Pillar 3 Disclosure Report Template (CRR Part Eight, CRR3)

Pillar 3 Disclosure Report: [Institution name] [Reference date, e.g. 2026-12-31]

Public prudential disclosure report and production file for a credit institution or investment firm subject to Part Eight of Regulation (EU) No 575/2013 (CRR, Articles 431 to 455) as amended by Regulation (EU) 2024/1623 (CRR3, applying from 2025-01-01). It covers the disclosure policy, the institution's classification and disclosure frequency, a map from each Part Eight article to the uniform disclosure templates of Commission Implementing Regulation (EU) 2024/3172 (the Pillar 3 ITS, as amended by Implementing Regulation (EU) 2026/722 for the EBA Pillar 3 data hub), key metrics, the qualitative risk management statements, the production controls and the management attestation. Articles and template codes are cited by number; obtain the regulation and the ITS annexes for the normative text and check the consolidated versions. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal, regulatory, accounting or financial advice.

Document control

Approvals

Revision history

Contents

1. Purpose, scope and disclosure policy
2. Institution category and disclosure frequency
3. Template map
4. Key metrics and overview of risk exposure amounts
5. Risk management objectives and governance
6. Own funds, capital requirements and output floor
7. Credit, counterparty, market, CVA and operational risk
8. Leverage, liquidity, interest rate risk and encumbrance
9. ESG, remuneration and other disclosures
10. Production process and controls
11. Attestation
12. Jurisdiction notes
13. Glossary and references
14. Standard and licence note

1. Purpose, scope and disclosure policy

1.1 Scope of application

State the name of the institution, the level of application (individual, sub-consolidated or consolidated) and the main differences between the accounting and the prudential scope of consolidation. CRR Article 436 asks for this, and the ITS templates on the scope of application (the EU LI and EU LIA series) show the reconciliation.

Example: Fernhollow Bank publishes this report at the consolidated level. The prudential perimeter equals the accounting perimeter except for Fernhollow Insurance Agency, which is consolidated in the financial statements but is not a financial sector entity and is risk-weighted as an equity holding in the prudential scope. Fernhollow Payments (payment institution subsidiary) is fully consolidated in both.

1.2 Disclosure policy

CRR Article 431(3) requires a formal policy approved by the management body that sets out how the institution meets its disclosure requirements, and internal processes, systems and controls to verify that disclosures are appropriate and compliant. Summarise the policy here and link the approved version.

1.3 Omitted information

CRR Article 432 allows an institution to omit information that is not material, or that is proprietary or confidential, as long as it says so and, for proprietary or confidential items, publishes more general information on the subject. Record every omission.

2. Institution category and disclosure frequency

2.1 Category

CRR Part Eight sets out the disclosure scope by category (Articles 433a to 433c, inserted by Regulation (EU) 2019/876, CRR2, and amended by CRR3): Article 433a for large institutions, Article 433b for small and non-complex institutions and Article 433c for other institutions, each with different content for listed and non-listed institutions. The definitions of "large institution" and "small and non-complex institution" are in CRR Article 4(1), points (146) and (145), also inserted by CRR2. Record the test that you applied.

Example: Fernhollow Bank is designated an O-SII by its national authority, which makes it a large institution, and its senior bonds and shares are listed. It therefore discloses the full annual set, the semi-annual subset and the quarterly key metrics.

2.2 Frequency calendar

Use the frequency columns of the ITS mapping (the EBA publishes a mapping tool with the instructions) to place each template in the calendar. The broad pattern for large institutions is: everything once a year, a subset of quantitative templates every six months and a small set of key metrics every quarter. Small and non-complex institutions disclose a reduced set, mostly once a year. Confirm each template against the current ITS rather than this summary.

2.3 Publication channel

CRR3 amended Article 434 so that institutions submit their disclosures to the EBA, which publishes them centrally, and Article 434a mandates uniform formats. Implementing Regulation (EU) 2026/722 amended the Pillar 3 ITS to support the EBA Pillar 3 data hub (P3DH). The EBA reported that the hub went live on 2026-01-28, with large and other institutions submitting from 2026-01-26 and a transitional period ending with the 2025-12-31 reference date. Small and non-complex institutions were not yet onboarded to the hub at the time of writing; check the EBA P3DH page for the current onboarding plan.

