Author: Selwyn Manning

Source: European Banking Authority

The European Banking Authority (EBA) publishes today the results of its benchmarking analysis on diversity practices in the management bodies of more than 850 institutions credit institutions and investment firms across the European Union (EU). As of 31 December 2024, significant gender imbalances and pay gaps persisted, particularly at senior management level, despite some progress compared with the situation in 2021. The EBA calls on institutions to consider promoting a more balanced representation of genders, and on competent authorities to continue assessing diversity and gender pay gap practices as part of their supervisory reviews.

Key findings

• Diversity policies remain unevenly implemented: around 20% of institutions have no diversity policy, and only 67% have set quantitative targets for gender representation.
• Gender imbalance persists at senior management level: nearly half of institutions have no women among their executive directors, and women account for only 12% of CEOs across the EU. While representation is higher in supervisory functions, women remain under‑represented in leadership roles.
• Male executive directors earn on average around 10% more than their female counterparts, pointing to shortcomings in the application of gender‑neutral remuneration policies.
• There is a positive correlation between gender balance and return on equity (RoE) at institutional level, reinforcing the case for stronger diversity practices.

The EBA will continue to monitor and assess developments in diversity and remuneration practices in the EU, in line with its mandate. It will strive to do so simplifying data templates, adjusting data collection and publication frequencies, and improving data quality, which currently limits the ability to publish benchmarking results closer to the reference date.

Note to the editors

Gender equality is a core value of the European Union and a fundamental right enshrined in the EU Treaties.

Since 2015, the EBA has been collecting data on credit institutions’ and investment firms’ diversity policies and on the composition of management bodies, covering gender, age, geographical origin, and educational and professional background. Since 2021, the benchmarking exercise has also included gender pay gaps at management-body level.

Under Directive 2013/36/EU and the Investment Firms Directive (IFD) institutions are required to adopt diversity policies, take diversity into account when selecting members of the management body, apply gender‑neutral remuneration policies, and monitor gender pay gaps.

The benchmarking analysis is based on data from 704 credit institutions and 163 investment firms across the EU, as well as Liechtenstein and Iceland, and covers a range of diversity dimensions, including gender, age, educational and professional background, and geographical representation.

The report’s findings are presented through interactive visualisations, including:

• Diversity policies & practices [DOWLOAD DATA]
  • Slide 1: gender distribution in top management sorted by role & gender, and age & gender
  • Slide 2: female directors in institutions’ management bodies by EU country
  • Slide 3: implementation of diversity policies by EU country
• Gender diversity & profitability [DOWLOAD DATA]
• Gender pay-gap [DOWLOAD DATA]

For the purposes of the Report, the gender pay gap is defined as the difference between the average gross hourly earnings of men and women, expressed as a percentage of men’s average gross hourly earnings. No adjustments are made for differences in professional experience, qualifications or roles. Since CEOs typically receive higher remuneration and are predominantly male, their inclusion increases the overall observed pay gap; this effect is primarily linked to role composition rather than gender alone.

Source: European Banking Authority

The European Banking Authority (EBA) contributes to the targeted consultation by the European Commission (EC) on the competitiveness of the banking sector and how EU banks can best make the EU a more attractive and competitive place for investors and citizens alike. Since its inception, the EBA has been fully mobilised to enhance the stability and effectiveness of the EU financial system through consistent, transparent, and fair regulation and supervision.

The EBA provides response to 43 of the 95 questions asked in the consultation.

EBA’s responses draw on the Authority’s ongoing work as well as on the report on the efficiency of the regulatory and supervisory framework (“TFE report”) it has published on 1 October 2025[1].

The response acknowledges the resilience of the EU banking sector following an institutional and regulatory build-up since the great financial crisis. As evidenced by the EBA EU-wide 2025 stress test, EU banks have demonstrated their ability to withstand extremely adverse shocks while remaining able to pursue their lending activities. This key as the EU economy largely relies on banks funding.

The EU banking landscape is diversified in size, geographical footprints and business models. EBA analysis confirms that this diversity contributes to stable funding structures, sound capitalisation and resilient profitability across bank types. The EBA notes the presence of foreign financial institutions in the EU, which hold significant market shares in some segments (e.g. derivatives).

