In conversation with... Erik Becker, Product Director at Regnology
Pillar 3 Data Hub: Beyond disclosure – an opportunity to rethink bank’s data and reporting governance
As the European Union sharpens its focus on financial resilience and transparency, the long‑running European Pillar 3 Data Hub (P3DH) project has completed its implementation phase and went live at the end of January 2026. The corresponding Implementing Technical Standards (ITS) from the EBA are final and in force for the P3DH, bringing a new level of transparency and standardization to the financial sector.
While rooted in regulation, specifically the EU’s Capital Requirements Regulation (CRR III) and Directive (CRD VI), P3DH is far more than an exercise in compliance. For banks, it brings strategic implications—from modernized processes and IT infrastructure to updated policies and stronger data governance.
Moreover, by requiring disclosures to be public, standardized, and machine-readable, it pushes institutions to elevate data quality, ensure internal consistency, and leverage more automation. It also lays the groundwork for broader EU initiatives like the European Single Access Point (ESAP), aiming to make financial data more accessible and comparable across the Union.
In this interview, Regnology Product Director, Erik Becker, delves into the P3DH impact and offers a practical lens on what it means for the industry.
What does the P3DH aim to achieve, and how is it expected to change the way banks approach disclosure?
The P3DH aims to transform prudential disclosure into a standardized, centralized, and transparent process—improving accessibility, comparability, and digital usability of banks’ risk data across Europe.
Historically, Pillar 3 reports were intended to offer clear insight into a bank’s risk profile, but in practice, they were often hard to locate, inconsistently formatted, and scattered across institutional web pages. Recognizing this fragmentation and lack of accessibility, the EBA has introduced P3DH, a centralized platform that will require banks to submit their disclosures in structured, machine-readable formats directly to the authority.
This represents more than just a change in the submission mechanism, it affects how disclosure data is produced, governed, validated, and consumed.
Many banks are already deep into, or nearing completion of, their impact assessments, with a clear focus on identifying resource requirements, strengthening data consistency, and reinforcing governance frameworks to support the transition.
The EBA’s P3DH went live at the end of January 2026, following User Acceptance Testing (UAT) activities that started in Q4 2025. After the defined transition phase, it will serve as a one-stop digital gateway for all prudential disclosures across Europe.
More than just digital copies, these reports are evolving into a public, centralized, and harmonized dataset—a dataset the EBA will make freely available to regulators, investors, analysts, and the public through a dedicated, accessible portal.
Where traditional Pillar 3 disclosure practices were often treated as a checkbox exercise—characterized by fragmented and inconsistent publication—the P3DH marks a strategic shift, prompting banks to fundamentally rethink their data architecture and reporting governance across the organization.
Erik Becker
Product Director
Regnology
Implementation timeline
The new Pillar 3 disclosure structure based on EBA DPM 4.1 applies from mid-June 2025 for large and other institutions and from 31 December 2025 for small and non-complex credit institutions (SNCIs).
The technical submission and publication of Pillar 3 disclosures via the EBA Pillar 3 Data Hub was implemented only after User Acceptance Testing (UAT) starting in Q4 2025 and the platform go-live at the end of January 2026. Until then, disclosures continued to be published via existing channels.
Institutions are required to submit or make available their Pillar 3 disclosures in line with their publication timelines, taking into account the phased transition toward centralized submission via P3DH.
The applicable reporting frequency continues to vary by topic and institution type—typically annual, semi-annual, or quarterly for large institutions, while other institutions have less frequent obligations.
A key element still pending is the EBA’s guideline under Article 106 CRD, which is expected to further harmonize publication rules across the EU. Until then, national practices may continue to differ, and institutions should remain closely aligned with both EBA and local supervisory expectations.
P3DH is here: What are the key challenges for the banking sector?
With the June 2025 deadline nearing, banks are accelerating implementation efforts, prioritizing strong data governance to ensure timely, accurate reporting. Based on feedback from the EBA’s P3DH discussion paper and industry observations, the key challenges include:
Data consistency
Aligning Pillar 3 disclosures with supervisory reporting datasets, including, but not limited to COREP, and FINREP, to ensure a unified and traceable data narrative.
Ensuring consistency between quantitative disclosure data in XBRL-CSV format and qualitative content in PDF format, to avoid discrepancies and maintain credibility.
Managing historical data to support accurate trend analysis and backward-looking consistency.
Regulatory alignment
Finalizing systems, policies, processes, and infrastructure to prepare for P3DH go-live.
