Pillar 3 Data Hub

Fleshing out the simplification agenda

The European Banking Authority (EBA) has published a discussion paper setting out its proposed approach for extending the Pillar 3 Data Hub (P3DH) to small and non-complex institutions (SNCIs).

The proposal represents a further step in the broader European agenda to simplify regulatory requirements and reduce unnecessary reporting burdens. By making greater use of information already submitted through supervisory reporting, the EBA aims to minimise duplication while improving the accessibility and comparability of prudential disclosures across the banking sector.

What is the P3DH?

The Pillar 3 Data Hub is the EBA's centralised platform for the publication of prudential disclosures required under part eight of the Capital Requirements Regulation (CRR). The ultimate objective of this exercise is for all European banks’ disclosures to be made available through a single European platform using data already reported to supervisory authorities.

Following the launch of the P3DH for large and other institutions, the EBA has undertaken a detailed assessment of the Pillar 3 disclosure requirements applicable to listed and non-listed SNCIs, comparing them against existing regulatory submissions. The exercise seeks to identify which disclosure requirements can be fulfilled directly from supervisory reporting data and where additional reporting elements may still be required.

Proposed implementation timeline

The EBA’s discussion paper arrives at a time when many SNCIs have already published their own Pillar 3 disclosures for the December 2025 reference date. This despite the entry into force of the CRR3 in January 2025, which mandates the EBA to make Pillar 3 disclosures available via their website (i.e., Pillar 3 Data Hub).

Under the proposed roadmap, the first phase of implementation is expected to go live during Q4 2026 and will initially focus on the Key Metrics (KM1) disclosure template using information already available through supervisory reporting.

For listed SNCIs, however, this will represent only part of their quantitative Pillar 3 obligations. Full coverage of the disclosure framework for both listed and non-listed SNCIs is not currently envisaged until 2028.

The EBA is therefore seeking feedback on the transitional arrangements to be applied during 2027. In particular, listed SNCIs are invited to comment on two possible approaches:

• Option A – continue publishing only the KM1 template through the P3DH, while institutions remain responsible for publishing all other applicable Pillar 3 disclosures.
• Option B – publish all disclosure templates for which supervisory reporting data is available, while institutions continue to publish any remaining disclosures not yet supported by the reporting framework.

The qualitative disclosures conundrum

While the approach for quantitative disclosures is relatively straightforward – leveraging existing supervisory reporting data and introducing additional data points where necessary – the treatment of qualitative disclosures remains less clear.

The EBA therefore refers to its parallel consultation on revisions to the Implementing Technical Standards (ITS) on Supervisory Reporting, where three possible approaches are being considered:

• Option A – no change. Institutions would continue publishing qualitative disclosures independently through their own Pillar 3 reports.
• Option B – institutions submit a separate document containing qualitative disclosures and narrative information to competent authorities for publication through the P3DH.
• Option C – the EBA's Data Point Model (DPM) is enhanced to allow qualitative information and supporting narrative to be reported in a structured format alongside quantitative disclosures.

While the third option would provide the highest degree of integration, the EBA acknowledges that technical limitations within the DPM may restrict the volume and flexibility of narrative information that can be reported compared to a standalone document approach.

Simplification does not reduce accountability

Although the P3DH is expected to significantly reduce the reporting burden on banks, responsibility for the completeness, consistency and accuracy of Pillar 3 disclosures will remain firmly with banks.

Indeed, as disclosures become increasingly visible through a centralised European platform, data quality is likely to attract even greater supervisory attention.

This message was reinforced in the MFSA’s Dear CEO Letter on the Thematic Review of Pillar 3 Disclosures published on 11 May 2026. Following supervisory work in 2024 and 2025 focusing primarily on Key Metrics, Own Funds, Leverage Ratio and Credit Risk disclosures, the MFSA has indicated that its 2026 review activities will focus on Liquidity, Interest Rate Risk in the Banking Book (IRRBB), Operational Risk and Asset Encumbrance disclosures.

As noted by Christopher P. Buttigieg, Chief Officer Supervision, and Catherine Galea, Head of Banking Supervision:

“As prudential information becomes more visible to a broader range of stakeholders – including supervisors, investors, analysts and the public – data quality and consistency are no longer merely local or institution-specific concerns.”  

The P3DH is expected to address one of the key findings identified by the MFSA, namely inconsistencies between Pillar 3 disclosures and the underlying supervisory reporting data. As disclosure information will increasingly be sourced directly from regulatory submissions, institutions will need to place greater emphasis on ensuring the accuracy and governance of their regulatory reporting processes.

This will be particularly relevant during the transition period, where institutions may continue publishing disclosures on their own websites while the same information is also made available through the P3DH. Any discrepancies between the two sources will need to be understood, investigated and appropriately explained.

Key dates

• 1 July 2026 – EBA public hearing on the P3DH discussion paper.
• 10 July 2026 – Deadline for feedback on the proposed revisions to the ITS on Supervisory Reporting.
• 20 July 2026 – Deadline for feedback on the P3DH discussion paper.
• September 2026 – Pilot exercise with volunteering SNCIs.
• Q4 2026 – Planned initial launch of the P3DH framework for SNCIs.

One notable area of uncertainty remains ESG-related disclosures. These have been excluded from the current analysis as discussions on the future disclosure and supervisory reporting framework for ESG risks are still ongoing.

How we can help

Having supported several banks in the independent review of their regulatory submissions, including Pillar 3 disclosures for the December 2025 reference date, we are currently assessing the implications of the P3DH framework to assist our SNCI banking clients in preparing for their integration.

Given the anticipated shift in supervisory focus to data quality, we are also supporting clients in strengthening their data governance and management processes whilst working on automation initiatives to reduce manual error.

Should you wish to discuss any aspect of these developments or your institution's participation in the consultation process, please feel free to contact us.