The macroeconomic context is evolving fast and EU banks are faced with a volatile and highly uncertain environment. Geopolitical tensions, trade disruptions and market volatility could trigger abrupt repricing of assets, thereby impacting asset quality and profitability. Also ranking high are sectoral vulnerabilities such as exposures to non-bank financial institutions (NBFIs) and transitional challenges linked to digital, sustainability and demographic evolutions.

The digital transition is already deeply transforming the banking sector. New entrants increase competition and encourages incumbent banks to integrate innovative technologies to front and back-office processes. Most EU banks are organically or inorganically incorporating artificial intelligence, cloud computing and Big Data analytics, amongst others, which also comes with new risks.

The EBA’s TFE report has built its recommendations on simplification on four guiding principles: (1) keep up resilience and credibility by commitment to Basel III standards, (2) better reap of the potential of the Single Market, (3) deepen the Single Market and finalise the Banking Union, and (4) maintain an EU level playing field, with appropriate proportionality adjustments and no fragmentation.

Banking rules developed in the EU over the years have increased level playing field and stability, thus fostering the Single Market. They are also complex, as manifested by the various layers of detailed Level 1 (especially if set by directives instead of regulations) Level 2 and Level 3 rules, and supervisory guidance. The EBA acknowledges that setting out provisions through directly applicable regulations fosters convergences within the EU banking sector. Depending on the issues, the rulebook need to find the right trade-offs between warranted supervisory flexibility and consistency through harmonisation.

After years of harmonisation, it is now possible to shift towards more focus on supervisory convergence work. This encompasses the check on the consistent and coherent application of rules, as well as on the review on the existing single rulebook to review the stock of legislation. The EBA is looking into the articulation of requirements across levels 1, 2, 3 texts.

As mentioned in the responses to the EC consultation, the EBA is developing analysis and proposals in the main following areas:

Production of regulatory mandates

Review of the single rulebook by building blocks

The EBA is reviewing all the regulatory products it has developed (Level 2 and Level 3) since its establishment, starting with credit risk, governance and remuneration, ESG, supervisory processes including stress tests and resolution. On credit risk, the EBA is consulting until 10 May 2026 on a Discussion Paper to enhance efficiency and simplicity by consolidating existing regulatory products and key definitions. which will input into the EC analysis. On governance and remuneration, the EBA is consulting until 26 May 2026 (with ESMA) on the suitability assessment of banks and investment firms’ officials. Work on reducing the complexity of the governance and remuneration requirements is under way (guidelines on third-party risk management, revised guidelines on internal governance, RTS on the minimum list of information for competent authorities). On ESG, simplifications on riskiness of exposures to environmental and social risks are expected by end-2026. On the review of supervisory processes including stress testing, the EBA streamlined the supervisory approval process for banks using Internal Ratings Based (IRB) models by reducing the overall number of changes subject to prior approval. In addition, it will release new details on its review of SREP guidelines end Q2 2026. Work on the simplification of the EU-wide stress test is ongoing.

Reporting

Fostering integrated reporting	The EBA is committed to the development and implementation of an integrated, cross-sectoral reporting system. The Joint Bank Reporting Committee (JBRC) set up jointly by the EBA and ECB in 2024 brings together key stakeholders to build an integrated reporting system covering prudential, resolution and statistical reporting. It works on semantic integration and the development of common definitions and standards for the data that banks are required to report for statistical, supervisory and resolution purposes.
Review and reduce existing reporting requirements	The EBA has established a harmonised EU‑wide reporting framework delivering significant efficiency gains for financial institutions and authorities compared with 27 separate national regimes. This has strengthened the foundations for consistent risk analysis and supervision across the Union. The EBA aims to reducing reporting costs by 25% overall. The EBA is consulting until 10 July 2026 on proposals to better align reporting requirements with supervisory needs and reduce the number of data points across the EU harmonised reporting by 50%, strengthening proportionality, in particular for small and non-complex institutions (SNCIs).
Implement a national public EU repository of competent authorities’ data requests	The EBA is establishing an EU-wide public repository of information requests by European and national competent (and resolution) authorities from all institutions in the EBA remit. This would provide public accountability, may facilitate future streamlining and data sharing amongst authorities, and help banks manage the overall reporting burden by not requesting similar information that is included in the EU reporting.
EU-national coordination of reporting initiatives	In addition to collecting data through regular reporting, European and national competent authorities and resolution authorities can request additional data on ad hoc basis. The EBA is working on proposals to facilitate convergence of practices for designing and making such data requests. These common practices will contribute to better coordination between the CAs and RAs and will also reduce reporting burden for banks.
Change management actions	First measures to increase predictability and stability of reporting change were introduced in the wake of the 2021 EBA Cost of Compliance report. The EBA aims to strengthen ex ante impact assessments, increase predictability of the reporting changes through deeper engagement with the stakeholders, and reduce the frequency of changes.