3. Template map

The map below follows the order of CRR Part Eight. Template codes are those used in the Pillar 3 ITS annexes (prefix "EU"); letters in a code (for example EU OVA) denote a qualitative table, numbers (EU OV1) a quantitative template. Confirm codes and applicability against the current ITS annexes, as amendments add and retire templates.

Three points need care in 2026 and 2027:

• Market risk. The CRR3 market risk own funds requirements (FRTB) were postponed in the EU to 2027-01-01. Implementing Regulation (EU) 2026/722 deferred the repeal of the previous ITS, Implementing Regulation (EU) 2021/637, by one year in line with that postponement. A further Commission delegated act with targeted market risk measures from 2027-01-01 was in preparation in mid-2026. Check which market risk templates apply to each reference date.
• ESG and shadow banking. The EBA consulted in 2026 on an amending ITS for ESG risks (Article 449a), equity exposures and the aggregate exposure to shadow banking entities (Article 449b), with proposed first reference dates of 2026-12-31 and 2027-12-31 for small and non-complex institutions. Check whether it has been adopted and published before you finalise MAP-18 and MAP-19.
• Operational risk. CRR3 replaced the previous operational risk approaches with a single standardised approach, so the disclosure of the advanced measurement approach (Article 454 in the pre-CRR3 text) no longer applies in the EU. The EBA revised the operational risk instructions with effect from June 2026.

4. Key metrics and overview of risk exposure amounts

4.1 Key metrics (EU KM1, extract)

Recompute: 3,000 / 20,000 = 15.00%; 3,400 / 20,000 = 17.00%; 4,000 / 20,000 = 20.00%; 3,400 / 50,000 = 6.80%. For 2026-06-30: 2,900 / 19,800 = 14.65%; 3,300 / 19,800 = 16.67%; 3,900 / 19,800 = 19.70%; 3,300 / 49,000 = 6.73%. LCR 6,260 / 4,200 = 149.0% and NSFR 36,000 / 30,000 = 120.0%, as in the ILAAP Report. Row numbers are indicative; use the row identifiers of the current KM1 layout. The ITS asks for LCR figures in KM1 as averages of month-end observations over the preceding twelve months; the example uses the point values at the reference date to stay consistent with the ILAAP Report, so replace them with averages in a real report.

4.2 Overview of risk exposure amounts (EU OV1, extract)

Recompute: 16,400 + 1,000 + 100 + 2,500 = 20,000; 8% of 20,000 = 1,600, and 1,312 + 80 + 8 + 200 = 1,600. In the real OV1, show counterparty credit risk, settlement risk, securitisation and the amounts below deduction thresholds on their own rows; the example folds them into credit risk because the ICAAP Report does.

5. Risk management objectives and governance

5.1 Risk management statement and risk profile (EU OVA)

Include a concise risk statement approved by the management body that describes the overall risk profile associated with the business strategy, with key ratios that show how the risk profile interacts with the risk tolerance. Then describe, per risk category, the strategies and processes, the structure and organisation of the risk management function, the scope and nature of risk reporting and measurement systems, and the hedging and mitigation policies.

Example: The management body of Fernhollow Bank declares that the bank's risk management arrangements are adequate for its profile and strategy. The bank is a retail and SME lender in two euro area countries. Its appetite is expressed through a CET1 floor of 12.0%, a leverage ratio floor of 4.5%, an LCR floor of 120% and an NSFR floor of 110% (Risk Appetite Statement, finance/risk-appetite-statement). At 2026-12-31 all four metrics were above their floors, as shown in EU KM1.

5.2 Governance arrangements (EU OVB)

6. Own funds, capital requirements and output floor

6.1 Composition of own funds (EU CC1, summary)

Recompute: 3,000 + 400 = 3,400; 3,400 + 600 = 4,000. Fill the regulatory adjustment rows (intangible assets, deferred tax assets, prudent valuation adjustments, shortfall of credit risk adjustments to expected losses for IRB exposures and others) from COREP; the example leaves them as placeholders because the ICAAP Report shows CET1 after deductions only.

