For once, the news reaching EU reporting teams is about something being taken away rather than added. In April 2026 the EBA opened a consultation on a simplification package whose first module targets the two areas those teams find most demanding: liquidity reporting and asset encumbrance. After a decade in which the COREP liquidity stack mostly grew, the direction of travel has reversed. This piece sets out what is proposed, who stands to benefit, and why it would be a mistake to treat any of it as done.
The context matters, because it explains why this is a reporting story and not a rules story. The EU's post-2023 position has been that its liquidity framework held up. CRR3, applicable since January 2025, left the LCR and NSFR substantively untouched. The one legislative change of note was making the preferential NSFR treatment of short-term securities-financing transactions permanent in June 2025, and even that was framed as a competitiveness measure rather than a prudential rethink.
So with the framework itself judged sound, the pressure has moved to its cost. Europe is in the middle of a broader push to reduce regulatory burden and improve competitiveness, and supervisory reporting is an obvious target: it is expensive to produce, especially for smaller institutions, and much of it is collected far more granularly than any supervisor routinely uses. The simplification package is the liquidity chapter of that wider agenda.
The package was published on 10 April 2026 as consultation paper EBA/CP/2026/07, a single revision of the ITS on supervisory reporting split into topic modules. Module 1 covers liquidity and asset encumbrance together (the same paper also carries the IRRBB reporting changes), and its thrust is twofold: cut the sheer volume of data collected, and give smaller institutions a lighter regime.
On volume, the proposals remove datapoints and templates that add cost without adding much supervisory value. The roll-over of funding template (C 70.00) would be discontinued for everyone, for example. On proportionality, the clearest changes are aimed at small and non-complex institutions:
In other words, the smallest banks would report fewer templates, less often, with fewer fields. That is a meaningful reduction for institutions whose compliance teams are small and whose liquidity risk profiles are, by definition, not complex. It is proportionality doing what it is supposed to do: matching the reporting burden to the risk. The largest banks, by contrast, see some additions as well as cuts, including a new C 67.01 that extends funding concentration from the top 10 to the top 30 counterparties.
The encumbrance templates (F 32 to F 36) capture how much of a bank's balance sheet is pledged and therefore unavailable: the quiet structural risk that a heavily encumbered bank has nothing left to mobilize in a crisis, and its unsecured creditors know it. Encumbrance reporting grew out of the 2011 to 2012 crisis and has become detailed since.
Folding it into the simplification exercise is sensible, because encumbrance and liquidity are two views of the same question: what can this bank actually turn into cash under stress? Trimming both together, rather than in separate cycles, is the right instinct, and the proposals explicitly align the encumbrance overview with the ALMM view of assets and collateral. The overview templates F 32.01 and F 32.02 would be replaced by new F 32.11 and F 32.12, F 32.03 would go, and the advanced data in F 36 would be restructured and limited to large institutions on a semi-annual basis.
The change to watch is contingent encumbrance. The F 34 template, which shows how much additional collateral a bank would have to post under stress, is proposed for discontinuation outright. It is one of the more forward-looking things the encumbrance module captures, so banks that use it internally should make sure the view survives in their own risk reporting even if the supervisor stops collecting it.
No, and this is the discipline. The consultation closed on 10 July 2026. The EBA plans to finalize the revised standards and submit them to the European Commission by the end of 2026, with first reporting under the revised framework expected for the 30 September 2027 reference date. Until a final report is published, the details can still change, and nothing has taken effect. It would be a serious error to read the proposals as permission to start decommissioning reporting capability now.
Two reasons for caution. First, the affected templates remain fully in force until the amending standards are adopted and reach their first reference date, so premature cuts create a compliance gap. Second, the ability to escalate liquidity reporting to daily in stress is not going away, whatever is simplified in normal times: under Article 414 of the CRR, a bank that breaches or expects to breach its liquidity requirements must report daily until compliance is restored, unless its supervisor allows otherwise. A bank that dismantles the machinery behind C 66.01 or C 73.00 because routine filing became lighter will find itself exposed the next time a supervisor asks for daily numbers. Simplifying the standing requirement does not reduce the need for the underlying data pipeline to exist and to be fast.
Step back and the package is best understood as housekeeping, not transformation. The binding ratios are unchanged. The strategic questions for EU liquidity regulation lie elsewhere: whether Europe eventually follows the UK and US in recognizing central-bank facilities inside liquidity adequacy, what a digital euro would do to the retail deposit base, and the long-delayed Integrated Reporting Framework (IReF), where the ECB now targets first official reporting in the second quarter of 2031.
Against those, a datapoint cull is modest. That is not a criticism. Reducing the cost of a framework you believe in is a reasonable thing to do, and the burden on smaller institutions has been real. But anyone expecting the simplification package to change how EU liquidity risk is actually regulated will be disappointed; it changes how much it costs to report, not what is required.
The EBA's 2026 simplification package is a welcome trimming of the EU's liquidity and asset encumbrance reporting, with the clearest wins for small and non-complex institutions through a lighter ALMM and the removal of the collateral-swaps template. But it is still a proposal awaiting final standards, it is housekeeping rather than reform, and the underlying data pipelines (above all the capacity to go daily in stress) still have to stand. Read it as cost relief, prepare for 2027, and hold your controls until the ink is dry.
For the full breakdown of the LCR, NSFR, ILAAP and liquidity reporting, and how Basel, the EU, the UK and the US differ, see Mirai RiskTech's guide liquidity regulation across Basel, the EU, the UK and the US: LCR, NSFR and reporting compared.