AnaCredit across national central banks, compared

AnaCredit is one ECB regulation and roughly twenty national implementations, and the national layer — not the ECB layer — decides what your file looks like. Regulation (EU) 2016/867 fixes the population, the threshold and the attribute set. Every national central bank then decides how to collect, whether to merge the collection with a pre-existing national credit register, what to demand on top, and how generously to use the derogation power. A group reporting in three countries runs three pipelines against three validation regimes, and in 2026 one of those regimes is being switched off.

1. What the regulation actually fixes

Four provisions do most of the work, and they are the parts you cannot negotiate with an NCB:

• Who reports (Article 3(1)). The actual reporting population is resident credit institutions and resident foreign branches of credit institutions, whether or not they are supervised under Directive 2013/36/EU. Residency, not group structure, is the test.
• The threshold (Article 5). Credit data are reported where the debtor’s commitment amount is EUR 25,000 or more on any reporting reference date within the reference period. The amount is calculated at debtor level — the sum of commitment amounts for all instruments of that debtor in relation to the observed agent.
• What “commitment amount” means (Article 1(25)). Outstanding nominal amount plus off-balance-sheet amount. Undrawn facilities count.
• The proportionality valve (Article 16). An NCB may derogate for small reporting agents provided the derogated agents combined account for no more than 2% of total outstanding loans reported under Regulation (EU) No 1071/2013 by resident reporting agents. Article 16(3) also permits a derogation where the NCB obtains the data elsewhere at the required quality and timeliness.

The collection began in stages: the first stage started on 1 September 2018 and the first transmission carried data for 30 September 2018. Everything else — file format, channel, submission windows, national add-ons, how hard the validation bites — is national.

2. Merged register or greenfield: the choice that shapes the project

Article 1(17) recognises the central credit register — a register operated by an NCB that both receives reports from lenders and feeds credit-risk information back to them. Countries that already ran one had to choose: extend it to carry AnaCredit, or stand up a parallel collection. That single choice explains most of what a reporting agent experiences.

Where the register was merged (Spain, France, Italy, Belgium), AnaCredit arrived as extra granularity on a pipeline the institution already ran, and national scope is usually wider than the ECB floor in at least one direction. Where it was greenfield (the Netherlands), the collection is technically clean and assumes automation from day one. Germany did something else again: a dedicated AnaCredit collection alongside a separate statutory large-loan return.

3. The six collections a cross-border firm actually meets

Spain — Banco de España, through the CIR. The pre-existing Central de Información de Riesgos was re-tooled so one national submission serves both the national register and the AnaCredit extract, delivered over EDITRAN. The declaration threshold for the national register is EUR 1,000 of accumulated risk per holder, so Spanish reporters systematically over-collect relative to the ECB floor.

France — Banque de France, through the Service Central des Risques. The SCR is a long-standing register of credit granted to legal entities, extended to carry the AnaCredit attribute set. As in Spain, AnaCredit added granularity rather than a new front door; it sits alongside collections such as SURFI.

Germany — Deutsche Bundesbank, a dedicated collection. AnaCredit is collected in its own right, with two artefacts worth knowing by name: the published handbook of AnaCredit validation rules, which is the specification most German implementation projects actually work from, and the Zurechnungserklärung, the attribution declaration fixing which entity reports which observed agent. See the Bundesbank reporting channel for how submissions are lodged.

Netherlands — De Nederlandsche Bank, greenfield. With no comparable national register, the collection was built fresh and lodged through Digitaal Loket Rapportages, consistent with the XBRL-based Dutch stack and sitting next to the BSI and MIR returns.

Italy — Banca d’Italia, alongside the Centrale dei Rischi. The national register records exposures from EUR 30,000, with the registration threshold dropping to EUR 250 where the position is classified as a sofferenza. That asymmetry matters: for performing exposures the national threshold is above the ECB floor, while for non-performing ones it is two orders of magnitude below it.

Belgium — Nationale Bank van België, through BECRIS. The Belgian Extended Credit Risk Information System is a purpose-built merged platform: reporters file once, and the NBB serves both the national register and the ECB from the same collection.

