Minutes November 26, 2015

1) EBA

The 2.4 taxonomy will not be used before end of May 2016
The group discusses the European implementations of CRDIV : each country has taken measures to deal with level 1 reporting.
Eg. Spain has an elaborated series of DPM based taxonomies.

Eurofiling has a page with the results of an EBA survey on http://www.eurofiling.info/corepTaxonomy/corep_taxonomy_in_europe.shtml


EIOPA is also going to start using a calendar such as EBA. For S2_2.0.1, the first remittance date is 20.05.2016.
EIOPA plans to have one corrective version per year and one adaptive version at the end of a year
We can expect the next release around Feb/March 2016

Technical issues with 2.0.1:
Julien has spotted problems with assertions linking to the balance sheet / assets: assertions with nilled typed dimensions have problems. Julien has communicated an alternative solution to EIOPA.
A quickfix could be that EIOPA alters the filing rule which states that you have to put ‘nil’ into ‘NA’, then the problem will not occur.
Julien also detected that validation performance degrades as soon as the number of facts increase, due to large numbers of xpath queries.

T4U is not yet able to work with the 2.0.1 taxonomy. EIOPA will probably release the tool next year, apparently for the last time.

Daniel asks about moderately/highly dimensional. From a data collection point of view, the taxonomy is moderately dimensional but has many dimensions. The taxonomy also holds a highly dimensional section for documentation purposes.

3) ECB

In September, EIOPA released ECB add-ons for reporting to insurance supervisors. Daniel asks if the alignment is also existing for the Banking Sector. The group discusses the fact that for the banking sector, with euro-zone and non-euro zone, the data collection domains are vast and more complex, and has different legacies which will probably take a while before getting harmonised (if ever).
Having said this, ECB has announced during the S2 conference in Paris that ECB considers harmonising nontheless some parts and that XBRL is being looked at.

ECB is doing additional checks (plausibility checks / non blocking rules) which are not officially available, not in any taxonomy nor any other official formal way. Some NCA’s in the Euro zone have shared an Excel overview with their filing institutions.

Next call is 28.01.2016 unless something new happens which urges a talk session.


 Merry Christmas and a happy new year !

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Minutes October 29, 2015

1) EIOPA has published its official taxonomy (release 2.0.1) on the scheduled date of 21.10.2015
- This version is the official production release, to be used at least for the first quarters.
- EIOPA may start working on an updated taxonomy which could be released during 2016

2) Market uncertainty around the Tool for Undertakings.
- as communicated earlier by EIOPA, the T4U will be phased out by EIOPA after the first reportings. It is expected that this tool will no longer support future versions of the Solvency II taxonomy.
- this is considered as a good thing by the working group and market stakeholders because:
european tax payers should not pay for software edited by a regulator
the market can play its role in providing quality solutions and
market participants do not have to compete against a competitor who is playing in a whole different league

- earlier mentionings of test instances. In the Madrid workshop, it was mentioned that test instances would be made available which either respect or violate certain Filing Rules. So far, these testfiles were not seen in the publications, the group wonders whether such instance documents are foreseen.

3) EBA taxonomy 2.4
- this taxonomy was released in the summer but still has not the legal publication base by the EU available, which means that this taxonomy will not go live for at least the next 6 months.
- meanwhile EBA is working on version 2.5 which will have some enhancements:
adopting the official table linkbase spec (info)
adopting the enumerations specification
- in the remote background, EBA is also gradually elaborating version 2.6 which will a.o. digest the impacts of IFRS9, which was also mentioned in a presentation from EBA in the Madrid workshop.

4) ESMA consultation on XBRL
- one of the questions is related to the IFRS taxonomy. What is the opinion of the working group?
- the group points out that the EBA FINREP IFRS framework has no link whatsoever to the IFRS taxonomy (anymore), with as main reason that the IFRS taxonomy was too generic for the specific needs for prudential supervision of the banks.
- if ESMA wishes to employ the IFRS taxonomy for listed companies, there will be somewhat reconciliation work XBRL-XBRL for listed banks (and insurers), which will also be the case in any other form of reporting. Prudential reporting is anyways separate from Investors communication

5) CEN: European Filing Rules II
The group considers it a good idea to invite stakeholders to a new workshop.
More info

6) Next Eurofiling workshop in Frankfurt
Proposition will be sent to Eurofiling Coordinator to re-issue another survey mid 2016 about 1 or 2 eurofiling conferences per year.


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Minutes September 24 2015

1) Concern about the growing size of the EBA taxonomies (1 Gb)

Each new version of a taxonomy, such as corep_2.2.0, contains all artifacts from the previous versions, even if they did not change.
eg. if version A_II has only one change in table 123, then with the current approach, the new taxonomy contains a full copy of all tables 1-122, which unnecessarily doubles the size of the full taxonomy.

