREL decisions. These changes use the updated DPM and XBRL taxonomy and have a first reference date in December 2026.

For reporting teams, the priority is to understand how the updated taxonomy affects existing data and reporting processes. Simply loading a new taxonomy is not enough if the underlying data cannot be mapped and validated efficiently.

FINREP IFRS 18 – 31 Mar 2027

Framework 4.4 adds a new FINREP entry point to reflect IFRS 18, the new accounting standard on presentation and disclosure in financial statements that replaces IAS 1. The first reference date is 31 March 2027.

IFRS 18 changes the way income and expenses are presented in the statement of profit or loss. Institutions reporting FINREP on an IFRS basis will need to check how their accounting data feeds the new templates. As this entry point arrives only one quarter after the December 2026 deadlines, it makes sense to plan the work together with the rest of Phase 1.

AMLA reporting – 31 Dec 2026

AMLA-related reporting is another important part of Phase 1.

Since 1 January 2026, AML/CFT responsibilities at EU level have been transferred from the EBA to the new Anti-Money Laundering Authority (AMLA). Framework 4.4 includes the technical reporting framework for AMLA eligibility and risk assessment.

Why eligibility matters

AMLA eligibility reporting supports the identification of obliged entities that may come under direct AMLA supervision from 2028. The reference date for this process is 31 December 2026.

Framework 4.4 also includes AMLA risk assessment reporting with a December 2026 reference date. For institutions concerned by these requirements, this adds another reporting process to prepare for alongside existing prudential and regulatory reporting.

Pillar 3 disclosures – 31 Dec 2026; SNCI: 31 Dec 2027

Pillar 3 is also changing under Framework 4.4. The EBA has updated the disclosure framework in connection with CRR3 and CRD6.

Among the changes are new or amended disclosures covering ESG risks, equity exposures and aggregate exposure to shadow banking entities.

The first reference date is 31 December 2026. Some requirements applying to small and non-complex institutions (SNCIs) have a later reference date of 31 December 2027. The corresponding DPM and XBRL taxonomy support reporting to the EBA Pillar 3 Data Hub.

One practical issue for banks will be keeping Pillar 3 disclosures consistent with the information used elsewhere in the regulatory reporting process. Where the same underlying data is used for different purposes, strong controls and traceability can help avoid discrepancies.

Phase 2: what comes in 2027

The second phase of Framework 4.4 covers most of the core supervisory reporting modules:

Jun 2027

SBPChanges to the market risk supervisory benchmarking templates
Sep 2027

COREP · FINREP · AE · ESGAmendments linked to CRR3/CRD6 and to the EBA’s simplification work
Sep 2027

IMMVNew moduleMonitoring the use and performance of initial margin models
Dec 2027

DORATechnical amendments to DORA reporting

Jun 2027

SBPChanges to the market risk supervisory benchmarking templates
Sep 2027

COREP · FINREP · AE · ESGAmendments linked to CRR3/CRD6 and to the EBA’s simplification work
Sep 2027

IMMVNew moduleMonitoring the use and performance of initial margin models
Dec 2027

DORATechnical amendments to DORA reporting

For many institutions, Phase 2 will mean more implementation work than Phase 1, even though the deadlines are further away. Starting the impact analysis early leaves time to adapt data, mappings and controls across several modules at once.

What should reporting teams be doing now?

The first Phase 1 deadlines are close enough that institutions should already be reviewing the impact of Framework 4.4 on their reporting processes, and planning for the wider Phase 2 changes. A few areas deserve particular attention:

Data

Identify where the information required by the new requirements comes from and check whether it is available at the required level of detail.
Mappings

Review existing mappings against the updated EBA DPM and XBRL taxonomy. This is especially important where data is currently collected from several systems.
Validation

Check the applicable validation rules and make sure they are included in the testing process before the first production submission.
Traceability

Reporting teams should be able to understand where a reported value comes from and how it has been transformed before submission or disclosure.
Future taxonomy changes

Framework 4.4 is not a one-off update. The EBA is moving towards DPM 2.0 and the new glossary, so reporting systems need to absorb future taxonomy and validation changes without rebuilding the process each time.

How UBPartner can help

UBPartner helps financial institutions manage regulatory reporting requirements and adapt to changing EBA frameworks.

With the XT Platform, institutions can manage data preparation, mapping, validation and reporting in a controlled environment. The platform supports XBRL-based regulatory reporting and helps reporting teams maintain visibility over the process from source data to final submission.