EBA funding plans: templates, deadline and rules

What a funding plan covers

Banks’ funding plans for 2024 to 2026 added up to cumulative lending growth of 12.4% for businesses and 7.1% for households, the EBA reported in July 2024. The EBA reads the plans together each year; since 2024 that analysis sits in its risk assessment report.

Funding plans grew out of a 2012 recommendation of the European Systemic Risk Board (ESRB/2012/2), which asked supervisors to watch how banks plan to fund themselves. The EBA guidelines turn that into one set of templates, so plans can be compared across banks and countries. Each template has the actual position at the reference date and the plan for each of the next three years.

01P 01.01 to P 01.03: balance sheet and liquidityAssets and liabilities by counterparty and by where the business is (domestic, other EEA, outside the EEA), and the liquidity coverage and net stable funding ratios, actual and planned.

02P 02.01 to P 02.08: deposits, pricing and plansInsured and uninsured deposits, public sector and central bank funding, innovative funding structures, interest rates on loans and deposits, the two largest currencies, and plans to buy, run off or sell loans and deposits.

03P 04.01 and P 04.02: profit or lossThe planned statement of profit or loss, with a shorter version for small and non-complex institutions.

04P 05.00: debt issuanceThe debt securities that mature and those to be issued in each year of the plan, by type, from Tier 2 instruments to covered bonds.

15 Marchthe deadline each year, on data as at the previous 31 DecemberEBA Guidelines EBA/GL/2019/05, paragraph 19 →

75%of each banking system’s total consolidated assets: the least the reporting banks must coverEBA Guidelines EBA/GL/2019/05, paragraph 9 →

1,384checks in EBA’s 4.2 funding plan rules (240 rules), all of them warningsLine4 count of the EBA 4.2 package →

Who reports funding plans, and when

Supervisors choose the banks: the largest by assets in each Member State, enough to cover at least 75% of the banking system’s total consolidated assets (EBA/GL/2019/05, paragraph 9). Banks report on a consolidated basis, or individually when they are not part of a group (paragraphs 6 and 7).

Plans are annual. They are due by 15 March, with a reference date of 31 December of the previous year (paragraphs 18 and 19), and the current guidelines have applied since 31 December 2020. Banks report in the format their supervisor sets, following the EBA data point model and its validation rules (paragraph 16). In EBA reporting framework 4.2, funding plans are their own module, with 240 validation rules.

What goes wrong in validation

EBA’s 4.2 package has 240 funding plan rules, written out into 1,384 checks. By Line4’s count all of them are warnings: a failure does not stop the plan being filed, but the supervisor can ask why. Most of them test that the plan hangs together.

01The plan has to roll forwardEach planned year’s stock of debt must equal the year before, less what matures, plus what is issued, as set out in P 05.00. Thirty-three rules tie P 01.02 to P 05.00 this way. An issuance plan updated without the balance sheet, or the other way round, fails them.

02Balances without pricingNinety-eight rules check that where P 01.01 or P 01.02 reports a balance, the matching line in the pricing templates P 02.04 and P 02.05 is filled in too. A new deposit line with no pricing fails them.

03Ratios as per unitPercentages go in per unit, with at least four decimals, so an LCR of 145% is 1.4500 (paragraph 16). Rule v6213_m expects the LCR in P 01.03 to be above 1, that is above 100%, now and in the first planned year.

04Figures that should match FINREPBanks have asked the EBA about funding plan figures that should agree with their FINREP balance sheet, such as deposits in P 01.02 (Q&As 2021_6303 and 2024_7133). Those checks span two returns, so a check on the funding plan alone cannot run them: reconcile with FINREP before you file.

A plan is only a plan if next year follows from this one.

An example: next year’s debt has to follow from this year’s

Rule v08934_m in EBA’s 4.2 package ties the liabilities template to the issuance plan. Here it is with simple numbers.

Long-term unsecured debt securities issued, P 01.02 and P 05.00

Planned position, year 1 (P 01.02, row 190): 12,000
Maturing in year 2 (P 05.00, row 0010): 2,500
Issued in year 2 (P 05.00, row 0020): 3,000
Planned position, year 2, as reported (P 01.02, row 190): 13,000

How the rulebook writes it{P_01.02,r190,c040,} = {P_01.02,r190,c030,} - {P_05.00,r0010,c0030,} + {P_05.00,r0020,c0030,}

The same check, in plain words

The planned stock at the end of year 2 must be the year 1 stock, less what matures, plus what is issued in year 2. 12,000 less 2,500 plus 3,000 is 12,500. The plan reports 13,000, so the check fails: either the issuance plan or the balance sheet is out of date.

