EBU Single Rulebook Q&A 29 April 2014 2014_1128 FINREP reporting requirements

If an institution is currently not within the scope of FINREP (i.e. not subject to article 4 of Regulation (EC) No. 1606/2002), but may fall within the scope of FINREP in the future, what would be the institution's first reporting reference date for FINREP? Article 99 (2) of Regulation (EU) No 575/2013 outlines the type of institutions that will need to report financial information under FINREP.