Guidance notes to reporting 
agents on SHS regulation  
for statistics on holdings of securities  
by reporting banking groups  (SHSG)  
  
September  2018 

 
Guidance notes to reporting agents on  SHS regulation  − Overview  1 Contents  
1 Overview  2 
2 Scope of the SHSG data collection  4 
3 Instrument categories covered  6 
4 General reporting requirements  8 
4.1 Frequency and timeliness  8 
4.2 Level of reporting  8 
4.3 Accounting rules for the reporting  10 
5 Reported attributes  16 
5.1 Holder reference information  16 
5.2 Holdings of ISIN and non -ISIN securities (attributes at group level)  22 
5.3 Holdings of ISIN and non -ISIN securities (attributes at entity level)  36 
5.4 Holdings of non -ISIN securities (additional instrument and issuer 
reference attributes)  51 
 
 
Guidance notes to reporting agents on  SHS regulation  − Overview  2 1 Overview  
In August 2016 the Governing Council adopted the amendment to the Regulation 
and Guideline of the European Central Bank (ECB) concerning statistics on holdings 
of securities (SHS) and the extension of the list of reporting banking groups. In order 
to bette r meet users’ needs and ensure the provision of adequate information on the 
statistics on holdings of securities by reporting banking groups (SHSG), additional 
attributes are included in the data collection, in particular on accounting and risk -
related inf ormation. In addition, the list of reporting banking groups will be extended 
to cover all significant banking groups under direct ECB supervision. The first 
reporting according to the new requirements, including the additional banking 
groups, is foreseen t o start with data relating to the reference period end -September 
2018.  
This document provides guidance and more detailed information on the 
amended SHSG data reporting requirements  as set out in Regulation (EU) No 
1011/2012 of the ECB of 17 October 2012 co ncerning statistics on hol dings of 
securities  (ECB/2012/24)  including subsequent amendments , hereinafter referred to 
as “the SHS Regulation”1. The document focuses on the SHSG data reporting, i.e. 
the reporting concerning the statistics on holdings of secu rities by reporting banking 
groups.  
In addition to the existing requirements, t his document also covers forthcoming 
requirements that will start to apply to the reporting of data relating to the reference 
period end -September 2018. The detailed implementation of the data collection from 
reporting agents to national central banks (NCBs) – i.e. further material such as 
templates, code lists and other technical specifications with regard to the primary 
reporting – is organised at national level unde r the respo nsibility of the relevant 
NCB.2 
This document explains the underlying methodology of the reporting requirements 
and provides guidance on the preferred approach that may be taken in cases 
where the respective ECB legal act leaves scope for differ ent interpretations . 
The document aims to provide guidance by clarifying and providing examples related 
to the requirements and definitions previously laid down in the SHS Regulation. It is 
not a legally binding document and cannot in any way replace the l egal requirements 
                                                                    
1  Available at https://www.ecb.europa.eu/ecb/legal/1005/shs/html/index.en.html . In February 2018 t he 
Governing Council approved a further  amendment as set out in R egulation (EU) 2018/318 of the ECB 
of 22 February 2018 amending Regulation (EU) No 1011/2012 concerning stat istics on holdings of 
securities (ECB/2018/7) . 
2  In accordance with amending Regulation ECB/2018/7 group data reporting agents can report data 
directly to the ECB , subject to the decision of the relevant NCB. I f an NCB decides to join this 
approach , the a ffected group data reporting agents are informed accordingly and the SHSDB team 
specifies the required reporting instructions in coordination with the relevant NCBs. This applies to all 
subsequent parts of this document where reporting instructions are fla gged as subject to the discretion 
of NCBs.  The relevant reporting requirements for directly reporting banking groups that clarify these 
discretionary case s are published on the ECB website: 
https://www.ecb.europa.eu/stats/financial_markets_and_interest_rates/securities_holdings/reporting/ht
ml/index.en.html .   
 
Guidance notes to reporting agents on  SHS regulation  − Overview  3 laid down in the SHS Regulation which is the sole legally binding act.  In the case of 
divergences between the relevant applicable legal act and this document , the former 
will prevail.  
This document is structured as follows:  
Section 2  contains information on the scope of the SHSG data collection;  
Section 3  covers specifications with regard to the instrument categories covered;  
Section 4  summarises general reporting requirements;  
Section 5  provides a detailed description of the attribut es included in the reporting 
with a breakdown by attribute type:  
Section 5.1  – Holder reference information;  
Section 5.2  – Holdings of ISIN and non -ISIN securities (attributes at group level);  
Section 5.3  – Holdings of ISIN and non -ISIN securities (attribu tes at entity level);  
Section 5.4  – Holdings of non -ISIN securities (additional instrument and issuer 
reference attributes).  
 
Guidance notes to reporting agents on  SHS regulation  − Scope of the SHSG data collection  4 2 Scope of the SHSG data collection  
Definition of banking group in line with prudential scope  
The scope of the reporting as defined i n Article 1(4) of the SHS Regulation follows 
the prudential approach as set out in Directive 2013/36/EU and Regulation (EU) No 
575/2013, i.e. the scope of prudential consolidation in accordance with the Capital 
Requirements Regulation (CRR).  
 Consequently , the security holdi ngs of all domestic and foreign financial 
entities of the groups (captured by the prudential scope)  have to be 
included in the reporting.  
 The holdings of the appointed heads of banking grou ps have to be reported 
as well.  
 However, certain entities, notably  insurance undertakings , are not covered by 
the prudential scope and, therefore, the holdings of insurance entities of the 
groups should not be reported in the SHSG data collection.  
 Securities held in custody for third parties are also not  in the scope of the SHSG 
data collection.  
Exclusion of banking group entities from reporting in line 
with CRR rules  
The amended SHS legal text makes explicit reference to various provisions of the 
CRR relevant for prudential consolidation . In particular, it makes reference to 
Articles 19(1) and 19(3) of the CRR, which clarify the cases where subsidiaries or 
undertakings in which a participation is held need not be included in the scope of 
consolidation. Credit institutions have discretion whether or not to  include 
subsidiaries or undertakings in the scope of CRR consolidation; however, it should 
be noted that this decision is binding for the purposes of determining the scope of 
the banking group whose securities holdings data must be reported according to t he 
amended SHS Regulation.  
Reporting for the whole banking group centrally by the 
head of a banking group  
The security holdings of all worldwide entities of the banking group have to be 
reported centrally by the head of the group (“home approach”) . The def inition of 
the head of a banking group as the reporting agent pursuant to Article 1(10) of the 
SHS Regulation captures:  
 
Guidance notes to reporting agents on  SHS regulation  − Scope of the SHSG data collection  5  EU parent institutions ;  
 EU parent financial holding companies ;  
 EU parent mixed financial holding companies ;  
 central  bodies within the me aning of Article 10 of the CRR.  
These terms are defined by reference to the relevant provisions of the CRR, save 
that an entity can qualify as the head of a banking group only if it is established in a 
euro area country. It should also be noted that group data  reporting agent s in 
accordance with Article 2(1b) of the SHS Regulation do not necessarily have to be a 
credit institution.  
 
Guidance notes to reporting agents on  SHS regulation  − Instrument categories covered  6 3 Instru ment cat egories covered  
Data reporting will need to cover h oldings of securities classified under the following 
instrument categories:  
 debt securities (F.31 and F.32)  
 listed shares (F.511)  
 investment fund sha res or units (F.521 and F.522).  
The numbering of categ ories reflects the numbering introduced in Regulation (EU) 
No 549/2013 of the European Parliament and of the Council of 21 May 2013 on the 
European system of national and regional accounts in the European Union, i.e. the 
European System of National and Reg ional Accounts, hereinafter referred to as 
“ESA 2010”.  
There is no requirement to report i nstruments classified under any of the other 
classes; the same applies to the other equity sub -categories, i.e. unlisted shares 
(F.512) and other equity (F.519). The instrument categories are defined in Part 1 of 
Annex II to the SHS Regulation:  
 
