Diligence prepares and submits Pillar 3 public disclosures in XBRL-CSV format for the EBA Pillar 3 Data Hub — ITS templates, DPM validation, and direct submission for banks and investment firms across Europe.
The EBA Pillar 3 Data Hub (P3DH) is a centralised European platform for collecting and publishing Pillar 3 public disclosures from banks and investment firms. It was established under CRR Article 434a, as amended by CRR II and CRR III. Institutions submit standardised XBRL-CSV files to their national competent authority (NCA), which forwards them to the EBA for consolidation and public publication on the P3DH portal.
The objective is to harmonise Pillar 3 disclosures across the EU, making them machine-readable and directly comparable across institutions and jurisdictions. The EBA publishes all submitted disclosures on its public Data Hub, allowing investors, analysts, and supervisors to access structured prudential data without manual interpretation of individual PDF reports.
The obligation applies to institutions subject to CRR Part Eight (Pillar 3) disclosure requirements. This includes:
The scope is being phased in. Large institutions and SSM significant institutions were required from the first reference dates. Smaller institutions are brought into scope progressively as the EBA expands the P3DH framework.
P3DH disclosures are submitted annually and semi-annually, depending on the template package. Annual submissions reference 31 December; semi-annual submissions reference 30 June. Submission deadlines align with the CRR Pillar 3 disclosure timelines — typically within 3–4 weeks of the reference date for public disclosure.
Pillar 3 Data Hub submissions use XBRL-CSV format — a tabular variant of XBRL designed for large, multi-dimensional datasets. The EBA defines the taxonomy, template structures, and validation rules. Institutions must generate conformant XBRL-CSV packages for each disclosure period and submit them through their NCA.
The EBA's Implementing Technical Standards (ITS) on Pillar 3 disclosures define the full template set. The ITS has been progressively expanded. The current framework includes templates covering:
An XBRL-CSV package consists of a metadata file (JSON), fact tables (CSV), and taxonomy references. The metadata maps each CSV file to its XBRL taxonomy context. Each fact row must include the correct entity identifier (LEI), reporting period, and the full set of dimensional coordinates for the data point.
Common technical errors in P3DH submissions include: incorrect LEI format, missing or malformed period context, wrong dimensional values for CRR scope (solo vs. consolidated), and unit errors for percentage vs. basis-point fields.
Institutions do not submit directly to the EBA. The XBRL-CSV package is submitted to the NCA — ACPR for French institutions — which validates and forwards to the EBA. ACPR accepts P3DH submissions through ONEGATE. The NCA returns a validation report; accepted submissions appear on the EBA public portal within days of acceptance.
CRR III (Regulation EU 2024/1623), applicable from 1 January 2025, significantly expands Pillar 3 disclosure requirements. New and revised templates cover output floor disclosures, revised credit risk output floor impacts, ESG risk, and updated remuneration reporting. Institutions using XBRL Express receive all CRR III template updates automatically as the EBA publishes the revised ITS taxonomy.
CRR III introduces mandatory ESG disclosure templates including the Green Asset Ratio (GAR) and Banking Book Taxonomy Alignment Ratio (BTAR). These templates use the same XBRL-CSV format and submit through the same P3DH pipeline. Diligence includes all ESG templates in XBRL Express from the relevant reference dates.
Pillar 3 Data Hub submissions require XBRL-CSV, a more complex format than standard XBRL XML. XBRL Express handles XBRL-CSV natively — the same tool used for COREP and FINREP also generates and validates P3DH packages. No separate tool, no format conversion step.
When the EBA releases a revised P3DH taxonomy — for CRR III, for new ITS templates, or for correction hotfixes — Diligence updates XBRL Express automatically. Institutions do not need to rebuild templates or manage taxonomy files manually.
XBRL Express applies the full EBA DPM validation ruleset before generating the XBRL-CSV package. Dimensional errors, missing facts, and CRR scope mismatches are caught before the file reaches ACPR or the EBA. This eliminates the most common causes of P3DH submission rejection.
French institutions submit P3DH packages through ONEGATE. Diligence's native ONEGATE integration means P3DH submissions follow the same workflow as COREP and FINREP — one platform, one connection, one audit trail.
Pillar 1 (COREP capital), Pillar 2 (ICAAP/ILAAP), and Pillar 3 (P3DH disclosures) generate overlapping data requirements. Managing all three in XBRL Express reduces manual reconciliation between pillars and ensures consistency in submitted figures.
Traditional Pillar 3 disclosures were published as PDF documents or HTML pages on the institution's website. The P3DH replaces this with structured XBRL-CSV submissions that the EBA collects and publishes centrally. Both obligations may coexist during the transition — some institutions still publish PDFs for qualitative disclosures while submitting quantitative templates to the P3DH.
The EBA P3DH framework has been phased in since 2021. Large institutions and SSM significant institutions have been in scope from the early reference dates. CRR III expands the scope and template set from 2025 onwards. Institutions should check the specific ITS reference dates applicable to their size and classification.
Yes. XBRL Express includes all EBA ITS Pillar 3 templates, including ESG disclosure templates (Green Asset Ratio, BTAR) introduced under CRR III. All templates are updated automatically when the EBA releases a new taxonomy version.
XBRL-CSV packages require a valid Legal Entity Identifier (LEI) for the reporting entity, correctly formatted in the XBRL context. XBRL Express validates the LEI format and maps it to the correct XBRL entity context automatically during report generation. Expired or invalid LEIs are flagged before submission.
XBRL-CSV packages prepared, DPM-validated, and submitted through ONEGATE — in the same platform you use for COREP and FINREP.