Adapting to frequent regulatory updates across jurisdictions, requiring agile data management.
Technical & Operational readiness
Upgrading IT infrastructure to support new formats—XBRL-CSV for quantitative data and machine-readable PDFs for narrative sections.
Strengthening coordination & collaboration across finance, risk, and regulatory teams to ensure data accuracy and timely submission.
Long-term compliance
Ensure consistency of data, preparing for ECB cross-checking published Pillar 3 disclosures against regulatory reporting data.
Laying the foundation for future integration with the European Single Access Point (ESAP) by 2030.
Mitigating reputational risk through consistent, high-quality public disclosures.
Preparing for the P3DH implementation
While the benefits of P3DH are widely acknowledged, the technical and operational demands are significant—especially in view of the first reference date in June 2025.
The impact of P3DH will vary depending on the size and complexity of the institution, following the EBA’s principle of proportionality.
For large and other institutions, preparation include the direct submission of both quantitative (XBRL-CSV) and qualitative (machine-readable PDF) disclosures to the EBA. Ensuring alignment between formats and passing validation checks is critical for compliance.
For small and non-complex institutions (SNCIs), the approach differs. These institutions will not submit directly. Instead, the EBA will use supervisory data collected through EUCLID to generate and publish their Pillar 3 disclosures in the EBA Data Access Portal (EDAP). Further specification and guidance on this process is expected by mid-2025.
Regardless of the submission model, institutions must ensure consistency between supervisory data and public disclosures. For larger and other institutions, the responsibility for data quality remains entirely with the bank, even though supervisors, especially the ECB, are expected to cross-check disclosures against regulatory submissions.
At the same time, with public disclosures becoming fully accessible to analysts, investors, and other stakeholders, ensuring alignment is also key to mitigating reputational risk. Many banks are therefore investing in automated reconciliation and quality controls to safeguard both compliance and credibility.
To support this, banks should aim to use a unified reporting solution that covers both Pillar 1 and Pillar 3 requirements. Unlike the modular submission logic in supervisory reporting, several disclosure requirements must now be submitted together via a single-entry point—for example, Own funds, Leverage Ratio, and liquidity disclosures are grouped under CONDISPILLAR3 (referring to DPM Version 4.1). This bundling requires institutions to manage all relevant templates in a single, consistent system, ensuring alignment across data sources and avoiding system breaks or duplication.
In this context, automation and integrated architecture are critical—enabling accuracy, scalability, and a shift from manual preparation toward strategic oversight.
As data becomes more transparent and available, what’s next?
The P3DH isn’t being built in isolation—it promotes transparency and market discipline by being part of the overall EU data strategy. It is designed to interface with the European Single Access Point (ESAP), the EU’s flagship initiative to centralize public corporate disclosures across the single market.
While P3DH focuses on prudential disclosures from credit institutions, ESAP aims to unify all corporate reporting data—financial, sustainability, and governance—from multiple frameworks into a single digital platform. Data submitted to P3DH will be made available via ESAP by 2030.
How is Regnology helping financial institutions in preparing for P3DH?
Regnology offers advanced regulatory reporting tools to meet demands of the dynamic regulatory landscape and allow financial institutions to modernize their reporting capabilities. With automation at its core, Regnology Reporting Hub offers straight-through reporting: from data ingestion and allocation to complex calculations, validation, XBRL report generation, and consistency checks. It automates fragmented, resource-heavy processes, ensuring transparency and full compliance with Pillar 3 requirements.
Key capabilities include:
Seamless alignment between Pillar 3 disclosures and regulatory reports (CRR Part VIII, Articles 436-455) using EBA mapping tool.
Automated reconciliation to prevent inconsistencies before submission.
Pre-configured XBRL-CSV tool, fully compliant with EBA requirements.
Future-proof reporting solution ready for ESAP integration.
Complete coverage of key supervisory and disclosure modules of P3DH.
By delivering fully machine-readable data in real time, Regnology empowers institutions to shift focus from operational burden to strategic value. With full coverage of the supervisory and disclosure requirements, our solution supports full compliance across Pillar 3 reporting obligations.
Looking ahead
The P3DH marks a fundamental shift in how regulatory disclosures are created, submitted, and consumed. For institutions, it’s not only a compliance obligation—but an opportunity to modernize reporting infrastructure, strengthen data governance,
and align with the EU’s broader push for transparency. Those that act early will be better positioned to navigate the transition smoothly and turn regulatory readiness into strategic advantage.
Digitally transform your regulatory reporting with Regnology Reporting Hub (RRH)
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