Use case #0002

Regulatory filing automation: what Risk Reporting AI submits to ECB / EBA

A bank with €500 million or more in assets is required to submit at least 14 distinct returns and disclosures to the ECB / EBA across various frequencies — monthly, quarterly, half-yearly, and annually. Each has a format, a deadline, and a data specification. The Risk Reporting Agent AI maintains a complete regulatory filing calendar, generates each return from the live operational data at the appropriate frequency, validates the data against the prescribed format before submission, and records the filing confirmation. Compliance is a byproduct of real-time data management, not a separate compliance exercise.

Why regulatory filing is a reporting team's largest single burden — and how automation eliminates it

In most banks with a manual or semi-automated reporting infrastructure, regulatory filing is the reporting team's highest-anxiety task. The anxiety is not about the calculations — the calculations are known and documented. The anxiety is about the data: is the extract current? Does it tie to the financial statements? Are there any discrepancies between what is being filed and what was submitted last quarter? Does the filing team have the authorised signatory available before the deadline?

Each of these concerns is a symptom of the same underlying problem: the data used for the regulatory filing is a copy of the source data, not the source data itself. A copy can be stale. A copy can have formatting errors introduced in the transfer. A copy can diverge from the simultaneously updated source when an account is reclassified or a provision is updated between the extraction and the submission.

The Risk Reporting Agent AI files directly from the source. There is no extraction, no copy, no transfer. The filing data is the operational data, formatted for submission. The question "does the filing tie to the financial statements?" cannot arise because they are the same data.

"The regulatory return that requires three days of data reconciliation before filing is a return assembled from copies. The Risk Reporting AI files from the source — and the source has already been reconciled, because it is the operational system."

The ECB / EBA regulatory calendar: what gets filed, when

NBS-6
Monthly
Monthly return on important financial parameters · ECB / EBA Master Circular DNBR

Balance sheet summary, income/expenditure, NPL position, and capital adequacy — monthly

NBS-6 is the primary monthly bank return — a high-level financial summary submitted to the ECB / EBA within 15 days of the month-end. The Risk Reporting AI assembles the NBS-6 from the CBS balance data and the Provisioning AI's classification database at month-end, validates the format against the ECB / EBA's prescribed XBRL taxonomy, and submits via the ECB / EBA's XBRL reporting portal. The submission is complete 7–10 days before the 15-day deadline — not on the last day.

→ Source: CBS + Provisioning AI · Format: XBRL · Auto-submitted · Confirmation recorded
15 days
after month-end
Filed day 8
FINREP
Quarterly
Quarterly asset quality and NPL schedule · DNBR reporting

Detailed NPL schedule by category, provisioning coverage, and sector-wise credit distribution

FINREP requires the institution to report the full EBA NPL classification standards-classified NPL position — account counts, outstanding balances, and provisions by category — plus the sector-wise breakdown of the credit portfolio. The Provisioning AI provides the classification data; the Origination AI provides the sector-wise portfolio composition. The two data sets are merged, validated, and submitted within 21 days of quarter-end.

→ Source: Provisioning AI + CBS · Format: XBRL · Sector data from Origination AI · Filed day 14
21 days
after quarter-end
Filed day 14
ALM Return
Monthly
Asset-Liability Management Return — Statement of Structural Liquidity

Asset and liability maturities bucketed by time band — 1–14 days through 5+ years

The ALM return requires the institution to report the maturity bucket structure of its entire balance sheet — assets and liabilities bucketed by days to maturity. The Risk Reporting AI pulls the maturity schedule from the CBS for every asset and liability and applies the ECB / EBA's prescribed bucketing rules. The Statement of Structural Liquidity and the Interest Rate Sensitivity Statement are generated simultaneously and submitted as a package.