Holistic picture

Reflect on the streamlining of capital/buffer/MDA requirements and the multitude of tiers of own funds and TLAC/MREL	Following the publication of the EBA report on stacking orders and capital buffers – reflections on management buffer practices in the EU in 2024, the EBA is reflecting on the articulation of the various stacks of capital requirements and buffers (TFE Recommendation 9) and the interplay of capital/buffer/MDA requirements and the multitude of tiers of own funds and TLAC/MREL. More analysis to follow in Q2 and Q3 2026.
Introduce a more systematic application of simpler rules for the SNCI category while maintaining a single bank regime and explore the expansion of the SNCI category	The EBA is committed to ensure proportionality of the rules and further reducing compliance costs, in particular for smaller institutions, without loosening the prudential standards (TFE recommendation 10 and Article 519f CRR) and will provide a report on the suitability of the prudential framework for SNCIs, analysing whether and to which extent more proportionality may be introduced in the framework.
Reflect on the existing balance of the home-host responsibilities and the use of waivers in the Single Market in the context of the Banking Union	The TFE report raised the issue of the right distribution of capital and liquidity within banking groups taking into account both the benefits of centralised risk management and those of local stability. Special attention is also given to the interaction between prudential and resolution frameworks.
Set up supervisory platforms bringing authorities from various horizons together	The EBA is exploring the potential and limits of implementing holistic supervisory “college” platforms bringing together all the authorities involved in the supervision of a given bank across regulated areas – especially macroprudential, microprudential, resolution (TFE Recommendation 14), leveraging on its broad constituency, which can help bring authorities from various horizons together to coordinate the setting of measures towards supervised entities (including setting of requirements) and avoid duplication, overlaps, inconsistencies or missed angles.
Periodically report to co-legislators about the adequacy and impact of the EU framework	As the EBA is committed to review the stock and the flows of the incoming mandates, the EBA could also provide on a regular basis an impact assessment of the regulatory framework applicable to banks in the EU (TFE recommendation 18).

 

Source: European Banking Authority

Background

Source: European Banking Authority

The European Banking Authority (EBA) today published a draft technical package for version 4.3 of its reporting framework, covering anti-money laundering (AML) and third country branches (TCB) reporting. This early release is intended to support reporting entities in preparing for upcoming changes ahead of the final publication, scheduled for June 2026. The EBA The EBA invites stakeholders to provide feedback on both the draft technical package and the accompanying glossary.

The draft technical package for release 4.3, includes validation rules, the Data Point Model (DPM) and XBRL taxonomies, and introduces the following new reporting requirements:

• New Implementing Technical Standards (ITS) on the supervisory reporting of third‑country branches, in accordance with Article 48l(1) of the Capital Requirements Directive (CRD). The first reference date is 31 March 2027.
• DPM and taxonomy supporting the methodology to identify obliged entities that will fall under the direct supervision of the Anti‑Money Laundering Authority (AMLA), with a first reference date of 31 December 2026. This package should be read in conjunction with the templates and instructions published by AMLA for the testing and calibration exercise here.

Background, consultation process and next steps

The final technical package for Reporting Framework 4.3 will be published in June 2026 and will reflect any necessary amendments following stakeholder review. This draft publication aims to provide additional implementation time for institutions and to enable the EBA to gather early feedback ahead of finalisation.

Stakeholders are invited to submit comments and suggestions on the draft technical package 4.3 and the new glossary by 10 May 2026, using the EBA feedback form.

Disclaimer: This draft technical package is provided for information purposes only. The final package will include additional elements not yet covered, notably two tables related to the AMLA framework (AML.01.01 and AML.01.02), as well as further validation rules applicable to AML reporting.

Source: European Banking Authority

The European Banking Authority (EBA) today published its 2024 Dashboard on high earners. The data shows an increase in the number of individuals in EU banks earning more than EUR 1 million. The Report also confirms that gender imbalance persists, with high‑paid positions still predominantly held by men in both credit institutions and investment firms.

