4. General considerations for collection of ICAAP- and ILAAP-related information

Competent authorities should collect the information from institutions regarding ICAAP and ILAAP specified in these Guidelines in order to perform the following supervisory assessments as specified in the SREP Guidelines:

• a. assessment of the soundness, effectiveness, and comprehensiveness of ICAAP and ILAAP frameworks in accordance with Section 5.6.2 of the SREP Guidelines;
• b. assessment of the granularity, credibility, understandability and comparability of ICAAP calculations as specified in Section 7.2.1 of the SREP Guidelines; and
• c. as an additional source of information for the assessments of other SREP elements, including business model analysis in accordance with Section 4 of the SREP Guidelines, assessment of internal governance and institution-wide controls in accordance with Section 5 of the SREP Guidelines, and assessment of risks to liquidity and funding and liquidity adequacy, in accordance with Section 8 of the SREP Guidelines.

Competent authorities should ensure that the information collected from institutions should contain the following:

• a. the ‘reader’s manual’ prepared in accordance with paragraph 11;
• b. general information about ICAAP and ILAAP frameworks, business models and strategy, as well as governance as specified in Section 5 of these Guidelines;
• c. ICAAP-specific information as specified in Section 6 of these Guidelines;
• d. ILAAP-specific information as specified in Section 7 of these Guidelines;
• e. summary of main conclusions of ICAAP and ILAAP and quality assurance information as specified in Section 8 of these Guidelines.

Competent authorities should ensure that the institution provides them with the ‘reader’s manual’ that is prepared as an overarching document facilitating the assessment of ICAAP and ILAAP documents. To this end, the ‘reader’s manual’ should provide an overview of all ICAAP- and ILAAP-related documents submitted to the competent authorities and their status (new, unchanged, changed with minor edits, etc.). The ‘reader’s manual’ should essentially work as an index by linking the specific information items referred to in these Guidelines with the documents provided by the institution to the competent authority (especially in the case where the format of the submission of information allows institutions to submit multiple internal documents, as specified in paragraph 12(d)). The ‘reader’s manual’ should also provide information regarding the material changes to the information items compared with the previous submission of information, and any exclusions from the submission (see also paragraphs 21-22), as well as any other information that may be relevant for the competent authority for the assessment. Furthermore, the ‘reader’s manual’ should contain references to all ICAAP and ILAAP information publicly disclosed by the institution (including the information disclosed in accordance with Article 438(a) of Regulation (EU) No 575/2013⁶ ).

⁶ OJ L 176/1

With regard to the collection of information specified in these Guidelines, competent authorities should set out the operational procedures and notify institutions subject to the provision of ICAAP and ILAAP information about the following:

• a. the dates by which the information should be provided by institutions to competent authorities (remittance dates). When setting remittance dates for the first time or when materially changing these dates competent authorities should allow institutions sufficient time to prepare their submissions;
• b. the reference date, and specify whether different reference dates can be used for individual information items;
• c. the frequency with which the information should be provided;
• d. the technical means and format for the submission of information, and in particular whether information should be provided as one document (report) or in any other form (e.g. multiple documents), or whether institutions may submit own internal documents.

The operational procedures specified in the previous paragraph should be proportionate to the category an institution is assigned to according to Section 2.4 of the SREP Guidelines as further specified in the following paragraphs.

Competent authorities should require an institution that falls under SREP Category 1 to provide them at least with all information items referred to in these Guidelines on an annual basis. Competent authorities should endeavour to set a single remittance date and a single reference date for all SREP Category 1 institutions; however, depending on the organisation of SREP processes, institution-specific dates may be set, where this is deemed more appropriate.

For non-Category 1 institutions referred to in Section 2.4 of the SREP Guidelines competent authorities may:

• a. determine another frequency of information submission rather than annually, and set different remittance and reference dates for various information items always in accordance with the minimum supervisory engagement model applied to each institutions according to Section 2.4 of the SREP Guidelines and the supervisory examination programme pertinent to the institution referred to in Article 99 of Directive 2013/36/EU;
• b. determine different levels of detail or waive certain specific information items referred to in these Guidelines. When waiving information items, competent authorities should ensure that they have obtained sufficient information to assess the ICAAP and ILAAP frameworks and the reliability of the ICAAP and ILAAP capital and liquidity estimates in accordance with the EBA SREP Guidelines.

Depending on the quality of the information provided and the assessment of whether the document(s) submitted cover all areas specified in these Guidelines, competent authorities may request institutions to provide additional information needed for the assessment of ICAAP and ILAAP within the SREP. Competent authorities should determine the appropriate level of granularity and quantity of information to be provided for the purposes of assessment of ICAAP and ILAAP, through an ongoing supervisory dialogue with an institution within the SREP.

The competent authorities should ensure that they receive all relevant information and that this information remains valid and applicable at the remittance date, even in cases where the (production) date of the document is different from the pertinent reference date. Documents related to any information item specified in these Guidelines produced in between the reference date and the remittance date should be included where relevant for ICAAP and ILAAP assessment purposes (taking into account materiality as specified in these Guidelines).

Competent authorities may, with a view to facilitating the assessment of individual SREP elements following the applied engagement model and supervisory examination programme, request from institutions some specific information referred to in these Guidelines or additional information outside the regular ICAAP and ILAAP submission cycle established in accordance with paragraphs 14 and 15 (e.g. some ILAAP-specific information may be requested for the SREP assessment of liquidity and funding risks, and not necessarily for the assessment of ILAAP itself).

Where these Guidelines are applied in relation to cross-border banking groups and their entities, and the college of supervisors has been established, competent authorities involved should, in the context of their cooperation for the SREP assessment in accordance with Section 11.1 of the SREP Guidelines, coordinate to the maximum extent possible the dates, means and format referred to in paragraph 12 as well as the exact and detailed scope of each information item consistently for all group entities.

Where information referred to in these Guidelines is requested from institutions in the form of the institutions’ own internal documents that do not follow the structure or format set out in these Guidelines, competent authorities should endeavour to ensure structural consistency and comparability, including by requesting institutions to explain by means of ‘reader’s manual’ how and where all information items specified in these Guidelines are covered in the documentation provided.

For the purposes of the assessment of ICAAP and ILAAP frameworks and calculations under SREP, competent authorities should ensure that they have received all relevant information items as specified in these Guidelines, taking into account proportionality. Where information items are already available to the competent authorities as part of other activities, competent authorities should require institutions to confirm in the ‘reader’s manual’ that this information remains up to date and there have been no changes to the pertinent documents, or to provide updated information on the changes made to the documents after the last submission. Based on these considerations, competent authorities may decide to omit information items that they possess from other supervisory activities and that remain valid and up to date from the requests for ICAAP and ILAAP information carried out in accordance with paragraphs 14 and 15.

Where information items are available at a very granular level, competent authorities may permit institutions to not submit include every available document in relation to the required information items. When excluding such granular information from submissions, such as supporting documents in relation to local dashboards, meeting minutes and individual key performance indicators, competent authorities should ensure that institutions have provided their general policies governing these items and have mentioned in the ‘reader’s manual’ what information has been excluded from the submission. Competent authorities should, as appropriate, require examples of this information. Competent authorities should ensure that data and documents excluded from submission could nevertheless be required, where this is necessary or appropriate, including for reasons of evidencing the institution’s compliance with the regulatory requirements.