Guidance notes to reporting agents on  SHS regulation  − Instrument categories covered  7 Category  Description of main features  
1. Debt securities (F.3)  Debt securities are negotiable financial instruments serving as evidence of debt. Debt securities 
display the fol lowing characteristics:  
(a) an issue date on which the debt security is issued;  
(b) an issue price at which investors buy the debt securities when first issued;  
(c) a redemption date or maturity date on which the final contractually scheduled repayment of the 
principal is due;  
(d) a redemption price or face value, which is the amount to be paid by the issuer to the holder at 
maturity;  
(e) an original maturity, which is the period from the issue date until the final contractually 
scheduled payment;  
(f) a remaining or residual maturity, which is the period from the reference date until the final 
contractually scheduled payment;  
(g) a coupon rate that the issuer pays to holders of the debt securities; the coupon may be fixed 
throughout the life of the debt s ecurity or vary with inflation, interest rates, or asset prices. Bills and 
zero-coupon debt securities offer no coupon interest;  
(h) coupon dates, on which the issuer pays the coupon to the securities’ holders;  
(i) the issue price, redemption price, and co upon rate may be denominated (or settled) in either 
national currency or foreign currencies.  
The credit rating of debt securities, which indicates the creditworthiness of individual debt 
securities issues, is assigned by recognised agencies on the basis of  rating categories.  
With regard to point (c), the maturity date may coincide with the conversion of a debt security into a 
share. In this context, convertibility means that the holder may exchange a debt security for the 
issuer’s common equity. Exchangeabi lity means that the holder may exchange the debt security for 
shares of a corporation other than the issuer. Perpetual securities, which have no stated maturity 
date, are classified as debt securities.  
1a. Short -term debt 
securities (F.31)  Debt securities  whose original maturity is one year or less, and debt securities repayable on 
demand of the creditor.  
1b. Long -term debt 
securities (F.32)  Debt securities whose original maturity is more than one year, or of no stated maturity.  
2. Equity (F.51)  Equity i s a financial asset that is a claim on the residual value of a corporation, after all other 
claims have been met. Ownership of equity in legal entities is usually evidenced by shares, stocks, 
depository receipts, participations, or similar documents. Share s and stocks have the same 
meaning.  
Equity is sub -categorised into the following: listed shares (F.511); unlisted shares (F.512); and 
other equity (F.519).  
2a. Listed shares (F.511)  Listed shares are equity securities listed on an exchange. Such an exchange may be a recognised 
stock exchange or any other form of secondary market. Listed shares are also referred to as 
quoted shares. The existence of quoted prices of shares listed on an exchange means that current 
market prices are usually readily avai lable.  
3. Investment fund shares or 
units (F.52)  Investment fund shares are shares of an investment fund if the fund has a corporate structure. 
They are known as units if the fund is a trust. Investment funds are collective investment 
undertakings through  which investors pool funds for investment in financial and/or non -financial 
assets.  
Investment fund shares are subdivided into: money market fund (MMF) shares or units (F.521); 
and non -MMF investment fund shares or units (F.522).  
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  8 4 General reporting requir ements  
4.1 Frequency  and timeliness  
Quarterly data collection  
In accordance with Article 3a(1) of the SHS Regulation, group data reporting agents 
must, on a quarterly basis, provide the relevant NCB with security -by-security data 
on the end -quarter positions of securities.  
Timeliness to be specified by the NCBs to meet requirements for 
transmission to SHSDB  
The NCBs are to decide by when they need to receive data from actual reporting 
agents to be able to perform the necessary quality control procedures and t o meet 
the deadlines for transmission to the securities holdings statistics database 
(SHSDB), as laid down in Article 6b of the SHS Regulation. The deadlines for the 
transmission from the NCBs to SHSDB are specified in Articles 3a(2) and 4b(2) of 
the ECB G uideline concerning SHS.  
4.2 Level of re porting  
Reporting at the level of group or legal entity  
As defined for each attribute separately in the Annex to the SHS Regulation, the data 
has to be reported either on a group or an entity -by-entity basis:  
 Group basis means that the data refers to information of the banking 
group as a whole . This applies in particular to those attributes that are 
uniquely defined for the group and, therefore, do not need to be collected for 
each entity separately.  
 Entity -by-entit y basis means that the reported data refers to each 
individual legal entity of a banking group , i.e. the head of the group and 
each subsidiary of the group separately. This is particularly the case for 
amounts (such as holding amount at market value), whic h should always be 
available with regard to each individual holding entity, or for attributes that are 
uniquely defined for the individual entity only. Please see the examples below 
for additional clarification, and the following sub -section for more infor mation on 
what is required by the accounting rules underlying the reporting.  
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  9 A separate reporting on individual level is required for significant supervised euro 
area branch es of credit institution s established in a non-participating Member 
State  as defined in point 20 of Article 2 of Regulation (EU) No 468/2014 . 
Accordingly, such significant supervised  branch es that are included in the reporting 
population have to fulfil the reporting requirements as specified for group data 
reporting agents . This applies to all su bsequent parts of this document.  
Holdings of branches to be reported together with related legal 
entity as single holding information  
Holdings of (domestic and foreign) branches  have to be reported together with 
the subsidiary to which t hey belong as single holding information of the 
subsidiary . In this respect, a branch is defined, in accordance with point 17 of Article 
4.1 of Regulation (EU) No 575/2013, as a place of business which forms a legally 
dependent part of an institution and w hich carries out directly all or some of the 
transactions inherent in the business of institutions. Where there is more than one 
subsidiary (legal entity) in the same country, such subsidiaries are regarded as 
separate entities for the reporting. Please se e the example below for additional 
clarification.  
Example:  
Separate reporting per legal entity  
Reporting group ABC consists of the head of the group and two subsidiaries. These three entities 
are legal entities.  
Reporting obligations:  
 The security holding s have to be reported separately for each legal entity, i.e. for a) the head 
of the group, b) subsidiary 1 and c) subsidiary 2.  
 This holds irrespective of whether subsidiaries 1 and 2 are domestic or foreign entities, i.e. 
even if both subsidiaries are loc ated in the same country or in the country of the head of group, 
their holdings have to be reported separately.  
 
Head of group
(Domestic or foreign) 
subsidiary 1(Domestic or foreign) 
subsidiary 2
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  10 Example:   
Reporting of branches together with related legal entity  
Reporting group ABC consists of the head of the group, one subsidiary and one branch; the branch 
belongs to the subsidiary  and is not a significant supervised branch of a credit institution 
established in a non -participating Member State . While the head and the subsidiary are legal 
entities, the branch is not.  
Reporting obligat ions:  
 The security holdings of the head of the group and the subsidiary have to be reported 
separately.  
 The h oldings of the branch have to be reported together with the subsidiary to which it belongs 
as single holding information of the subsidiary.  
 This holds irrespective of whether the branch is a domestic or foreign branch, i.e. even if the 
subsidiary is located in a country different from that where the branch is located, their holdings 
have to be reported together.  
 If the branch were to belong to the he ad of the group, the requirements described above with 
regard to the subsidiary would also apply in the same way to the head of the group.  
 
4.3 Accounting rules for the reporting  
Application of harmonised accounting and risk calculation 
principles  
Group accounting policies should be applied, in agreement with the relevant NCB, to 
the data reported at group level and on an entity -by-entity basis, i.e. data 
reported at entity level should follow the accounting rules of the group to the 
extent possible . The same logic should also be applied to risk -related data 
regarding the approach for prudential purposes, i.e. data reported at entity level  
Head of group
(Domestic or foreign) 
subsidiary
(Domestic or foreign)
branch
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  11 should follow the approach for prudential purposes of the group to the extent 
possible . Please see below the num eric example for the SHSG reporting with 
regard to the application of harmonised accounting and risk calculation principles.  
Overall, the aim within the extended SHSG reporting is to collect security -by-
security information at legal entity level that can be used to reconcile the 
relevant (aggregated) consolidated financial reporting framework (FINREP) 
and common reporting framework (COREP) data . Accordingly, for each reporting 
banking group, harmonised accounting and risk calculation principles should be 
applied, preferably in accordance with the standards and principles of the group.  
If, at group level, the bank follows national accounting standards (nGAAP) as 
the main accounting policy instead of international financial reporting 
standards (IFRS) , the SHS G data provided for the foreign legal entities should also 
be based on the nGAAP of the group, corresponding to the head of the group (and 
not on the nGAAP of the foreign legal entity), to ensure a consistent and 
comprehensive data set.  
Even if the standar ds and approaches used at individual and consolidated level are 
the same, the value for the attributes at individual and consolidated level may 
change (e.g. in the case of the application of the IFRS 3 acquisition method). In such 
cases, the SHSG reporting  should be based on the values applied for the 
consolidated statements . 
Where individual financial statements are not always in line with the group approach, 
it might be possible to derive the data from homogenised entity statements  (i.e. 
individual statem ents that have already been harmonised as part of the consolidation 
process by taking into account the principles of the group).  
Only in cases where the accounting and risk -related data are not by any means 
available in accordance with the harmonised group  approach  can different 
principles based on the individual statements be used for the SHSG reporting at 
entity level, in agreement with the relevant NCB.  
Example:   
Application of harmonised accounting and risk calculation principles  
Reporting group ABC inc ludes three entities; the three entities hold a certain number of securities 
under the same ISIN.  
1) Individual statements  
It is assumed that the group as a whole follows IFRS  as the accounting standard for the 
consolidated statements. The prudential appro ach at group level for this security is the 
standardised approach . The applied accounting and risk calculation principles might differ at entity 
level. At individual entity level, they have individual FINREP and COREP statements with the figures 
shown belo w (any differences from the group approach at individual level are marked in 
bold ): 
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  12 2) Consolidated statements  
In order to generate the consolidated FINREP and COREP statements, the banking group has to 
follow the different steps of the consolidation process, starting normally with the individual figures. 
The final result is the consolidated statements, which are reported as c onsolidated FINREP and 
COREP. It should be noted that key attributes (such as “accounting classification of instruments” or 
“prudential portfolio”) might still be different for the same instrument and the same legal entity within 
a group at consolidated le vel and, accordingly, need to be reported separately. This applies also to 
the prudential approach that might be different for the same holding entity and instrument.  
Assuming that the group uses IFRS and the standardised approach, the figures after the 
consolidation process will be as shown below ( changes compared with individual data are 
marked in bold ). Obviously, in the consolidated statements, there is no breakdown by entity. The 
information shown here is for illustrative purposes only.  
3) SHSG reporting  
The SHSG reporting should be conducted at legal entity level in accordance with accounting and 
risk calculation principles of the group, i.e. the data of the consolidated statements as shown above. Individual data  Entity A  Entity B  Entity C  
Nominal value or number of 
securities held  120 60 50 
Accounting classification of 
instruments  nGAAP:  Non-trading non -
derivative  financial assets 
measured at a cost -based 
method  IFRS: Financial assets at amortised 
cost IFRS: Financial assets held for 
trading  
Prudential portfolio  Non-trading book  Non-trading book  Trading book  
Sources of encumbrance  Unencumbered/  
No encumbrance  Unencumbered/  
No encumbrance  Unencumbered/  
No encumbrance  
Type of impairment  General allowances (GAAP)  Stage 1 (IFRS)  Not applicable  
Impairment assessment method  Individually assessed  Individually assessed  Not applicable  
Approach for prudential purposes  IRB: Advanced approach  IRB: Advanced approach  Not applicable  
Exposure class  IRB: Exposures to institutions  IRB: Exposures to institutions  Not applicable  
Carrying amount  900 550 500 
Exposure value  1000  600 - 
Consolidated d ata  Holdings from A  Holdings from B  Holdings from C  
Nominal value or number of 
securities held  120 60 50 
Accounting classification of 
instruments  IFRS: Financial assets at amortised 
cost IFRS: Financial assets at amortised 
cost IFRS: Financial assets held for 
trading  
Prudential portfolio  Non-trading book  Non-trading book  Trading book  
Sources of encumbrance  Unencumbered/No encumbrance  Unencumbered/No encumbrance  Unencumbered/No encumbrance  
Type of impairment  Stage 1 (IFRS)  Stage 1 (IFRS)  Not applicable  
Impairment assessment method  Individually assessed  Individually assessed  Not applicable  
Approach for prudential purposes  Standardised approach  
 Standardised approach  
 Not applicable  
Exposure class  SA (standardised approach): 
Exposures to institutions and 
corporates with a short -term credit 
assessment  SA (standardised approach): 
Exposures to institutions and 
corporates with a short -term credit 
assessment  Not applicable  
Carrying amount  1100  550 500 
Exposure value  1200  600 - 
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  13 It should be noted that only a subset of the att ributes of the SHSG reporting is shown below, for 
illustrative purposes only.  
 
