The European Banking Authority (EBA) was mandated by the EU directive on credit servicers and credit purchasers to draw on its existing voluntary NPL transaction data templates to develop new standardised and mandatory data templates to be used by credit institutions for the provision of information to credit purchasers when selling NPLs. After a public consultation, the EBA published in December 2022 its final draft Implementing Technical Standards (ITS) on its NPL transaction data templates (EBA/CP/2022/05). The ITS were submitted to the European Commission for adoption. On September 26th, 2023, the ITS were published in the Official Journal of the European Union to become effective on October 19th, 2023.
The final templates include 129 data fields, of which 69 are mandatory. In our experience, transforming the data to the new templates is relatively straightforward using existing NPL data preparation software. However, we expect banks to find it challenging to provide all mandatory data fields immediately. Different data fields apply depending on whether the NPL relates to a private individual or corporate borrower and the collateral type of the loan. The templates are to be used for loans that have originated on or after 1 July 2018 and that became an NPL after 28 December 2021. The ITS do not constitute a supervisory reporting obligation and there is currently no enforcement mechanism, but rather rely on market discipline.