6.2 Reconciliation to the balance sheet (EU CC2) and capital instruments (EU CCA)

For CC2, list each balance sheet item under the regulatory scope of consolidation that feeds an own funds row and give the cross-reference letter used in CC1. For CCA, list every capital instrument with its issuer, identifier, governing law, regulatory treatment, maturity, call features, coupon terms, write-down or conversion triggers and its position in the creditor hierarchy. Publish the full terms and conditions of each instrument, as Article 437 requires.

6.3 Output floor comparison (EU CMS1, EU CMS2)

CRR3 introduced the output floor in CRR Article 92(3), with a transitional factor that rises each year under Article 465 from 50% in 2025. Institutions using internal models compare their modelled RWEA with the RWEA they would have under standardised approaches only.

Recompute: 55% x 23,500 = 12,925, which is below 20,000, so the floor is not binding. These figures agree with the ICAAP Report, section 5.3.

7. Credit, counterparty, market, CVA and operational risk

7.1 Credit risk and credit quality

Describe the credit risk strategy, the definition of default and of past due and impaired exposures, the approach to credit risk adjustments and the use of credit risk mitigation. Then populate the credit quality templates (performing and non-performing exposures, forborne exposures, collateral obtained by taking possession) and the approach templates (standardised in EU CR4 and CR5, IRB in EU CR6 onwards).

7.2 Counterparty credit risk

Describe the methods used to measure counterparty exposure (for example the standardised approach for counterparty credit risk), the limits, the collateral and margining policies, and wrong-way risk. Populate the CCR templates for the approaches you use and state if a template does not apply.

Example: Fernhollow Bank's derivatives are interest rate and FX hedges with central counterparties and a few banks under collateral agreements. Credit derivatives are immaterial and EU CCR6 is omitted under OMI-001.

7.3 Market risk and CVA risk

State which market risk approaches apply at the reference date and use the matching template set. For 2026 reference dates the EU market risk own funds requirements under CRR3 had been deferred to 2027-01-01; check the version of the market risk templates that applies to each reference date. Describe the CVA risk approach under CRR3 and populate the CVA tables and templates.

Example: Market risk RWEA of 1,000 (internal model 962.5, standardised 37.5) and CVA RWEA of 100 agree with OV1 and with the VaR Backtesting Report (finance/var-backtesting-report).

7.4 Operational risk

Describe the operational risk management framework, the business indicator and its components, the loss data used and any exclusions approved by the competent authority, as the current operational risk templates require. The Operational Risk RCSA (finance/operational-risk-rcsa) and the Operational Loss Event Report (finance/operational-loss-event-report) are the internal sources.

Example: Operational risk RWEA of 2,500 corresponds to an own funds requirement of 200 (8% of 2,500).

8. Leverage, liquidity, interest rate risk and encumbrance

8.1 Leverage ratio

Populate the leverage templates (reconciliation of accounting assets to the leverage exposure, the common disclosure, the split of on-balance sheet exposures) and describe the processes used to manage the risk of excessive leverage and the factors that moved the ratio during the period.

Example: The leverage ratio is 6.80% (3,400 / 50,000), against the 3.0% requirement in CRR Article 92(1)(d) and the internal floor of 4.5%.

8.2 Liquidity

Describe the liquidity risk management strategy, the structure of the liquidity function, the funding sources, the stress testing and the contingency funding plan, then populate the LCR and NSFR templates.

Example: The liquidity buffer of 6,260 after haircuts holds 5,600 of Level 1 assets (central bank reserves 2,000 and government bonds 3,600), which is 89.5% of the buffer (5,600 / 6,260); the rest is Level 2A covered bonds (510) and Level 2B RMBS (150) after haircuts. The composition and the stress results are in the ILAAP Report, section 5, and the Contingency Funding Plan (finance/contingency-funding-plan).

8.3 Interest rate risk in the banking book

Describe how the institution defines, measures and manages IRRBB, the main modelling assumptions (non-maturity deposits, prepayments), and disclose the changes in economic value of equity and net interest income under the supervisory shock scenarios. Use the same figures as the IRRBB Policy and Report (finance/irrbb-policy-and-report).