Intra-group holdings to be included  
According to the reporting requirements, all holdings should be reported on a gross 
basis, without netting out from the group holdings the securities issued by entities of 
the same group, i.e. intra -group positions must always be reported . In this 
regard, it should be clarified that this also covers (pure) “own” holdings , i.e. 
holdings by a legal entity of securities issued by the legal entity itself. “Own” holdings 
have to be reported 1) if the position had previously been sold to another holder 
(even if w ithin the same banking group) and bought back by the issuer afterwards  or 
2) for securities effectively issued but retained by the original issuer at issuance as 
own holdings . Securities are considered as effectively issued (even if they have not 
been sold  to another holder) when they are actually used by the issuer for market 
operations (e.g. as collateral or in repo operations  including the usage of own 
securities eligible as ECB collateral ) or when they are recorded in the balance sheet.   
As specified ab ove, it would be preferable for the SHSG reporting to follow the 
accounting rules of the group. In this case, data on accounting and risk -related 
attributes might not be available, as intra -group positions do not appear in the 
consolidated accounts. Accord ingly, the accounting and risk -related attributes 
may not be reported to SHSG for intra -group positions (in accordance with the 
prudential scope), subject to the discretion of the NCBs .3 Conversely, the other 
                                                                    
3  This possible separate treatment regarding intra -group positions  applies to the accounting and risk -
related attributes listed as follows: “status of forbearance and renegotiation (and date)”, “performing 
status of the instrument (and date)”, “default status of the issuer (and date)”, “default status of the 
instrument ( and date)”, “probability of default of the issuer”, “loss given default in downturns/in normal 
economic times”, “risk weight”, “accounting classification of instruments”, “prudential portfolio”, “source 
of encumbrance”, “type of impairment”, “impairment as sessment method”, “approach for prudential 
purposes”, “exposure class”, “carrying amount”, “accumulated impairment amount”, “accumulated 
changes in fair value due to credit risk”, “cumulative recoveries since default” and “exposure value”.  Entity 
ID Accounting  
classification 
of instruments  Prudential  
portfolio  Sources of  
encumbrance  Type of  
impairment  Impairment  
assessment  
method  Approach 
for 
prudential  
purposes  Exposure class  Carrying 
amount  Exposure 
value  
A IFRS: Financial 
assets at 
amortised cost  Non-trading 
book  Unencum bered/  
No 
encum brance  Stage 1 
(IFRS)  Individually 
assessed  Standardised 
approach  SA (standardised 
approach): 
Exposures to 
institutions and 
corporates with a 
short -term credit 
assessment  1100  1200  
B IFRS: Financial 
assets at 
amortised cost  Non-trading 
book  Unencum bered/  
No 
encum brance  Stage 1 
(IFRS)  Individually 
assessed  Standardised 
approach  SA (standardised 
approach): 
Exposures to 
institutions  and 
corporates with a 
short -term credit 
assessment  550 600 
C IFRS: Financial 
assets held for 
trading  Trading book  Unencum bered/  
No 
encum brance  Not 
applic able Not 
applicable  Not 
applicable  Not applicable  500 - 
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  14 information required for the SHSG reporting, in  particular holding amounts at market 
and/or nominal values, has to be provided for intra -group positions.  
Treatment of retained securitisations  
Where assets, such as loans or securities, are securitised (e.g. sold to a financial 
vehicle corporation (FVC )), securities issued by these vehicles might be held by the 
originator of the securitisation (self - or retained securitisation). Such security 
holdings, including covered bonds and other similar asset types, have to be 
included in the SHSG reporting  in ac cordance with Article  1(16) of the SHS 
Regulation, which clarifies that security holdings refer to the economic ownership of 
securities. As these security holdings are also intra -group positions, the guidance for 
intra-group holdings, as defined above, als o applies to retained securitisations 
regarding the SHSG reporting requirements for accounting and risk -related 
attributes.  
Holdings of securities, where issuer is in liquidation, to be included  
Security holdings have to be included in the SHSG reporting  for as long as a 
claim of the holder against the issuer exists . This also applies to matured 
securities (i.e. after the maturity date) where the issuer is in an ongoing liquidation 
process. Holdings of such securities have to be reported until the liquida tion has 
been finally settled.  
Treatment of repurchase transactions  
In accordance with Article 5b(2) of the SHS Regulation, holdings of securities lent out 
under securities lending operations, or sold under repurchase agreements (repos), 
must be recorded as holdings by the original owner, and not as holdings of the party 
temporarily acquiring them, where there is a firm commitment to reverse the 
operation , as opposed to an option to do so. The treatment outlined above should 
be applied regardless of the gr oup accounting policy , in accordance with the 
SHS Regulation. Attribute -specific exceptions are not foreseen.  
Negative holdings to be reported in the case of reverse repos/short 
selling  
Where the party  temporarily acquiring the securities sells them, suc h a sale must be 
recorded as an outright transaction in securities and reported, by the party 
temporarily acquiring them, as a negative position  in the relevant securities 
portfolio. Similar to intra -group positions, accounting and risk -related attributes might 
not be available for “pure” short positions (i.e. those where no positive amount is 
held and recorded on the asset side), as they are recorded on the liability side. 
 
Guidance notes to reporting agents on  SHS regulation  − General reporting requirements  15 Accordingly, the accounting and risk -related attributes relating to “pure” short 
positions do not have to be included in the SHSG reporting, subject to the 
discretion of the NCBs . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  16 5 Reported attributes  
The data to be provided within the SHSG data reporting includes the following main 
components:  
 SHSG holder information data – holder referen ce information  
 SHSG holdings data – holdings of ISIN and non -ISIN securities  
 attributes at group level  
 attributes at entity level  
 SHSG holdings data – holdings of non -ISIN securities  
 additional instrument and issuer reference attributes.  
Overall, for  accou nting and risk -related attributes, the SHSG data collection primarily 
follows the requirements set out by the supervisory reporting for those attributes. 
This covers in particular definitions and classifications, but also the applicability 
regarding specif ic accounting classifications and asset types. Please refer to the 
subsections of the relevant attributes below for more detailed information.  
5.1 Holder reference information  
With regard to the holder reference information, only a limited set of basic data  is 
collected to ensure (i) the provision of a minimum set of reference information, (ii) the 
unique identification of the holders as well as (iii) the interlinkage with other data 
sets. Reporting agents are encouraged to use the same identifiers as those rep orted 
in the context of the collection of granular credit and credit risk data (AnaCredit).  
Reference information at legal entity level t o be provided  
Holder reference information for each individual legal entity of a banking group (i.e. 
the head of the gr oup and each subsidiary of the group separately) has to be 
reported. Conversely, reference data on (domestic and foreign) branches should 
not be reported , since their holdings are meant to be collected together with the 
subsidiary to which they belong as p art of the single holding information of the 
subsidiary.  The reference information has to be provided in the case of significant 
supervised branches of credit institutions established in non -participating Member 
States.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  17 Data on all entities required to com plete group structure 
information for secu rities holdings  
Reporting agents  are also encouraged to provide reference information on group 
entities that do not hold securities, if those group entities own subsidiaries that 
themselves are security holders. Th is aims to ensure the availability of complete 
information on the group entities relevant for SHSG data purposes . Please see 
the example below for additional clarification. For the sake of simplicity, reporting 
agents may also provide their full group stru cture at legal entity level (without 
restriction to entities that hold securities) , in agreement with the relevant NCB.  
Example : 
Reporting of intermediate legal entity levels that do not hold securities  
Reporting group ABC consists of the head of the group, subsidiary 1 and subsidiary 2; subsidiary 2 
is owned by subsidiary 1. Securities are held by the head of the group and subsidi ary 2, but not by 
subsidiary 1.  
Reporting obligations:  
 In order to complete the group structure information relevant for se curities holdings, the 
reporting agents are encouraged to provide reference information on all legal entity levels up 
to the lowest level of security holdings.  
 This also includes subsidiaries that do not hold any securities but that are nevertheless the 
parent of a subsidiary or branch that does  hold securities.  
 This holds irrespective of the country of location of the head of the group and both 
subsidiaries.  
 For the sake of simplicity, reporting agents may also provide their full group structure at legal 
entity level (without restriction to entities that hold securities), in agreement with the relevant 
NCB.  
  
