Update on reporting the performance status of the instrument
AnaCredit reporting instructions have been changed so that the data attribute “performing status of the instrument” does not apply to derecognised instruments; for such instruments the value “non-applicable” should be reported. These new instructions shall apply as of the reporting reference date 31 July 2024.
Question
As from the update of the AnaCredit validation checks of 26 January 2024, the data attribute “performing status of the instrument” now covers the value “non-applicable”. Could you please clarify in which situations reporting agents should use the special value “non-applicable” under this attribute?
Answer
Pursuant to the AnaCredit Regulation, there are a total of 88 data attributes, all of which are in principle mandatory. However, in line with the guidance in Section 2.2 of Part 2 of the AnaCredit reporting manual, certain data attributes do not apply in some situations, even in relation to data attributes that are required to be reported. In this connection, the special reporting value “non-applicable” was introduced.
Until now reporting agents could report either “performing” or “non-performing” for the data attribute “performing status of the instrument” under AnaCredit. This also included cases where an instrument is not recognised in the balance sheet. Thus in all cases reporting agents were required to apply the criteria of the ITS on supervisory reporting (Regulation (EU) 2021/451) when classifying an instrument as performing or non-performing (cf. page 143, lines 1-8 in Part II of the AnaCredit Reporting Manual). However, under the ITS derecognised instruments are not within the scope of the definition of performing/non-performing exposures.
Therefore, with a view to ensuring alignment with the ITS, reporting to AnaCredit has been amended so that the attribute “performing status of the instrument” does not apply to derecognised instruments. As a result, reporting agents should only use “performing” or “non-performing” in relation to instruments that are classified as recognised in the data attribute “recognition status”.
The AnaCredit reporting schemes will be updated accordingly, such that it is possible to report “non-applicable” under the data attribute “performing status of the instrument” for derecognised instruments (including written-off instruments that have been derecognised). The first reference date as of which the “non-applicable” value is to be used is 31 July 2024.
The changes to the instructions do not require any past data to be revised and resubmitted to AnaCredit.
Please also note that the use of “non-applicable” is explicitly mentioned in the validation check CN1003, which ensures that where the data attribute “performing status of the instrument” is reported as “non-applicable”, the instrument must be derecognised (i.e. the data attribute “recognition status of the instrument” is reported as “entirely derecognised”).