8.4 Encumbered and unencumbered assets

Disclose encumbered and unencumbered assets by type, collateral received and sources of encumbrance, and explain the main encumbrance drivers (covered bonds, central bank operations, repos, derivative margins). The ITS asks for median values over the period for these templates; check the instructions.

9. ESG, remuneration and other disclosures

9.1 ESG risks (Article 449a)

Describe how environmental, social and governance risks are integrated in strategy, governance and risk management, and populate the ESG templates (exposures to carbon-related sectors, physical risk, alignment metrics and other templates required for the reference date). CRR3 widened the scope of Article 449a, and in 2026 the EBA consulted on amending the ESG templates with simpler requirements for smaller institutions; check which version applies. Link the Climate Transition Plan (finance/climate-transition-plan) once it is in place.

9.2 Shadow banking (Article 449b)

Disclose the aggregate exposure to shadow banking entities as specified by the ITS once the amending templates apply. Until then, record in section 1.3 that the template is not yet specified.

9.3 Remuneration (Article 450)

Describe the remuneration policy, governance (remuneration committee), the link between pay and performance, the ratio between variable and fixed remuneration, deferral and malus and clawback arrangements, and populate the remuneration templates for identified staff. Respect the confidentiality of individuals: where fewer staff are in a category than the policy threshold, aggregate the data.

9.4 Countercyclical buffer, securitisation and G-SII indicators

10. Production process and controls

10.1 Process

The diagram shows the production run for one reference date. Quantitative templates are built only from closed supervisory returns, and no figure moves to review until the reconciliations in section 10.2 pass.

10.2 Reconciliation and quality checks

10.3 Omission and materiality decisions

Record each decision in the table in section 1.3 with the criteria applied. Re-assess omissions every year; information that was immaterial last year may not be this year.

10.4 Review opinion

11. Attestation

I, [name, position], attest that the disclosures in this report for the reference date [YYYY-MM-DD] have been prepared in accordance with the formal disclosure policy and the internal processes, systems and controls approved by the management body of [institution name].

12. Jurisdiction notes

13. Glossary and references

References (cited by number and title; obtain the official text):

• Regulation (EU) No 575/2013 (CRR), Part Eight, Articles 431 to 455, as amended by Regulation (EU) 2024/1623 (CRR3). EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1623/oj
• Commission Implementing Regulation (EU) 2024/3172 laying down implementing technical standards on public disclosures of the information in Titles II and III of Part Eight of the CRR, repealing Implementing Regulation (EU) 2021/637. EBA page: https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/transparency-and-pillar-3/implementing-technical-1
• Commission Implementing Regulation (EU) 2026/722 amending Implementing Regulation (EU) 2024/3172 as regards the use by institutions other than small and non-complex institutions of the EBA single access point for their disclosures (OJ 2026-03-27, in force 2026-04-16). EUR-Lex: https://eur-lex.europa.eu/eli/reg_impl/2026/722/oj
• EBA, Pillar 3 data hub, and press release "The EBA Pillar 3 data hub goes live", 2026-01-28: https://www.eba.europa.eu/risk-and-data-analysis/pillar-3-data-hub
• Prudential Regulation Authority, PS1/26 Implementation of the Basel 3.1 final rules, 2026-01-20.
• 12 CFR Part 217, Subpart D, § 217.61 Purpose and scope: https://www.law.cornell.edu/cfr/text/12/217.61
• Basel Committee on Banking Supervision, Basel Framework, disclosure requirements chapters (DIS) (name only).

14. Standard and licence note

Based on Regulation (EU) No 575/2013 Part Eight as amended by Regulation (EU) 2024/1623 and on Commission Implementing Regulation (EU) 2024/3172 as amended by Implementing Regulation (EU) 2026/722. EUR-Lex and EBA material is reused with acknowledgement; article numbers and template codes are cited and no normative text, template layout or instruction is reproduced. Basel Committee material is cited by name only. The structure, guidance, checks and the Fernhollow Bank example are original; Fernhollow Bank and every figure are fictional. Check the current official versions, the consolidated texts and the current ITS annexes before use, as Pillar 3 requirements change often. This is a documentation format, not legal, regulatory, accounting or financial advice.

Template licence: MIT.