Head of group
(Domestic or foreign) 
subsidiary 2Reference data on 
subsidiary 1 (which does 
not hold securities ) to be 
provided to complete 
group structure 
information(Domestic or foreign) 
subsidiary 1
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  18 5.1.1  Holder identifier code  
Use 
Mandatory . 
Description  
A standard code, agreed with the relevant NCB, that uniquely identifies the holder 
and information  on the identifier type of code used, e.g. EU identifier or national 
identifier . 
Additional clarifications  
The reporting group as well as each relevant legal entity of the group (including the 
head of the group) should be uniquely identified.  
An EU identi fier means a commonly used identification code, agreed with the 
relevant NCB, which enables the unambiguous identification of any entity within the 
European Union.  
National identifier means a commonly used identification code, agreed with the 
relevant NCB,  which enables the unambiguous identification of any entity within its 
country of residency.  
Moreover, the type of identifier that is used as a holder identifier code should be 
specified as a separate variable. This would indicate which type of identifier,  such as 
a tax number, has been used. The same identifier type should be used for an entity 
reported in the different attributes “holder identifier code”, “identifier code of the 
immediate parent of the holder”, “guarantor identifier code” and “issuer iden tifier 
code”.  
5.1.2  LEI of the holder  
Use 
Mandatory . 
Description  
Legal Entity Identifier (LEI), in line with International Organization for Standardization 
(ISO) 17442, of the holder . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  19 Description  
The LEI of each relevant legal entity of the group (including the  head of the group) is 
to be reported.  
In addition, for the reporting group, the LEI of the group should be used, where 
available. If the LEI of the group is not available, it should be the LEI of the 
respective head of the group.  
5.1.3  Name of the holder  
Use 
Mandatory . 
Description  
Full legal name of the holder . 
Additional clarifications  
The name of each relevant legal entity of the group (including the head of the group) 
is to be reported.  
It should be noted that, with regard to the reporting group, the name of the reporting 
group, and not the name of the head of the reporting group, should be used.  
5.1.4  Country of the holder  
Use 
Mandatory . 
Description  
Country of legal incorporation of the holder . 
Additional clarifications  
The country of legal incorporation of each re levant legal entity of the group (including 
the head of the group) has to be reported.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  20 5.1.5  Sector of the holder  
Use 
Mandatory . 
Description  
Institutional sector of the group data reporting agent according to ESA 2010 and 
Regulation (EU) No 1011/2012 (ECB/2012/2 4). 
Additional clarifications  
The institutional sector of each relevant legal entity of the group (including the head 
of the group) has to be reported.  
It should be noted that the head of group is not necessarily a credit institution 
according to the definition laid down in Article 1(10) of the SHS Regulation: this 
applies, for example, where a financial holding company is acting as the head of 
banking group.  
5.1.6  Accounting standard of the holder  
Use 
Mandatory . 
Description  
Accounting standard used within the SHSG reporting for (i) each group as a whole 
and (ii) each individual legal entity of the group . 
Additional clarifications  
With regard to the reporting group, this is the accounting standard that is used for the 
reporting of attributes on a group basis .  
With regard to the relevant legal entities, this is the accounting standard that is used 
by the legal entity for the reporting of attributes on an entity -by-entity basis. 
Harmonised group accounting policies should be applied to the data reported for 
each entity of the group to the extent possible, in agreement with the relevant NCB.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  21 5.1.7  Identifier code of the immediate parent of the holder  
Use 
Mandatory . 
Description  
A standard code, agreed with the relevant NCB, that uniquely identifies the 
immediate parent  of the holder and information on the identifier type of the code that 
is used, e.g. an EU identifier or national identifier . 
Additional clarifications  
The immediate parent to be identified in the reporting has to be the legal entity 
owning the legal entit y that holds securities. In case the immediate parent is not a 
legal entity (and is therefore a branch)  and it is not a significant supervised branch of 
a credit institution established in a non -participating Member State , the legal entity to 
which the bra nch belongs has to be provided. Please see the example below 
regarding the treatment of immediate parents that are not legal entities.  
If the security -holding legal entity has no immediate parent (i.e. it is the head of the 
group), the identifier for the l egal entity itself is to be reported.  
In general, the entity that is used for consolidation purposes must be reported as the 
immediate parent. In cases where several entities hold equal shares of a subsidiary 
(e.g. two entities with a 50% share), the repor ting agent can determine, for the 
purposes of reporting, one of these parents as the immediate parent, in agreement 
with the relevant NCB. The selected immediate parent must be used consistently 
over time for the reporting.  
Moreover, the type of identifier  that is used as the identifier code should be specified 
as a separate variable, e.g. a national identifier, such as a tax number. The same 
identifier type should be used for an entity reported in the different attributes “holder 
identifier code”, “identif ier code of the immediate parent of the holder”, “guarantor 
identifier code” and “issuer identifier code”.  
An EU identifier means a commonly used identification code, agreed with the 
relevant NCB, which enables the unambiguous identification of any entity within the 
European Union.  
National identifier means a commonly used identification code, agreed with the 
relevant NCB, which enables the unambiguous identification of any entity within its 
country of residency.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  22 Example  
Treatment of immediate parents that are not legal entities  
Reporting group ABC consists of the head of group X, branch Y and subsidiary Z; subsidiary Z 
belongs to branch Y. The head of the group and the subsidiary are legal entities, but the branch is 
not and it is not a significant supervis ed branch of a credit institution established in a non -
participating Member State .  
Reporting obligations:  
 As the level of legal entity is the lowest level of granularity for the SHSG data collection, the 
immediate parent reported for the subsidiary has to  be the head of the group and not the 
branch.  
 This holds irrespective of the country of location of the head of th e group, subsidiary and 
branch.  
 