4. Germany, 2026: one of the two German returns is being switched off

Until now a German credit institution has carried two credit-reporting obligations: AnaCredit, and the quarterly Millionenkredit notification under § 14 KWG — borrowers whose credit volume reaches or exceeds EUR 1 million, reported to the Bundesbank, which then tells each reporter how far that borrower is indebted elsewhere.

That second return is ending. After a joint Bundesbank and BaFin proposal in August 2025, the Standortfördergesetz cleared the Bundesrat on 30 January 2026 and discontinues the Millionenkredit system on 30 December 2026, affecting roughly 3,200 reporting entities. The stated reason matters here: the supervisors now get the information from other sources, granular AnaCredit data foremost among them. The German dual burden existed because AnaCredit had not yet displaced the national instrument — and now it has.

5. Side by side

6. Worked example: which entity in the group actually files

Facts: a credit institution incorporated in Germany operates a branch in Spain and a subsidiary in the Netherlands. All three book loans to Spanish corporates.

Which rule applies: Article 3(1) attaches the obligation to resident credit institutions and resident foreign branches. Article 6(2) requires a reporting agent that is a legal entity to report in relation to all observed agents that are part of that legal entity; Article 6(3) requires a foreign branch to report its own activity, with coordination between the relevant NCBs where both the legal entity and its foreign branch are resident in reporting Member States.

What the practitioner does: three submissions, not one consolidated file. The German entity reports to the Bundesbank for its own book excluding the Spanish branch; the Spanish branch reports to Banco de España over EDITRAN in the national integrated format; the Dutch subsidiary reports to DNB in XBRL, because it is a separate resident legal entity rather than a branch. Outcome: the same Spanish corporate debtor lands in two national collections under two counterparty-identification regimes — which is why a single group counterparty master with country adapters at the output edge is the only workable architecture.

7. Worked example: the EUR 25,000 test is a debtor-level sum, not a loan size

Facts: a debtor holds a EUR 9,000 amortising term loan with EUR 6,000 outstanding, plus a revolving facility with a EUR 20,000 limit and nothing drawn.

Which rule applies: Article 5(2) sums the commitment amounts of all the debtor’s instruments in relation to the observed agent, and Article 1(25) defines commitment amount as outstanding nominal plus off-balance-sheet amount. The undrawn EUR 20,000 is off-balance-sheet, not zero.

What the practitioner does: computes EUR 6,000 + EUR 20,000 = EUR 26,000 and reports the debtor and both instruments. Outcome: a debtor whose largest drawn balance is EUR 6,000 is in scope. This catches the classic first-year defect — filtering on outstanding balance per instrument, which silently drops every client whose limits exceed their drawings, then reports them for the first time when a draw-down happens, producing an unexplained population jump the NCB will query.

8. Worked example: planning the German 2026 change without breaking AnaCredit

Facts: a German institution has one team maintaining both the § 14 KWG return and AnaCredit, on a shared borrower-grouping layer built for the Millionenkredit definition of borrower unit.

Which rule applies: the § 14 KWG obligation ends on 30 December 2026; the AnaCredit obligation under Regulation (EU) 2016/867 is untouched, including the Article 5 threshold and Template 1 counterparty reference data.

What the practitioner does: separates the shared layer before decommissioning anything, because the two models answer different questions. Retiring the return must not retire the counterparty master, the connected-clients data used elsewhere, or the reconciliation that has been quietly proving AnaCredit completeness against the EUR 1 million population. Outcome: one return retired, and one control that has to be rebuilt on AnaCredit data alone.

9. FAQ

10. What to do, today

• Classify each group entity on two axes — merged-register or greenfield, and legal entity or branch. Those two predict the shape of the work.
• Implement the Article 5 debtor-level test as an explicit rule with off-balance-sheet amounts included, and reconcile its output population month over month.
• Read the national instructions before the ECB manual; for German entities, work from the validation-rules handbook and settle the Zurechnungserklärung before build.
• If you report in Germany, put 30 December 2026 in the plan now and inventory every control that depends on the § 14 KWG population before retiring it.

Related: AnaCredit implementation phases · AnaCredit for payment firms · The AnaCredit data model · CIR — the Spanish credit register · Which BaFin licence you need in Germany