→ Source: CBS maturity schedules · ECB / EBA bucket structure applied · Simultaneous SLS + IRSS
15 days
after month-end
Filed day 7
Fair Practice
Code Report
Quarterly
FPC compliance report — collections conduct, disclosure, complaint resolution

Complaints received, resolved, and pending; collection conduct incidents; disclosures made

The FPC quarterly return requires the institution to report on customer complaints (received, resolved, and pending), any collection conduct incidents flagged, and confirmation of the disclosures made during the quarter. The Risk Reporting AI assembles this from the collections system (conduct data), the grievance management system (complaints), and the Disbursement AI (disclosure confirmations). It is the one return that requires data from the most operational systems.

→ Source: Collections, Grievance, Disbursement AI · Conduct incidents cross-checked
30 days
after quarter-end
Filed day 18
GNPA/NNPA
Disclosure
Quarterly
Public NPL disclosure — website and annual report

Gross NPL ratio, Net NPL ratio, and Provision Coverage Ratio — public disclosure

The three NPL ratios required for public disclosure are computed directly from the Provisioning AI's classification database and the CBS balance data. They are posted to the institution's website simultaneously with the FINREP filing — ensuring consistency between the regulatory return and the public disclosure. The Risk Reporting AI generates a disclosure document in the prescribed format and an automated CMS update for the website.

→ Consistent with FINREP · Website and XBRL filing simultaneous · CMS update automated
Simultaneous
with FINREP
Filed day 14

The complete regulatory filing calendar: all 14 returns tracked

ReturnFrequencyDeadlinePrimary Data SourceStatus — Q3 FY2025–26
NBS-6 (Financial parameters)Monthly15 days post month-endCBS + Provisioning AIFiled — all months
FINREP (Asset quality)Quarterly21 days post quarter-endProvisioning AI + CBSFiled Q1 and Q2
ALM — Structural LiquidityMonthly15 days post month-endCBS maturity schedulesFiled — all months
ALM — Interest Rate SensitivityMonthly15 days post month-endCBS + Pricing AIFiled — all months
EBA consumer protection standards ReportQuarterly30 days post quarter-endCollections + Grievance + Disbursement AIFiled Q1 and Q2
GNPA / NNPA Public DisclosureQuarterlyWith FINREPProvisioning AIFiled Q1 and Q2
Credit Information Returns (credit bureau)Monthly15 days post month-endCBS payment registerFiled — all months
KYC / AML Suspicious TransactionAs applicableWithin 7 days of identificationKYC / AML AI + Document AI3 filed this quarter
Significant Counterparty ExposureAs applicableWhen threshold crossedCBS + Origination AINo threshold crossings
Stress Test Report (Q3)Quarterly30 days post quarter-endStress Testing AIData-ready · Jan 14 filing
FINREP Q3QuarterlyJan 21, 2026Provisioning AI + CBSData-ready · Jan 14 filing
Annual Director / Auditor ReportAnnualWithin 30 days of AGMAll data sources consolidatedAnnual · FY2025–26 build
Related Party TransactionsQuarterlyWith quarterly financialsCBS + TreasuryFiled Q1 and Q2
Capital Adequacy Return (capital adequacy ratio)Quarterly21 days post quarter-endStress Testing AI + CBSFiled Q1 and Q2
14Distinct ECB / EBA returns managed — from monthly NBS-6 to annual director report · All tracked in calendar
ZeroLate filings — every return filed 7–14 days before deadline · Deadline approached as backstop, not target
ZeroDiscrepancies between regulatory submissions and financial statements — same source data, same moment
Day 7–14Typical filing day — most returns due day 15–30; filed day 7–14 · Buffer for review and correction

Regulatory compliance is not a periodic exercise — it is a continuous data quality discipline

a bank that treats regulatory filing as a quarterly or monthly event — rather than a continuous data quality practice — will always file in a rush, because the data quality issues that were tolerable between reporting cycles are suddenly urgent at the filing deadline. The Risk Reporting Agent AI treats regulatory filing as the natural output of continuous data management: the CBS is current, the provisioning is current, the ALM maturity schedule is current — and all that the regulatory return requires is to format that current data into the prescribed submission format and send it. When the data is always right, the filing is never the problem. The filing is just the printing of what you already know to be true.

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