Outlining the Disclosure and Reporting Requirements for Investment Firms under IFR/IFD

Disclosure overview

1. Investment firms other than Small and non-interconnected investment firms (Class 2)

Class 2 investment firms must disclose information on a range of items, including:

i. Risk management objectives and policies:

Investment firms are required to disclose their risk management goals and strategies for each distinct risk category. This involves outlining the methods and processes employed to handle these risks effectively, along with an approved risk statement by the firm’s management body.

ii. Internal governance arrangements:

Firms must disclose the number of directorships held by members of the management body, the diversity policies related to the selection of management members and whether a risk committee has been established. If such a committee exists, firms must also disclose how many times it meets annually.

iii. Own funds:

As per Article 49, investment firms shall disclose the following information regarding their own funds, in accordance with Article 46:

• A full reconciliation of Common Equity Tier 1 items, Additional Tier 1 items, Tier 2 items and applicable filters and deductions applied to the firm’s own funds and the balance sheet in the audited financial statements of the investment firm.
• A description of the main features of the Common Equity Tier 1, Additional Tier 1 and Tier 2 instruments issued by the investment firm.
• A description of all restrictions applied to the calculation of own funds including the instruments and deductions affected by these restrictions.

iv. Own funds requirements

Firms must provide a summary of their internal capital adequacy process, K-factor calculations, and fixed overheads requirements. Required templates include I CC1, I CC2, and I CCA.

v. Remuneration policy and practices

Investment firms are required to disclose key elements of their remuneration systems, including fixed-to-variable remuneration ratios, aggregated quantitative remuneration data, and whether they qualify for a derogation under Article 32(4) of Directive (EU) 2019/2034.

vi. Investment policy

Firms whose average on- and off-balance sheet items exceed €10 million over the preceding four-year period must disclose information regarding their investment policy.

vii. Environmental, social and governance (ESG) risks

Firms not meeting the criteria outlined in Article 32(4) of Directive (EU) 2019/2034 are required to disclose ESG risks, including physical and transition risks. These must be disclosed biannually, with the first report due by 26 December 2022.

2. Small and non-interconnected investment firms (Class 3)

Class 3 firms that issue Additional Tier 1 instruments must disclose information related to:

• Risk management objectives and policies (as mentioned in point i).
• Own funds (point iii).
• Own funds requirements (point iv).

This information must be published on the same day as their annual financial statements.

Reporting requirements

Below is an outline of the reporting requirements for firms subject to IFR/IFD, in line with Commission Implementing Regulation (EU) 2021/2284. Class 2 and Class 3 firms have different reporting obligations, with Class 3 firms having a less extensive reporting regime due to fewer templates and data points.

1. Investment firms other than Small and non-interconnected investment firms (Class 2):

2. Small and non-interconnected investment firms (Class 3):

How can we help?

Our team of Prudential Risk experts understands that regulations are a key driver of strategic priorities for financial institutions. We specialise in helping clients within the financial services sector navigate complex regulatory frameworks. Working closely with our clients, we identify their regulatory obligations and develop strategies to ensure full compliance.