Rule v08934_m is a warning in EBA’s 4.2 package. The same test runs for Tier 2, senior non-preferred, covered bonds and the other debt types. The numbers are illustrative.

Check a funding plan before you submit it

Line4 Check runs all 1,384 of EBA's active funding plan checks in your browser, on an xBRL-CSV package or an XBRL-XML instance. Try it on EBA’s own funding plans sample, or drop in your own file. Your file never leaves your computer. It is a free check to catch problems early, not a substitute for your authority’s own validation.

Free tool · Line4 CheckCheck a funding plan against EBA's rules, in your browser

Line4 Check runs all 1,384 of EBA's active checks, on an xBRL-CSV package or an XBRL-XML instance. Your file never leaves your computer. It is a free check, not a substitute for your authority's own validation.

Funding plans FP1,384 of 1,384 checks · 100%

Try EBA's FP sample Check your own file

Why checking at submission matters

Most of these checks are warnings, so a plan can be accepted with exceptions that nobody looks at until later. Run at the point of submission, the same rules give the firm an answer in seconds, while there is still time to fix the file, and give the supervisor data it can rely on from day one.

That is the first step to real-time supervision: validated data, sent straight from the firm’s systems, seen as it changes. On top of it, AI can read the movements that matter, such as a planned jump in market funding that the issuance plan does not support, and draft the question for a supervisor, citing the cells behind it. Rules decide whether the data is right. Supervisors decide what it means.

Put it to workBefore you submit a funding plan

1Confirm with your supervisor that you are in scope this year, and on which basis: consolidated or individual.
2Roll each planned year forward from the last, using the issuance and maturities in P 05.00.
3Report pricing in P 02.04 and P 02.05 for every balance in P 01.01 and P 01.02.
4Enter ratios per unit with four decimals: 145% is 1.4500.
5Reconcile the actual position with your FINREP balance sheet, then run the file against EBA’s 4.2 rules before 15 March.

Where Line4 fits

Line4 is SupTech software for financial regulators. It collects returns in XBRL, Excel and CSV by portal, API or MCP, validates them against your taxonomies and rules at the point of submission, and puts AI to work reading them, with supervisors making every decision. If you work with a standard we have not yet run in production, we will say so plainly and show you how we would approach it.

You can try validation at the gate now on an EBA filing: our free EBA validator checks filings for 41 EBA modules, in xBRL-CSV or XBRL-XML, against EBA's own rules, in your browser, without uploading anything. Guides to the returns it checks: IRRBB reporting, NSFR reporting, Resolution and MREL reporting, ALMM reporting, Asset encumbrance reporting, PSD2 fraud reporting and Supervisory benchmarking.

Questions

What is an EBA funding plan?

A bank’s plan for its funding over the next three years, reported to its supervisor once a year in the EBA’s harmonised templates: assets, liabilities, liquidity ratios, deposits, pricing, profit or loss and debt issuance, each actual and planned.

What are the EBA guidelines on funding plans?

EBA/GL/2019/05, the Guidelines on harmonised definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2. They replaced EBA/GL/2014/04 from 31 December 2020. Annex I has the instructions and Annex II the templates.

Which banks have to report funding plans?

The largest credit institutions by assets in each Member State, chosen by their supervisor so that together they cover at least 75% of the banking system’s total consolidated assets. They report on a consolidated basis, or individually if they are not part of a group.

When are funding plans due?

By 15 March each year, with a reference date of 31 December of the previous year (EBA/GL/2019/05, paragraph 19). Where national law lets a bank report on a different accounting year-end, the latest one is the reference date.

Which templates are in a funding plan?

In EBA reporting framework 4.2: P 00.01 (nature of the report), P 01.01 to P 01.03 (assets, liabilities and liquidity ratios), P 02.01 to P 02.08 (deposits, public and central bank funding, innovative funding, pricing, currencies, and loan and deposit plans), P 04.01 and P 04.02 (profit or loss) and P 05.00 (debt issuance and redemptions).

Can I check a funding plan for free?

Yes. Line4 Check runs all 1,384 of EBA's active funding plan checks in your browser, on xBRL-CSV or XBRL-XML, without uploading the file. It is not a substitute for your authority’s own validation.

Sources

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Funding plans reporting: EBA templates, deadline and validation rules