5.2 Holdings of ISIN and non -ISIN securities (attributes at 
group level)  
Information on the instruments that ar e defined for each group  
The set of attributes listed in this section is called “attributes at group level”, because 
they are defined for entire groups (and not entity by entity). This also stands in 
contrast to “pure” instrument reference attributes that  are unique to all groups, e.g. 
maturity date.   
Head of group
(Domestic or foreign) 
subsidiary(Domestic or foreign) 
branchImmediate parent of 
the subsidiary at the 
level of legal entity to 
be provided
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  23 5.2.1  ISIN code  
Use 
Mandatory . 
Description  
ISIN code that ha s been assigned to the security.  
Additional clarifications  
The “ISIN code” means the International Securities Identification Number assigned to 
securities, composed of 12 alphanumeric characters and which uniquely identifies a 
securities issue (as defined by ISO 6166).  
5.2.2  Issuer is part of the group (prudential scope)  
Use 
Mandatory, subject to the discretion of the NCBs . 
Description  
Indicates whether  the security was issued by an entity of the same reporting group in 
line with the prudential scope of consolidation . 
Additional clarifications  
According to the reporting requirements, all holdings should be reported on a gross 
basis, without netting out f rom the group holdings the securities issued  by entities of 
the same group.  
In addition, it should be clarified that not only intra -group holdings are to be flagged 
by this variable, but also (pure) “own” holdings, i.e. holdings by a legal entity of 
securi ties it has issued itself.  
Prudential scope of consolidation refers to the consolidation scope, as defined in 
Chapter 2 of Title II of Part One of Regulation (EU) No 575/2013.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  24 5.2.3  Issuer is part of the group (accounting scope)  
Use 
Mandatory . 
Description  
Indicates whether the security was issued by an entity of the same reporting group in 
line with the accounting scope of consolidation . 
Additional clarifications  
According to the reporting requirements, all holdings should be reported on a gross 
basis, with out netting out from the group holdings the securities issued by entities of 
the same group.  
In addition, it should be clarified that not only intra -group holdings are to be flagged 
by this variable, but also (pure) “own” holdings, i.e. holdings by a lega l entity of 
securities it has issued itself.  
Accounting scope of consolidation refers to the scope of the consolidation for 
financial reporting according to IFRS, as defined in Article 2 of Regulation (EC) No 
1606/2002 of the European Parliament and of the  Council, or, if not applicable, any 
other national or international standards that apply to the actual reporting agents.  
5.2.4  Status of forbearance and renegotiation  
Use 
Mandatory . 
Description  
Identification of forborne and renegotiated instruments . 
Additional  clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  25 If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity and investment fund shares or units  the attribute is not 
applicable, it should be flagged and reported accordingly.  
Specifically, the attribute i dentifies (i) instruments forborne in accordance with 
Implementing Regulation (EU) No 680/2014 and (ii) instruments which are not 
forborne in accordance with Implementing Regulation (EU) No 680/2014 but are 
otherwise renegotiated according to Regulation (E C) No 290/2009.  
The value reported represents the latest status of the instrument at the reporting 
reference date, since the status of an instrument may change over the course of its 
life. The forbearance status may also change back to not forborne or rene gotiated.  
It should be clarified that this attribute is defined at instrument level, i.e. the status 
can vary for different securities of the same issuer.  
According to Annex V to Implementing Regulation (EU) No 680/2014, for the 
purposes of Annexes III and  IV, Template 19 (Information forborne exposures) 
forborne exposures are debt contracts in respect of which forbearance measures 
have been extended. Forbearance measures according to Annex V to Implementing 
Regulation (EU) No 680/2014 consist of concession s towards a debtor facing or 
about to face difficulties in meeting its financial commitments (“financial difficulties”).  
For details concerning concessions, see Annex V to Implementing Regulation (EU) 
No 680/2014.  
For details of when an exposure must be t reated as forborne, see Annex V to 
Implementing Regulation (EU) No 680/2014. Moreover, Annex V to Implementing 
Regulation (EU) No 680/2014 states that a modification involving repayments made 
by taking possession of collateral is to be treated as a forbear ance measure when 
the modification constitutes a concession.  
Instruments which are not subject to forbearance but whose financial conditions 
have been otherwise modified must be reported as a “renegotiated instrument 
without forbearance measures”.  
Instrum ents which are not forborne or renegotiated should also be flagged and 
reported accordingly.  
If the instrument is reported as forborne or renegotiated, the attribute “date of the 
forbearance and renegotiation status” must be reported indicating the date on  which 
the indicated status is considered to have occurred.  
5.2.5  Date of the forbearance and renegotiation status  
Use 
Mandatory . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  26 Description  
Date on which a forbearance or renegotiation status as reported under “status of 
forbearance and renegotiation” is considered to have occurred . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity and investment fund shares or units the attribute is not 
applicable, it should be flagged and reported acc ordingly.  
If the instrument is reported as forborne or renegotiated, the attribute “date of the 
forbearance and renegotiation status” must be reported, indicating the date on which 
the indicated status is considered to have occurred.  
By contrast, if the in strument is not forborne or renegotiated at the reporting 
reference date, the relevant NCB may dispense with the requirement to fill the 
attribute. If the relevant NCB decides that the attribute is always to be reported:  
 the issue date of the security is t o be provided, if the instrument has never been 
forborne or renegotiated;  
 as regards instruments that had been classified as forborne or renegotiated, but 
changed back to not forborne or renegotiated before the reference date of the 
reporting, the date on which the instrument is considered to have changed back 
to not forborne or renegotiated is reported.  
5.2.6  Performing status of the instrument  
Use 
Mandatory . 
Description  
Identification of non -performing instruments in accordance with Commission 
Implementing Regu lation (EU) No 680/2014 . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  27 Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subj ect to the discretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity and investment fund shares or units the attribute is not 
applicable, it should be flagged and reported accordi ngly. 
Instruments must be reported with the value used for its classification in FINREP 
template 18. For further details regarding the classification as non -performing, see 
Part 2 of Annex V to Implementing Regulation (EU) No 680/2014.  
If the instrument is  reported as non -performing, the attribute “date of the performing 
status of the instrument” must be reported, indicating the date on which the non -
performing status is considered to have been established.  
5.2.7  Date of the performing status of the instrument  
Use 
Mandatory . 
Description  
Date on which the performing status as reported in “performing status of the 
instrument” is considered to have been established or changed . 
Additional clarifications  
This attribute may not be required for the reporting of intra-group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments held  for trading) 
or in the case of equity and investment fund shares or units the attribute is not 
applicable, it should be flagged and reported accordingly.  
If the instrument is reported as non -performing, the attribute “date of the performing 
status of the instrument” must be reported indicating the date on which the non -
performing status is considered to have been established.  In case of more than one 
date for the non -performing status, the most recent date has to be reported. This 
means, for example, if the instrument changes to non -performing on 2017 -01-15 for 
the first time, afterwards reverting back to performing and changi ng again to non -
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  28 performing on 2017 -03-15, the date when the most recent non -performing period has 
started is to be reported, i.e. non -performing with date 2017 -03-15. 
By contrast, if the instrument is performing at the reporting reference date, the 
relevan t NCB may dispense with the requirement to fill the attribute. If the relevant 
NCB decides that the attribute is always to be reported:  
 the issue date of the security is to be provided, if the instrument has never been 
non-performing;  
 as regards instrument s that had been classified as non -performing, but 
changed back to performing before the reference date of the reporting, the date 
on which the instrument is considered to have changed back to performing is to 
be reported.  
5.2.8  Default status of the issuer  
Use 
Mandatory . 
Description  
Identification of the default status of the issuer in accordance with Article 178 of 
Regulation (EU) No 575/2013 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope ) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity  and investment fund shares or units the attribute is not 
applicable, it should be flagged and reported accordingly.  
It should be reported whether the issuer is in default or not at the reporting reference 
date.  
If the issuer is in default, a further brea kdown has to be provided to indicate whether 
the default is because:  
 the issuer is considered unlikely to pay, as specified in Article 178(1)(a) of 
Regulation (EU) No 575/2013, or  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  29  any debt is more than 90/180 days past due, as specified in Article 178(1)( b) of 
Regulation (EU) No 575/2013, or  
 both criteria above apply.  
The criteria to be applied for reporting this attribute must be the same as those used 
by the reporting agent for the supervisory reporting in accordance with the CRR.  
If the issuer was in de fault earlier, but not at the reporting reference date, the default 
status of the issuer must be reported as not in default.  
It should be noted that for one and the same default of an issuer (i.e. for the duration 
of default), the default status of the iss uer may change after the moment at which a 
default actually started (e.g. from unlikely to pay to 90 days past due or both).  
If the issuer is reported as in default, the attribute “date of the default status of the 
issuer” must be reported, indicating the  date on which the default status of the issuer 
is considered to have been established.  
5.2.9  Date of the default status of the issuer  
Use 
Mandatory . 
Description  
Date on which the default status as reported in the “default status of the issuer” 
came into effect or changed . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the di scretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity and investment fund shares or units the attribute is not 
applicable, it should be flagged and reported accordingly.  
If the issuer is reported as in default, the attribute “date of the default status of the 
issuer” must be reported, indicating the date on which the default status of the issuer 
is considered to have been established. However, the reported date should not be 
earlier than the corresponding issue date of the security.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  30 By contrast, if the issuer is reported as not in default on the reporting reference date, 
the relevant NCB may dispense with the requirement to fill the attribute. If the 
relevant NCB decides that the attribute is always to be reported:  
 the issue date of the security is to be provided, if the issuer has never been in 
default;  
 as regards issuers that had been classified as in default, but changed back to 
not in default before the reference date of the re porting, the date on which the 
status of the issuer is considered to have changed back to not in default is to be 
reported.  
5.2.10  Default status of the instrument  
Use 
Mandatory . 
Description  
Identification of the default status of the instrument in accordance wit h Article 178 of 
Regulation (EU) No 575/2013 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity and investment fund shares or units the attribute is not 
applicable, it should be flagged  and reported accordingly.  
The assessment of the default status at instrument level is only possible for retail 