In 2024, the total number of high earners increases at 2 554 (from 2 343 in 2023). In credit institutions, the number increased by 7% (from 2 122 in 2023 to 2 266 in 2024). In investment firms, it rose by 30% (from 221 in 2023 to 288 in 2024). This development is mainly linked to i) strong profitability supported by higher interest income and active trading, alongside a rebound in advisory and capital markets; ii) favourable economic conditions, including elevated interest rates and renewed M&A activity; and iii) competitive pay adjustments justified by the firms as warranted to attract and retain talent.

The weighted average ratio of variable to fixed remuneration for high earners in credit institutions increased to 98 %. For investment firms, the average ratio fell to 359%. The cap on variable-to-fixed remuneration laid down in the Capital Requirements Directive (CRD) has not applied to investment firms since 2021.

Legal basis and next steps

This Report has been developed in accordance with Article 75(3) of Directive 2013/36/EU and Article 34 (4) of Directive (EU) 2019/2034, which mandate the EBA to collect information on the number of individuals earning EUR 1 million or more per financial year, (high earners), including the business area involved and the main components of remuneration (salary, bonus, long-term award and pension contributions).

The EBA will continue to monitor and assess developments in remuneration practices in the EU, in line with its mandates. However, the relevant regulatory products implementing these mandates will be reviewed in the near future to simplify data templates, adjust data collection and publication frequencies, and consequently reduce data quality issues which currently prevent the publication of the EBA benchmarking report closer to the reference date.

Source: European Banking Authority

The Joint Bank Reporting Committee (JBRC), jointly set up by the European Banking Authority (EBA) and the European Central Bank (ECB), today launched a public call for expressions of interest to join its Reporting Contact Group (RCG). The RCG brings together stakeholders with expertise in banks’ regulatory reporting and serves as a regular forum for cooperation, exchange of views and sharing of best practices with authorities. The call is open to candidates representing stakeholders across the European Economic Area (EEA). The deadline for applications is 28 April 2026 (23:59 CEST).

Application process

Applications must be submitted via the online application form (password: RCGApril2026) and include a CV (preferably in Europass format).

Selection process and next steps

Further details on the selection process are provided in the Call for candidates document.

The JBRC will decide on the final composition of the RCG, aiming, to the extent possible, to ensure, diversity of the banking sector, geographical and gender balance and broad representation of stakeholders across the EEA.

Applicants will be informed of the outcome of their application. The final composition of the RCG will be published on the EBA and ECB websites. A reserve list will also be established.

For further information, please contact the RCG Secretariat at ecb-jbrc@ecb.europa.eu and eba-jbrc@eba.europa.eu

Background information

The JBRC was established by the EBA and the ECB under a Memorandum of Understanding signed on 18 March 2024, following a feasibility study conducted by the EBA in accordance with Article 430c(2)(c) of Regulation (EU) No 575/2013. The JBRC promotes cooperation among European institutions and authorities involved in supervisory, resolution and statistical banking reporting and facilitates transparent engagement with stakeholders to support the development of an integrated reporting system.

The RCG is a permanent substructure of the JBRC, composed of up to 22 members appointed for a three-year renewable mandate. Members are expected to dedicate at least one full day per week to RCG activities and to have strong expertise in supervisory, resolution and/or statistical reporting, or in related areas such as data modelling and standardisation. The mandate of the current RCG composition expires at the end of 2027.

Source: Government of the Netherlands

News item | 31-03-2026 | 13:00

Contributing to redressing historical injustice

The Netherlands is returning cultural objects that were involuntarily taken during the colonial period. Source countries may submit requests for restitution, which are then assessed by the independent committee. The return of cultural objects from a colonial context contributes to redressing this historical injustice.

With this fourth return to Indonesia, the Netherlands is further implementing its policy on colonial collections. In September 2025, then minister Gouke Moes decided to return the Dubois Collection held by Naturalis Biodiversity Center. In December 2025, the first four major objects, including a skullcap, were returned to Indonesia. The further transfer of this extensive collection is currently underway.