>> The working group recommends EBA to rework in the near future the taxonomies to one synchronised taxonomy where only changed files are stored in new taxonomy versions.
2) Publication of taxonomy 2.4
The actual go-live date of this taxonomy is unclear at this point.
It’s a good thing that EBA has put “expected reference date” on the Roadmap !!

3) EBA filing rules
Some member states already start enforcing (or facilitating) filing rules such as the working of the filing indicators.
In 2.4 is specified “not before 2014-12″

4) publication of a draft of the EIOPA full S2 taxonomy is expected in the next week (around 30.09)


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Minutes August 27 2015

EIOPA S2 taxonomy (version 2.0.0)

1. the differences between the ECB entry points and the general entry points are discussed

2. It appears that some enumeration lists are out-of-sync with the business lists as documented

3. Taxonomy 2.0.1 will add some assertions and fix potentially some bugs

EBA taxonomies

4. Multi-currency is a difficult matter which may come as a surprise to banks

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Minutes June 25th 2015

1) EBA’s intention to switch to the Table Linkbase REC
The group discusses the paper and is very happy with this news.

2) EIOPA taxonomy 1.7
Most members did not dedicate (a lot of) time to version 1.7.0 and are looking forward to version 2.0 and the assertions. The fact that interval arithmetics may or may not be used is a matter of EIOPA, as long as the thresholds are not becoming a matter of national discretion. The solution must remain European and not create more room for deviation.
Julien has looked at the taxonomy, and considers the rearrangement of templates by EIOPA a good evolution.
Deactivation of rules: the group considers that from a release management point of view, it technically impossible to deal with frequent changes on country-by-country level ! Better to accumulate over longer periods, such as two months.

3) EBA 2.3.1
- being put in production
- table 46 seems to have changed; David gathers input for this potential issue
- Vincent expects EBA to publish its taxonomy 2.4, the date is not known for sure however

4) AOB
Multi-currency: both EBA and EIOPA will adopt the same method, with the proper and intended use of the unitRef and dimensions to take care of “reported in original currency” or “reported in converted currency”

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Minutes May 28th 2015

1) EBA’s whitepaper on multi-currency reporting

The group discusses in detail the paper, and identifies two scenarios instead of one as proposed in EBA’s paper:

Clean scenario : amounts are expressed using the unitRef to differentiate one from the other

° validation rules would need to take into consideration the unitref to differentiate while evaluating
° this scenario works with fact values from dynamic lists where the primary key is not the currency but an identifier such as Portfolio number
° what if amounts are expressed in both the original currency and a converted value in the reporting currency? What with conversion rates?

The group asks if EBA has an example to study.

discuss this in the
- roundtable
- XBRL Subgroup

2) Madrid Roundtable:

- David Bell
- Mark Goodhand
- Antoine
- Eric
- Derek
- Aitor
- Katrin
- Andreas

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Minutes April 30th 2015

1) introduction

2) EIOPA filing rules:

- our replies to EIOPA have resulted in the changing of the Filing Rules document, which demonstrates that

- the group thinks that it’s good to have this communication channel to regulators to raise timely issues to regulatory requirements

3) EBA’s whitepaper on multi-currency reporting

After explanation of the intention of the paper, the participants will discuss this further internally and the group agrees to have the final word during the May call, right before the Madrid week.

It is observed that banks are going to need new Software releases to accommodate the definitive multi-currency solution … lots of changes.

4) Madrid : the group recommendation to have a roundtable slot during the Eurofiling day to discuss some of the topics has been honoured with a slot on Wednesday afternoon. The roundtable will include already David Bell, Corefiling and maybe one from Invoke.

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Minutes March 26th 2015

1) Charter: no comments

2) wiki: some people don’t have access to the wiki, Derek will send mail to Javi to clarify

3) Googlegroups: Eric would like to share documents on the googlegroups, Derek will ask Javi how this can be done?

4) Discussion on EIOPA’s filing rules draft document (feedback before March 30, 2015)

° General comment:
EIOPA refers to both EBA’s filing rules and to CEN’s European Filing Rules (CWA1).
>> It is recommended to have one central document, e.g. at the CEN which is a neutral European Standardisation body.
° 1.6.2 – Filing indicators in several tuples
All filing indicator elements SHOULD be reported in a single tuple before the business facts in the instance document .