exposures – as defined in the CRR – if the credit institution exercises the option 
provided by the last sentence of Article 178(1) of the CRR. I n all other cases, default 
is defined at the level of the issuer. In principle, retail exposures are not applicable to 
securities. Accordingly, the relevant NCB may dispense with the requirement to fill 
the attribute, as the information reported for the “d efault status of the issuer” is 
deemed sufficient.  
This attribute should be reported whether the instrument is in default or not at the 
reference date of the reporting (e.g. default status referring to the reference date at 
the end of the fourth quarter of  2018).  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  31 If the instrument is in default, a further breakdown has to be provided to indicate 
whether the default is because:  
 the issuer is considered unlikely to pay, as specified in Article 178(1)(a) of 
Regulation (EU) No 575/2013, but the instrument is n ot more than 90/180 days 
past due or  
 the instrument is more than 90/180 days past due, as specified in Article 
178(1)(b) of Regulation (EU) No 575/2013, but the issuer has not been 
classified as unlikely to pay or  
 both criteria above apply.  
The criteria t o be applied for reporting this data attribute must be the same as those 
used by the reporting agent for the supervisory reporting in accordance with the 
CRR.  
Please also note that the default status of the instrument may change after the 
moment at which a default actually started (e.g. from unlikely to pay to 90 days past 
due or both). In this connection, note that the data attribute “cumulative recoveries 
since default” is calculated from when the default status is considered to have begun 
– that is, all  recoveries are accounted for over the actual duration of a default (which 
spans the period between the moment the default actually started and the moment 
on which it ended, as opposed to when it was last updated).  
If the instrument is reported as in default, the attribute “date of the default status of 
the instrument” must be reported, indicating the date on which the default status of 
the instrument is considered to have been established.  
5.2.11  Date of the default status of the instrument  
Use 
Mandatory . 
Description  
Date on which the default status as reported in the “default status of the instrument” 
came into effect or changed . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pur e” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  32 If in accordance with the accounting standard (e.g. for instruments held for trading) 
or in the case of equity and inves tment fund shares or units the attribute is not 
applicable, it should be flagged and reported accordingly.  
If the instrument is reported as in default, the attribute “date of the default status of 
the instrument” must be reported indicating the date on whi ch the default status of 
the instrument is considered to have been established. However, the reported date 
should not be earlier than the corresponding issue date of the security.  
By contrast, if the instrument is reported as not in default on the reportin g reference 
date, the relevant NCB may dispense with the requirement to fill the attribute. If the 
relevant NCB decides that the attribute is always to be reported:  
 the issue date of the security has to be provided, if the instrument has never 
been in defa ult; 
 as regards instruments that had been classified as in default, but changed back 
to not in default before the reference date of the reporting, the date on which 
the instrument is considered to have changed back to not in default is to be 
reported.  
5.2.12  Prob ability of default of the issuer  
Use 
To be reported, if in accordance with the approach for prudential purposes the 
availability of the attribute is required  and the holding belongs to a banking book 
position , or if the data is available by other means . 
Description  
Issuer’s probability of default (PD) over one year determined in accordance with 
Articles 160, 163, 179 and 180 of Regulation (EU) No 575/2013 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdin gs (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
The issuer is considered to be in default where:  
 the issuer is considered unlikely to pay,  as specified in Article 178(1)(a) of 
Regulation (EU) No 575/2013 or  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  33  any debt is more than 90/180 days past due, as specified in Article 178(1)(b) of 
Regulation (EU) No 575/2013.  
The PD calculation is determined in accordance with the requirements specifi c to PD 
estimation, as laid down in the CRR.  
The attribute has to be reported in the case of banking book positions (also called 
non-trading book in the prudential portfolio) or if the data is available by other means.  
The same PD has to be reported for al l securities held by one reporting group and 
issued by the same issuer. Where more than one PD is available within the reporting 
group (e.g. owing to differing calculation methods at individual legal entity level), a 
single PD needs to be determined for th e reporting based on the practice at group 
level to the extent possible and excluding the potential impact of (partial) guarantees 
and similar activities.  
5.2.13  Loss given default in downturns  
Use 
To be reported, if in accordance with the approach for prudential  purposes the 
availability of the attribute is required  and the holding belongs to a banking book 
position , or if the data is available by other means . 
Description  
Ratio of the amount that could be lost on an exposure during economic downturns 
owing to a d efault over a one -year period to the amount that would be outstanding at 
default, in accordance with Article 181 of Regulation (EU) No 575/2013 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudent ial 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
Loss given default (LGD) values for each individual security have to be reported if 
the Internal Rati ngs Based ( IRB) approach for regulatory capital calculation is 
applied  (unless the attribute is not required for the supervisory reporting)  or if the 
data is available by other means.  
Own LGD estimates should be reported, as defined in Article 181 of Regul ation (EU) 
No 575/2013.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  34 Where own LGD estimates are not available, the fixed LGD values set out in Article 
161(1) of Regulation (EU) No 575/2013 should be used for the reporting.  
If neither own LGD estimates nor fixed LGD values are available, then infor mation on 
the risk weight should be provided via the dedicated attribute.  
LGDs in downturns are defined in accordance with Article 181(1)(b) of Regulation 
(EU) No 575/2013, where institutions must estimate LGDs that are appropriate for an 
economic downturn  if those are more conservative than the long­run average. The 
additional requirements set out in the subsequent paragraphs of Article 181 of 
Regulation (EU) No 575/2013 apply accordingly.  
The attribute has to be reported in the case of banking book positi ons (also called 
non-trading book in the prudential portfolio) or if the data is available by other means.  
5.2.14  Loss given default in normal economic times  
Use 
To be reported, if in accordance with the approach for prudential purposes the 
availability of the at tribute is required  and the holding belongs to a banking book 
position , or if the data is available by other means . 
Description  
Ratio of the amount that could be lost on an exposure in normal economic conditions 
owing to a default over a one -year period to  the amount that would be outstanding at 
default . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded  on the asset side), subject to the discretion of the NCBs.  
Loss given default (LGD) values for each individual security have to be reported if 
the IRB approach for regulatory capital calculation is applied  (unless the attribute is 
not required for the sup ervisory reporting)  or if the data is available by other means.  
Own LGD estimates should be reported, as defined in Article 181 of Regulation (EU) 
No 575/2013.  
Where own LGD estimates are not available, the fixed LGD values set out in Article 
161(1) of Reg ulation (EU) No 575/2013 should be used for the reporting.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  35 If neither own LGD estimates nor fixed LGD values are available, it is expected that 
information on the risk weight can be provided instead via the dedicated attribute.  
LGDs in normal economic tim es are defined in accordance with Article 181(1)(a) of 
Regulation (EU) No 575/2013, where institutions have to estimate LGDs by facility 
grade or pool on the basis of the average realised LGDs by facility grade or pool 
using all observed defaults within th e data sources (default weighted average). The 
additional requirements set out in the subsequent paragraphs of Article 181 of 
Regulation (EU) No 575/2013 apply accordingly.  
The attribute has to be reported in the case of banking book positions (also called  
non-trading book in the prudential portfolio) or if the data is available by other means.  
5.2.15  Risk weight  
Use 
To be reported, if in accordance with the approach for prudential purposes the 
availability of the attribute is required  and the holding belongs to a  banking book 
position , or if the data is available by other means . 
Description  
Risk weights associated with the exposure, in accordance with Regulation (EU) No 
575/2013 . 
Additional clarifications  
This attribute may not be required for the reporting of int ra-group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
Risk weights for each individual security have to be reported if the standa rdised 
approach for regulatory capital calculation is applied by the reporting group. Risk 
weights should be reported as defined in Section 2 of Chapter 2 of Title II of Part 
Three of Regulation (EU) No 575/2013.  
Where the IRB approach is applied by the r eporting group, the attribute has to be 
mandatorily provided if this is also required for supervisory reporting requirements, 
e.g. simple risk weight approach.  
The same risk weight has to be reported per instrument, including when it is held by 
different entities of the same reporting group. Where more than one risk weight is 
available within the reporting group (e.g. due to differing calculation methods at 
individual legal entity level), a single risk weight needs to be determined for the 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  36 reporting based on the practice at group level to the extent possible and excluding 
the potential impact of (partial) guarantees and similar activities.  
The attribute has to be reported in the case of banking book positions (also called 
non-trading book in the prudential portfolio) or if the data is available by other means.  
5.3 Holdings of ISIN and no n-ISIN securities (attributes at  
entity level)  
This section describes those attribu tes that are defined per individual holding record 
on an entity -by-entity basis. It applies to all reported amounts and to those attributes 
for which different entities might report different values for the same 
instrument . It should be noted that an entit y may in practice report several amounts 
or attributes for the same instrument, e.g. one holder could classify the same 
instrument into different prudential portfolios (banking and  trading book).  
5.3.1  Accounting classification of instruments  
Use 
Mandatory . 
Desc ription  
Accounting portfolio where the instrument is recorded in accordance with the  
accounting standard  applied by the reporting agent.  
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scop e) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
The attribute contains information about the accounting portfolio in which the 
instrument is classified in ac cordance with the accounting standard – IFRS or 
nGAAP – under Regulation (EU) 2015/534 of the European Central Bank 
(ECB/2015/13) applied by the reporting agent.  
Securities classified as “non -current assets and disposal groups classified as held for 
sale” in the IFRS framework (Finrep Template 1.1 Row 370) should be mapped to 
that category  in which they were included before becoming “held for sale”.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  37 The possible values of the attribute depend on whether the accounting standard 
applied is IFRS or nGAAP. Dep ending on the accounting standard, the values of 
other attributes (such as the carrying amount) may vary.  
The accounting classification is closely linked with the attributes regarding 
impairment and changes in fair value due to credit risk as well as the p rudential 
portfolio. The table below provides an overview over the possible combination of 
certain data attributes by the accounting classification of instruments . It should 
be noted that the table serves only as a general guideline and that exceptions may  
be possible in practice.  
Accounting classification of instruments  Impairment  Accumulated 
changes in fair 
value due to credit 
risk Prudential portfolio  
    