Source: European Banking Authority

The European Banking Authority (EBA) today published a Report comparing how banks test the implementation of their recovery plans through so-called “dry runs”. In a context of heightened uncertainty and the continued need for operational preparedness and resilience to unexpected stress events, the analysis confirms that dry runs are an effective tool to strengthen the operationalisation of recovery plans and enhance institutions’ crisis readiness. When used meaningfully, dry runs improve institutions’ ability to respond to stress situations in a timely and credible manner.

The analysis finds that most institutions recognise the value of dry runs and use the lessons learned to improve their recovery planning arrangements. However, approaches and levels of maturity vary significantly across institutions.

Where dry runs are carried out primarily to meet supervisory expectations, they tend to be less effective, resembling compliance exercises with limited insights and follow-up actions. By contrast, institutions with more advanced practices use dry runs as genuine management tools, fully embedding recovery planning within their broader risk management framework. In these cases, dry runs strengthen internal preparedness by enhancing the credibility, feasibility and organisational understanding of recovery planning arrangements.

Looking ahead, the EBA highlights the importance for institutions to maintain regular, high-quality testing of key recovery plan elements and to continue refining  their dry run practices. The Report also points to the potential benefits of stronger synergies and better integration of testing activities across the recovery and resolution, supporting a more effective crisis management continuum.

Legal basis and next steps

In line with the EBA supervisory convergence priorities, under which the usability and testing of recovery plans is a key focus for prudential supervisors in 2026, the EBA has conducted a thematic comparative analysis on recovery plan dry runs. The work also reflects the EBA’s broader mandate to contribute to effective recovery and resolution planning.

The Report is particularly timely in light of recent and upcoming developments, including:

• the publication of the EBA Handbook on Simulation Exercises for Resolution Authorities, which sets out methodologies and good practices for coordinated simulation exercises;
• the EBA’s preparation its future mandate under the Crisis Management and Deposit Insurance (CMDI) regulatory framework to coordinate EU-wide simulation exercises across competent and resolution authorities.

This benchmarking exercise is not intended to provide prescriptive guidance. Rather, it aims to support institutions in the further development of their dry run practices and to contribute to the establishment of useful benchmarks for their implementation.

Source: European Banking Authority

The European Banking Authority (EBA) today published a Decision harmonising how National Competent Authorities (NCAs) report under the SEPA Regulation. The Decision complements the existing European Commission’s Implementing Regulation which requires all Payment Service Providers (PSPs) to report data on charges for credit transfers and payment accounts, as well as the shares of transactions rejected due to EU sanctions. The Decision streamlines the second step of this reporting process – from the NCAs to the EBA and the European Commission.

By introducing a single reporting channel through the EBA, the Decision reduces the administrative burden on NCAs and ensures that both the EBA and the European Commission receive consistent, high-quality data. This supports the Commission in monitoring that consumers benefit from access to instant credit transfers across the EU, and that these are not more expensive than standard credit transfers.

The Decision stipulates that the NCAs will now report this information only to the EBA, and the EBA will then make it available to the European Commission. The Decision also clarifies that when NCAs already possess some of the required data, they are responsible for ensuring its accuracy and completeness without re-collecting it from PSPs.

Furthermore, the Decision amends the Annex to the EBA’s EUCLID Decision to incorporate this new reporting requirement.

The Decision takes effect immediately.

Legal basis

Article 15(3) of the SEPA Regulation requires PSPs to report to their competent authorities every 12 months “(a) the level of charges for credit transfers, instant credit transfers and payment accounts; (b) the share of rejections separately for national and cross-border payment transactions, due to the application of the targeted financial restrictive measures.”

Article 15(4) of the SEPA Regulation requires that “competent authorities shall provide the Commission and EBA with the information reported to them by PSPs under paragraph 3, and the information on the volume and value of instant credit transfers in euro which have been sent, both national and cross-border, by PSPs established in their Member State in the course of the preceding calendar year.”

​Article 53 of the EBA Regulation establishes the tasks of the EBA Executive Director, including implementation of the annual work programme, and adoption of internal administrative instructions and the publication of notices. 

Source: European Banking Authority

The European Banking Authority (EBA) is announcing a series of measures to significantly simplify EU supervisory reporting. A public consultation on revised Implementing Technical Standards (ITS) on supervisory reporting and on supervisory benchmarking reporting is open until 10 July 2026, and until 10 May 2026 for IFRS 18-related requirements.

