Supervisory benchmarking: EBA templates, deadlines and validation rules

What supervisory benchmarking covers

In the 2025 credit risk exercise, 99 institutions with approval for the internal ratings-based approach took part (EBA, June 2026). Banks that calculate capital with their own models can reach different answers for similar risks. Each year, under Article 78 of the Capital Requirements Directive, they run their models over the same benchmark portfolios and report the results.

The EBA turns the submissions into benchmark values and gives them to supervisors. Supervisors must look into institutions that diverge from most of their peers, and act where a model understates own funds requirements in a way its risks do not explain (CRD Article 78(4)).

Who reports, and when

Institutions permitted to use internal approaches report to their competent authority at least once a year (CRD Article 78(1)). The EBA publishes the list of institutions for each exercise. The portfolios, templates and instructions are in Commission Implementing Regulation (EU) 2016/2070, which is amended for each year’s exercise.

Credit risk and IFRS 9 data are as at 31 December and usually due on 11 April. Market risk runs to its own timetable in the regulation: the initial market valuation first, the risk measures later. In EBA reporting framework 4.2, the market risk changes apply from reference dates in February and May 2026. Supervisors apply EBA’s validation rules and ask banks to resubmit when rules fail, and the EBA circulates the benchmarks in late June or early July (EBA handbook).

A change is coming. The EBA has consulted on moving the credit risk and IFRS 9 templates into the main supervisory reporting regulation, 2024/3117, with fewer templates and portfolios, from the 2027 exercise on December 2026 data, keeping the 11 April deadline (EBA/CP/2026/08). It has said it may fall back to the 2026 templates if the timeline slips.

What goes wrong in validation

EBA’s 4.2 package has 88 active benchmarking rules across the four modules, written out into 312 checks. Many test that a single value is in range, such as a PD between 0 and 1. By Line4’s count one can block a filing: v4926_m, which says no PD in the high-default template C 103.00 can be above 1. The EBA’s handbook is plain about what that means: failing an “Error” rule causes the file to be rejected immediately.

An example: a default curve cannot go down

Rule v09321_m in EBA’s 4.2 IFRS 9 benchmarking module checks the lifetime PDs in C 112.00. Here it is with simple numbers.

Check benchmarking templates before you submit them

Line4 Check runs 304 of EBA's 312 active benchmarking checks (97%), across the four benchmarking modules below, in your browser. The 8 checks it does not run yet are all in the credit risk module. Try EBA’s own samples, 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.

Why checking at submission matters

Most of these checks are warnings, so a submission 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 bank whose PDs drift away from its peers’ from one exercise to the next, and draft the question for a supervisor, citing the cells behind it. Rules decide whether the data is right. Supervisors decide what it means.