IFRS: Financial assets held for trading  Not possible  Possible  Trading book  
IFRS: Non-trading financial assets mandatorily at fair 
value through profit or loss  Not possible  Possible  Non-trading book  
IFRS: Financial assets designated at fair value through 
profit or loss  Not possible  Possible  Non-trading book  
IFRS: Financial assets at fair value th rough other 
comprehensive income  Possible  Not possible  Non-trading book  
IFRS: Financial assets at amortised cost  Possible  Not possible  Non-trading book  
nGAAP: Trading financial assets  Not possible  Possible  Trading book  
nGAAP: Non-trading non -derivative financial assets 
measured at fair value through profit or loss  Not possible  Possible  Non-trading book  
nGAAP: Non-trading non -derivative financial assets 
measured at fair value to equity  Possible  Possible  Non-trading book  
nGAAP: Non-trading  non-derivative financial assets 
measured at a cost -based method  Possible  Not possible  Non-trading book  
nGAAP: Other non -trading non -derivative financial 
assets  Possible  Not possible  Non-trading book  
nGAAP: Financial assets designated at fair value through 
profit or loss  Not possible  Possible  Non-trading book  
5.3.2  Prudential portfolio  
Use 
Mandatory . 
Description  
Classification of trading book and non -trading book exposures. Instruments in the 
trading book as defined in Article 4(1)(86) of Regulation (EU) No 575/2013 . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  38 Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the d iscretion of the NCBs.  
The value of this attribute depends on the actual classification of the instrument in 
the trading or in the non -trading book for capital ratio purposes and not on the type of 
instrument or the accounting classification of the instrum ent. 
Instruments in the trading book are all financial instruments held either with trading 
intent or in order to hedge positions held with trading intent.  
Generally, instruments classified as “financial assets held for trading” or “trading 
financial asset s” in accordance with the accounting standard will be held in the 
trading book; however, there may be exceptions, especially regarding nGAAP (e.g. 
in the case of financial derivatives).  
5.3.3  Sources of encumbrance  
Use 
Mandatory . 
Description  
Type of business activity in which the exposure is encumbered in accordance with 
Implementing Regulation (EU) No 680/2014. An asset will be treated as encumbered 
if it has been pledged or if it is subject to any form of arrangement to secure, 
collateralise or credit enhanc e any instrument from which it cannot be freely 
withdrawn . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and  
recorded on the asset side), subject to the discretion of the NCBs.  
This attribute identifies the type of business activity in which the exposure is 
encumbered in accordance with Annexes XVI and XVII of Implementing Regulation 
(EU) No 680/2014. An asset w ill be treated as encumbered if it has been pledged or 
if it is subject to any form of arrangement to secure, collateralise or credit enhance 
any instrument from which it cannot be freely withdrawn.  
 