>> the group recommends EIOPA to put back “MUST” because some NSA’s will inforce this rule as a MUST which means that tools will have do deal with solutions per NSA.
>> in fact: all SHOULD’s in filing rules are to be avoided for the same reason …

° S.2.18.(c) – representation and @decimal for monetary facts
Monetary facts MUST be reported with at least two decimals (two digits after the decimal point) and @xbrli:decimals appropriate to the scale of a reported value.
>> the group discusses this at length and recommends EIOPA to rephraze this to:
… and @xbrli:decimals=”i” with i = a value between 0 and -4.

5) Madrid : the group recommends having a roundtable slot during the Eurofiling day to discuss some of the topics.

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Minutes May 15th 2014

1.     EBA news. 

Incorrect validation rules. (recapitulation of past conference calls)

The European Banking Authority (EBA) issued a list of incorrect validation rules found in its Implementing Technical Standards (ITS) on supervisory reporting. See the press release at 16 April 2014 (and a further revised list dated 19 May 2014).

From an XBRL point of view, there are several roughly factors involved in the issue, factors analyzed in the Eurofiling Workshops as, among others:

Lack of realistic test cases. The reporting framework is so large than prepare ex-ante   realistic test cases never has been a practical option. Even worst, as the actual reports are confidential, no public “realistic conformance suite” would be made available.

Testing procedures: It is common that early-birds reporting entities send draft reports to NCAs, which in turn feeds the EBA with such draft reports.

Taxonomies are “data centric” while validations rules are “from centric”. The taxonomy development is based in the Data Point Modelling methodology, data centric by nature. However, the validation rules are designed by the business experts in a positional Excel-like notation. Positional validation rules are more prone to be affected than data centric ones by minor updates (i.e. creation of new financial instruments)   The “user friendly validation notation” is a recurrent (but yet unsolved) topic in Eurofiling.

Legal complexities: as the validation rules are part of the Implementing Technical Standards (ITS) on supervisory reporting which has legal effects, fixing bugs is more complex than in the traditional software change management. Due to the lack of practical methods of Formal Validation of software, a classical programmers’ aphorism is “each program has at least one bug” with the corollary “when the detected bug is fixed, other hidden bug will appear”.

As good news, the data container (primary items plus dimensions) proved to be stable.

2.     EIOPA news. 

Working in two “Tools for Undertakings” T4U  oriented respectively to Supervisors and Reporting Entities.

3.     ESMA’s ESEF (European Single Electronic Format). 

4.     CEN WS XBRL Project and Standards/Practices.

Eric Jarry & Ignacio Boixo in the slot of Best Practices Board in the XII Conference (Orlando).

5.     Events and AOB.

13 XBRL EU Day & 19 Eurofiling . Presentations published.

Eurofiling recognition & carving to Claudio Bodini.

XBRL Europe recognition & carving to Noemi Di Segni.

[2014-06-09 & 11] 26th International XBRL Conference Orlando (Florida)

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Minutes April 10th 2014

1.     EBA news. 

Consultation on XBRL Taxonomy (v2.1) related to remittance of supervisory data. Consultation on a revised version of its XBRL Taxonomy for supervisory reporting, which incorporates additional reporting requirements for asset encumbrance, non-performing exposures and forbearance. This consultation aims at ensuring that the data national competent authorities collect from credit institutions and investment firms is transmitted to the EBA in a uniform and consistent manner. The consultation runs until 14 April 2014.

Possible EBA calendar impact due to practical challenges about -among others-:

  • Physical publication of EBA documents in the EU Official Journal [i.e. how to reformat large Excel tables or DPM to accommodate in DIN A4 paper]
  • Official translations to all the European languages
  • Accuracy and stability of validations [i.e. lack of test cases, learning curve, interaction between supervisors designing validations on paper and IT experts running validations on computers, validations notation, and so on]

2.     EIOPA news. 

3.     ESMA’s ESEF (European Single Electronic Format). 

4.     CEN WS XBRL Project and Standards/Practices.

Eric Jarry linking with the XII Best Practices Board (BPB) in organizing the Large Instance Processing slot for Rome.

5.     Events and AOB.

13 XBRL EU Day & 19 Eurofiling . May 5, 6, 7. Rome.

(Gilles Maguet) For organizational and security reasons, the catering initially envisaged for the two main days (Monday and Tuesday) cannot be used and we have to use a specific caterer indicated by the host. For this reason we will incur in additional expenses that we are asking you to share also for the lunches and coffee breaks during the two days. The payment shall be one of the following:

40 € for each participant on Monday, or Tuesday, or both days, WITHOUT gala dinner
90 € for participant on Monday, or Tuesday, or both days, WITH for 1 gala dinner ticket

The payment is to be processed in priority through to the bank account of XBRL Italy

[2014-04-22] XBRL Spain, 10 years. Madrid

[2014-06-09 & 11] 26th International XBRL Conference Orlando (Florida)

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