Templates and tables

15.The disclosure requirements are presented either in the form of templates or of tables. Templates should be completed with quantitative data in accordance with the definitions provided. Tables generally relate to qualitative requirements, but quantitative information is also required in some instances. Banks may choose the format they prefer when presenting the information requested in tables.

16.In line with Principle 3 above, the information provided in the templates and tables should be meaningful to users. The disclosure requirements in this guidance that necessitate an assessment from banks are specifically identified. When preparing these individual tables and templates, banks will need to consider carefully how widely the disclosure requirement should apply. If a bank considers that the information requested in a template or table would not be meaningful to users, for example because the exposures and RWA amounts are deemed immaterial, it may choose not to disclose part or all of the information requested. In such circumstances, however, the bank will be required to explain in a narrative commentary why it considers such information not to be meaningful to users. It should describe the portfolios excluded from the disclosure requirement and the aggregate total RWAs those portfolios represent.

Templates with a fixed format

17.Where the format of a template is described as fixed, banks should complete the fields in accordance with the instructions given.

18.If a row/column is not considered to be relevant to a bank’s activities the bank may delete the specific row/column from the template, but the numbering of the subsequent rows and columns should not be altered. Banks may add extra rows and extra columns to fixed format templates if they wish to provide additional detail to a disclosure requirement by adding sub-rows or columns, but the numbering of prescribed rows and columns in the template should not be altered.

Templates/tables with a flexible format

19.Where the format of a template is described as flexible, banks may present the required information either in the format provided in this guidance or in one that better suits the bank. The format for the presentation of qualitative information in tables is not prescribed.

20.However, where a customized presentation of the information is used, the bank should provide information comparable with that required in the disclosure requirement (i.e. at a similar level of granularity as if the template/table were completed as presented in this document).

Signposting

21.Banks may disclose in a document separate from their Pillar 3 report (e.g. in a bank’s annual report or through published regulatory reporting) the templates/tables with a flexible format, and the fixed format templates where the criteria in paragraph 22 are met. In such circumstances, the specific Pillar 3 table(s) may form a section in a bank’s financial reporting, but the full table will be needed to be disclosed in the Pillar 3 tables separately as well.

22.The disclosure requirements for templates with a fixed format can be disclosed by banks in a separate document other than the Pillar 3 report provided all of the following criteria are met:

1. •the information contained in the signposted document is equivalent in terms of presentation and content to that required in the fixed template and allows users to make meaningful comparisons with information provided by banks disclosing the fixed format templates;
2. •the information contained in the signposted document is based on the same scope of consolidation as the one used in the disclosure requirement;
3. •the disclosure in the signposted document is mandatory.

Banks should note that although signposting may be allowed in the annual report, the bank would still need to disclose this table separately in the Pillar 3 Disclosure along with all other tables mentioned in paragraph 27 below.

23.Banks can only make use of signposting to another document if the level of assurance on the reliability of data in the separate document are equivalent to, or greater than, the internal assurance level required for the Pillar 3 report (see sections on reporting and assurance of Pillar 3 data above).

Qualitative narrative to accompany the disclosure requirements

24.Banks are expected to supplement the quantitative information provided in both fixed and flexible templates with a narrative commentary to explain at least any significant changes between reporting periods and any other issues that management considers to be of interest to market participants. The form taken by this additional narrative is at the bank’s discretion.

25.Disclosure of additional quantitative and qualitative information will provide market participants with a broader picture of a bank´s risk position and promote market discipline.

26.Additional voluntary risk disclosures allow banks to present information relevant to their business model that may not be adequately captured by the standardised requirements. Additional quantitative information that banks choose to disclose should provide sufficient meaningful information to enable market participants to understand and analyze any figures provided. It should also be accompanied by a qualitative discussion. Any additional disclosure should comply with the five guiding principles set out in paragraph 14 above.