What the EBA is proposing

The proposals aim to reduce the reporting burden for EU banks while ensuring that supervisory authorities continue to receive the information they need to fulfil their supervisory responsibilities.

“With this unprecedented simplification package, the EBA is proposing very concrete changes to make supervisory reporting considerably simpler, smarter and more proportionate. The new approach would reduce unnecessary burden while preserving the quality and relevance of the information supervisors need. It should also support easier data sharing and more integrated reporting across Europe”, said the incoming EBA Chair, François-Louis Michaud.

The envisaged revisions would better align reporting requirements with supervisory needs, reduce the number of data points across the EU harmonised reporting by around 50% (despite the addition of new reporting requirements related to IFRS 18, ESG and the Fundamental Review of the Trading Book – FRTB), and strengthen proportionality, in particular for small and non-complex institutions (SNCIs).

Separate EU-wide stress test and supervisory benchmarking data collections would be integrated into regular reporting. This would reduce overlaps, increase consistency, simplify reporting processes and make requirements more stable over time.

To foster transparency and coordination, the EBA will develop an EU-wide public repository of European and national supervisory data requests and issue guidance on data-request best practices. As a first step, today’s package includes an overview of national supervisory data collections and ongoing simplification efforts by competent authorities.

The proposed changes would apply from September 2027. In the meantime, the EBA will support implementation through close engagement with stakeholders via the public consultations, related hearings and a workshop.

Those measures contribute to EBA’s work towards integrated prudential and statistical reporting supported by a common data dictionary as part of the Joint Bank Reporting Committee (JBRC) initiative. They build on modern data modelling solutions, including Data Point Model (DPM) 2.0 standards and DPM Studio.

Consultation process

Responses to the consultations can be submitted using dedicated surveys in each topic-specific module and in the general part of the consultation paper on changes to the ITS on supervisory reporting  and in the consultation on the ITS on supervisory benchmarking. Unless requested otherwise, all contributions received will be published after the consultation closes.

The deadline for submitting comments is 10 July 2026, except for IFRS 18-related changes in FINREP, where the deadline is 10 May 2026.

The EBA will hold two public hearings on:

• the consultation paper on changes to the ITS on supervisory reporting on 5 May 2026, 10:00–13:00 CEST. Please register here by 28 April 2026, 16:00 CEST.
• the consultation paper on changes to the ITS on supervisory benchmarking on 24 June 2026, 09:30-12:30 CEST. Please register here until 17 June 2026, 16:00 CEST

The EBA will organise a workshop on ‘Efficient reporting: simpler, smarter, proportionate’, on 4 June 2026, 09:30–13:30 CEST. Please register here by 28 May 2026, 16:00 CEST.

Legal basis and background

EU supervisory reporting requirements are set out in Commission Implementing Regulation (EU) 2024/3117 (ITS on Supervisory reporting). They support supervisors’ assessment of institutions’ financial soundness and compliance with prudential requirements. In line with the EU-wide focus on simplification, the EBA has undertaken a comprehensive review of the ITS.

The EBA’s proposals draw on the experience gained from the use of supervisory reporting (including the EBA’s 2021 study on the cost of compliance with supervisory reporting and the 2025 Report on the efficiency of the regulatory and supervisory framework). Simplification measures focus on reducing data points and templates; adjusting reporting frequency and scope; strengthening proportionality for SNCI, including through a ‘core plus supplement’ approach; integrating parallel EBA data collections (such as stress testing and supervisory benchmarking) into regular reporting; improving alignment of definitions and qualitative elements; and better integrating reporting requirements currently requested at national level.

For supervisory benchmarking on credit risk and IFRS 9, the EBA collects data on the basis of Commission Implementing Regulation (EU) 2024/3117. Following changes to Article 78 of Directive 2013/36/EU (CRD) the reporting requirements need to be updated. Beyond, the consultation introduces simplifications and streamlining. Following the integration into the ITS on Supervisory reporting, the related credit risk and IFRS 9 requirements will be removed from the ITS on Benchmarking of internal models (Regulation (EU) 2016/2070).

The consultation paper sets out a proposal on ESG supervisory reporting requirements, building on the final draft ITS on disclosures developed pursuant to Article 449a of Regulation (EU) No 575/2013, and drawing on the related Pillar 3 disclosure framework. The ITS on disclosures is expected to be published in the coming weeks.