Guidance notes to reporting agents on  SHS regulation  − Report ed attributes  39 Instruments pledged that are subject to any restrictions  in withdrawal, such as for 
instance assets that require prior approval before withdrawal or replacement by other 
assets, should be considered encumbered. Whether an instrument is “encumbered” 
is not based on an explicit legal criterion, such as title tran sfer, but rather on 
economic principles, as the legal frameworks may differ in this respect across 
countries. The definition is however closely linked to contractual conditions.  
Instruments that are only partially encumbered should be reported with the 
applicable source of encumbrance and the corresponding amount. The 
unencumbered part should be reported separately with the remaining amount that 
does not fall under the above definition of encumbrance. This means, for example, 
that if EUR 60 of a total holdi ng of EUR 100 is encumbered, it should be reported in 
two separate rows, one with EUR 60 encumbered, the other with EUR 40 not 
encumbered.  
If different accounting classifications apply for the same holding and there is a clear 
assignment of encumbered amo unts to accounting portfolios available, this data 
should be reported. If this information is not available or not assigned, the 
encumbered amount should be applied proportionally to the different accounting 
portfolios. This guidance should also be applied  in cases similar to the one described 
above on different accounting classifications.  
Instruments that are not subject to encumbrance at all should also be flagged and 
reported accordingly.  
5.3.4  Type of impairment  
Use 
Mandatory . 
Description  
The attribute indic ates the type of impairment the instrument is subject to. In 
addition, the attribute indicates if an instrument is not subject to impairment . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential  
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of NCBs.  
If in accordance with the accounting standard (e.g. for instruments measured or 
designated at fair value thr ough profit or loss under IFRS) or in the case of equity 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  40 and investment fund shares or units the instrument is not subject to impairment, it 
should be flagged and reported accordingly.  
The attribute applies to instruments subject to impairment under the ap plied 
accounting standard, even when the accumulated impairment amount is determined 
to be zero.  
Note that one holder might allocate different impairment types to the same 
instrument, for example if the instrument is purchased in tranches at different poi nts 
in time where the risk assessment has changed.  
Under IFRS, the impairment status may be either:  
1. Stage 1 (IFRS) : to be used if the instrument is not impaired and a loss 
allowance at an amount equal to 12 -month expected credit losses is raised 
against the instrument under IFRS;  
2. Stage 2 (IFRS) : to be used if the instrument is not impaired and a loss 
allowance at an amount equal to lifetime expected credit losses is raised 
against the instrument under IFRS;  
3. Stage 3 (IFRS) : to be used if the instrument is credit impaired . 
Under GAAP, the impairment relates to the following types:  
1. general allowances (GAAP) : to be used  if the instrument is subject to 
impairment in accordance with an applied accounting standard other than IFRS 
and no specific loss allowances are raised against the instrument (unimpaired);  
2. specific allowances (GAAP) : to be used if the instrument is subjec t to 
impairment in accordance with an applied accounting standard other than IFRS 
and specific loss allowances are raised, irrespective of whether these 
allowances are individually or collectively assessed (impaired).  
5.3.5  Approach for prudential purposes  
Use 
Mandatory . 
Description  
Identification of the approach used to calculate the risk -weighted exposure amounts 
for the purposes of points (a) and (f) of Article 92(3) of Regulation (EU) No 575/2013 . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  41 Additional clarifications  
This attribute may not be required f or the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
This section on the approach for prudential purposes  refers in fact to the attribute 
“capital calculation approach for prudential purposes” in the amended SHS 
Regulation. The name for the further material on reporting requirements has been 
amended to align with the more commonly used wording in this case th at is also 
applied, for example, in the context of COREP.  
It has to be differentiated whether the standardised approach, in accordance with 
Chapter 2 of Regulation (EU) No 575/2013, or the IRB approach, as defined in 
Chapter 3 of Regulation (EU) No 575/20 13, is used for prudential purposes.  
With regard to the IRB approach, a further differentiation should be reported:  
 if banks use their own -calculated PDs, while for the other parameters (such as 
LGD) pre -defined values provided by supervisors are taken, th is should be 
reported as the so -called “Foundation IRB approach”;  
 if banks calculate and use, in addition to the PDs, their own risk parameter 
subject to the supervisory guidelines, this should be reported as the so -called 
“Advanced IRB approach” ; 
 in addi tion s pecific codes for securitisation positions and equity exposures are 
available  to align with supervisory  requirements regarding IRB exposures .  
Regulation (EU) No 575/2013 no longer refers to the above terms (“Foundation” and 
“Advanced”) to distinguis h the IRB approach, although they are still commonly used 
by market participants and supervisors.  
The applied approach may vary for the same holding entity and instrument, for 
example where different prudential approaches are assigned to different portfoli os of 
the entity that include the instrument. Therefore, the information has to be reported 
separately on an entity -by-entity basis for the individual holding.  
The attribute has to be reported in the case of banking book positions (also called 
non-trading  book in the prudential portfolio) or if the data is available by other means.  
5.3.6  Exposure class  
Use 
Mandatory . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  42 Description  
Exposure class as defined in accordance with Regulation (EU) No 575/2013 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
The types of exposures depend on the applied capital calculation approach and are 
defined in Article 112 of Regulation (EU) No 575/2013 for the standardised approach 
and in Article 147 of Regulation (EU) No 575/2013 for the IRB approach.  
Accordingly, consistency should be ensured between the reported  exposure class 
and the capital calculation approach for prudential purposes; for example, where the 
standardised approach is indicated as the capital calculation method, one of the 
exposure class types related to the standardised approach has to be provid ed.   
It is possible to have different exposure classes for the same holding, as in the case 
of partially guaranteed holdings, for example, where the part that is guaranteed may 
fall into an exposure class other than the unguaranteed exposure class. Theref ore, 
the information has to be reported separately on an entity -by-entity basis for the 
individual holding.  
The attribute has to be reported in the case of banking book positions (also called 
non-trading book in the prudential portfolio) or if the data is available by other means.  
5.3.7  Impairment assessment method  
Use 
Mandatory . 
Description  
The method of assessing whether the instrument is subject to impairment in 
accordance with applied accounting standards. Collective and individual methods 
are distinguished . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  43 Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
If in accordance with the accounting standard (e.g. for instruments measured or 
designated at fair value through profit or loss under IFRS) or in the case of equity  
and investment fund shares or units , the instrument is not subject to impairment,  it 
should be flagged and reported accordingly.  
The attribute identifies the impairment assessment method in accordance with which 
the accumulated impairment amount is established for an instrument (i.e. whether it 
is individually or collectively assessed) , if the instrument is subject to impairment in 
accordance with the accounting standard.  
An instrument can be impaired on the basis of either an individually made 
assessment or a collectively made assessment (i.e. by being grouped together with 
instruments  with similar credit risk characteristics). An instrument cannot be subject 
at the same time to an individual and a collective assessment of impairment.  
5.3.8  Number of units or aggregated nominal value  
Use 
Mandatory . 
Description  
Number of shares or units of a s ecurity or aggregated nominal amount in nominal 
currency or euro if the security is traded in amounts rather than in units,  excluding 
the accrued interest.  
Additional clarifications  
For debt securities, the nominal value is the redemption price or face val ue, which is 
the amount to be paid by the issuer to the holder at maturity, excluding the accrued 
interest.  
In the case of equity and investment fund shares or units , the nominal value is 
normally reported in number of shares. If the nominal amount is provided, it should 
be the par value of the individual security . 
For securities with an ISIN code, if the holding amount is already reported at market 
value, the relevan t NCB may dispense with the requirement to fill the attribute.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  44 For securities without an ISIN code, the holding amount must be reported at market 
value, i.e. the amount held at the price quoted in the market in EUR, including 
accrued interest. Alternative approximations, for example, carrying amount, could be 
used on a best efforts basis if the market value is not available. Thus, the reporting of 
the attribute is not required for securities without an ISIN code, sub ject to the 
discretion of NCBs.  
In the ca se of proportional consolidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has to be adjusted for the reporting, in accordance 
with the propo rtional share of consolidation.  
5.3.9  Reporting basis  
Use 
Mandatory, subject to the discretion of NCBs . 
Description  
This attribute indicates the underlying reporting basis of the security . 
Additional clarifications  
This attribute indicates whether the security is quoted in percentage or in units.  
5.3.10  Market value  
Use 
Mandatory, subject to the  discretion of NCBs . 
Description  
Amount held of a security at the price quoted in the market in EUR . 
Additional clarifications  
The market value should be based on the last available representative price of the 
instrument at the reference date.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported a ttributes  45 For securiti es with an ISIN code, NCBs may, at their discretion, require d ata 
excluding accrued interest.  
For securities with an ISIN code, if the holding amount is already reported at nominal 
value (i.e. in number of units or nominal amount), the relevant NCB may dis pense 
with the requirement to fill the attribute.  
For securities without an ISIN code, the holding amount must be reported at market 
value, i.e. an amount held at the price quoted in the market in EUR, including 
accrued interest. Alternative approximations , e.g. carrying amount or nominal value, 
could be used on a best efforts basis if the market value is not available.  
In the case of proportional consolidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has to be adjusted f or the reporting, in accordance 
with the proportional share of consolidation.  
5.3.11  Carrying amount  
Use 
Mandatory . 
Description  
Carrying amount in accordance with Annex V to Implementing Regulation (EU) No 
680/2014 . 
Additional clarifications  
This attribute may no t be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of NCBs.  
The carrying amount is to be understood a s meaning the amount to be reported on 
the asset side of the balance sheet following the accounting policy of the group as a 
whole to the extent possible (see Section 4.3 above on accounting rules for a more 
detailed description). The carrying amount of fi nancial assets must include accrued 
interest.  
If the reporting agent is subject to Regulation (EU) 2015/534 of the European Central 
Bank (ECB/2015/13), it would be expected that the carrying amount reported is the 
same amount used to fulfil the requirement s of this Regulation.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  46 The carrying amount is the net carrying amount for instruments measured at 
amortised cost and the fair value for instruments measured at fair value through 
profit and loss or other comprehensive income.  
In the case of proportional con solidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has to be adjusted for the reporting, in accordance 
with the proportional share of consolidation.  
5.3.12  Accumulated impairment amount  
Use 
Mandatory . 
Description  
The amount of  loss allowances that are held against or are allocated to the 
instrument on the reference date. This data attribute applies to instruments subject to 
impairment under the applied accounting standard . 
Additional clarifications  
This attribute may not be req uired for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of the NCBs.  
If in accordance with the accounting standard  (e.g. for instruments measured or 
designated at fair value through profit or loss under IFRS) or in the case of equity 
and investment fund shares or units the instrument is not subject to impairment, the 
attribute should not be filled.  
Under IFRS, the acc umulated impairment re lates to the following amounts:  
 loss allowance at an amount equal to 12 -month expected credit losses;  
 loss allowance at an amount equal to li fetime expected credit losses.  
Under GAAP, the accumulated impairment relates to the followin g amounts:  
 loss allowance at an amou nt equal to general allowances;  
 loss allowance at an amount equal to specific allowances.  
A positive amount of accumulated impairment amount is reported if credit losses are 
expected for the instrument or if general or specific allowances are associated with 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  47 the instrument (or a portfolio to which the instrument belongs) in accordance with the 
accounting standard respectively.  
If the attribute is reported, the attributes “type of impairment” and “impairment 
assessment me thod” further specify which type (IFRS stages 1, 2 or 3, or, in the 
case of GAAP, specific or general allowances) and method (individually or 
collectively assessed) were used in order to calculate the accumulated impairment 
amount.  
In the case of instrumen ts for which the impairment assessment method is 
collectively assessed, the accumulated impairment amount that is determined for the 
total basket of instruments (to which the instrument is assigned for the purpose of 
the collective assessment) is suitably allocated to the individual instrument, 
considering that only the collectively assessed impairment amounts that are relevant 
for SHSG eligible instruments within the pool assessed are included in the re -
distribution (in order to avoid excessive impairments ). 
In the case of proportional consolidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has to be adjusted for the reporting, in accordance 
with the proportional share of consolidation.  
5.3.13  Accumulated changes in fair value du e to credit risk  
Use 
Mandatory . 
Description  
Accumulated changes in fair value due to credit risk in accordance with Annex V to 
Implementing Regulation (EU) No 680/2014 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of NCBs.  
If in accordance with the accounting standard or in the case of equity and invest ment 
fund shares or units the attribute is not applicable, it should not be filled.  
The accumulated changes in fair value due to credit risk are calculated by adding all 
negative and positive changes in fair value due to credit risk that have occurred 
since recognition of the debt instrument.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  48 In particular, if the fair value of an asset has deteriorated owing to the changes in 
creditworthiness (a negative change), it would be expected that a positive amount is 
reported for the attribute.  
This amount is only reported if the addition of positive and negative changes in fair 
value due to credit risk results in a positive amount of the attribute (meaning 
deterioration or negative change of fair value).  
This attribute should reflect changes in fair value sole ly due to changes in credit risk. 
However, changes in fair value may also be caused by other factors, whose effects 
may not be readily (if at all) isolated from the effects of changes in credit risk.  
In this respect, if a reporting agent considers a partic ular factor to have an effect on 
creditworthiness, then a change in fair value as a result of this particular factor may 
be considered when determining this attribute, assuming that a change in fair value 
has indeed taken place due to credit risk.  
To this  extent, if the reporting agent is able to measure the change in fair value due 
to this particular credit risk event, then that amount should be delivered.  
On the other hand, if changes in credit risk take place in parallel to changes in 
factors other than  credit risk that also affect the fair value but the reporting agent is 
not able to (readily) isolate the effects of such factors from the effects of credit risk on 
the fair value, the total change in fair value can be considered as a proxy measure of 
accu mulated changes in fair value due to credit risk.  
In any case, for an instrument whose creditworthiness (or the creditworthiness of the 
debtor of the instrument) has not changed (i.e. neither deteriorated nor improved) 
compared with the initial recognition , 0 (zero) should be reported in this data 
attribute.  
If the creditworthiness deteriorates, and no other factors unrelated to credit risk affect 
the fair value, the data attribute is reported as a positive amount, i.e. this applies 
when the fair value of t he instrument at the reporting reference date decreased 
compared with the initial recognition owing to the deterioration in creditworthiness.  
The attribute must be reported if in accordance with the supervisory reporting 
requirements  the availability of th e attribute is required or if the data is available by 
other means .  
In the case of proportional consolidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has to be adjusted for the reporting, in accordance 
with the proport ional share of consolidation.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  49 5.3.14  Cumulative recoveries since default  
Use 
Mandatory . 
Description  
Total amount recovered since the date of default . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of NCBs.  
If in accordance with the accounting standard or in the case of equity and investment 
fund shares  or units the attribute is not applicable, it should not be filled.  
The attribute informs about the amount of recoveries received in relation to defaulted 
instruments from the start of the latest default of the instrument till the reporting 
reference date.  It should be clarified that the term “default” in the definition of the 
data attribute refers to default as specified in Article 178 of the CRR.  
If an instrument is in default at the reporting reference date, then an amount of 
recoveries received in the p eriod since the start of the default must be reported. If no 
recoveries have been received since the start of the default, zero must be reported.  
It should be noted that the amounts of recoveries since default are not accumulated 
over multiple defaults of one and the same instrument (i.e. where an instrument 
defaults, cures and re -defaults again). Accordingly, there is no carrying -over of 
recoveri es from one default to another place – every time a new default starts, the 
cumulative recoveries since default are set to zero and the accumulation starts 
anew.  
Where the reason for default is other than past due, the amounts recovered must 
also be reported in this attribute.  
For the purpose of calculating the cumulative recoveries after default, all recoveries 
should be taken into account irrespective of their source; for example, the attribute 
must consider any voluntary cash repayments, any proceeds from liquidating of 
collateral, amounts received as a result of calling guarantees, etc. Moreover, 
recoveries from any protection securing the instrument must be included in this 
attribute.  
However, the attribute should be reported net of any recovery costs – for example, if 
a cost is incurred when realising proceeds from a collateral (e.g. liquidating a real 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  50 estate pr operty which serves as protection), only the proceeds remaining after 
deduction of the costs of the liquidation process are reported in this attribute.  
In all other cases, where an instrument is no longer in default at a reporting 
reference date, the relev ant NCB may dispense with the requirement to fill the 
attribute.  
In the case of proportional consolidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has to be adjusted for the reporting, in accordance 
with the proportiona l share of consolidation.  
5.3.15  Exposure value  
Use 
Mandatory if it is a banking book position, or if the data is available by other means . 
Description  
Exposure value after credit risk mitigation and credit conversion factors in 
accordance with Implementing Regulation (EU) No 680/2014 . 
Additional clarifications  
This attribute may not be required for the reporting of intra -group holdings (prudential 
scope) and “pure” short positions (i.e. those where no positive amount is held and 
recorded on the asset side), subject to the discretion of NCBs.  
Where the standardised approach is applied, the exposure value is defined in 
accordance with Article 111 of Regulation (EU) No 575/2013. The exposure value of 
an asset item will be its accounting value remaining after spe cific credit risk 
adjustments, additional value adjustments in accordance with Articles 34 and 110 of 
Regulation (EU) No 575/2013 and other own funds reductions related to the asset 
item have been applied. The definitions of Article 111 and subsequent part s of 
Regulation (EU)  No 575/2013 apply accordingly.  
Where the IRB approach is applied, the exposure at default (EAD) is requested, that 
is, used within the calculation of the expected loss. The expected loss is defined as 
the product of EAD, PD and LGD. Th e definition for the exposure value regarding the 
IRB approach is set out in Section 5 of Chapter 3 of Regulation (EU) No 575/2013.  
In the case of proportional consolidation of holding entities (see Article 18(4) of the 
CRR), the total holding amount has t o be adjusted for the reporting, in accordance 
with the proportional share of consolidation.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attri butes  51 5.4 Holdings of non -ISIN securities (additional instrument and 
issuer reference attributes)  
Mandatory non -ISIN holdings data colle ction  
As part of the SHS legal update  in August 2016, the Governing Council approved to 
make mandatory the SHSG data collection on holdings of securities without an ISIN 
code. Accordingly, the attributes included in the ISIN holdings feed, as described 
in the previous sub -sections, have to be  reported for the non -ISIN holdings as 
well. In addition, a set of required instrument and issuer reference information  
for securities without an ISIN code has to be provided directly by the SHSG data 
reporting agents.  
Mandatory reporting of market values for non -ISIN securities  
The holding amounts for non -ISIN securities have to be mandatorily reported 
at market value, including possible adjustments  such as accrued interest and 
early redemptions. Alternative approximations (such as carrying amount, other 
evaluations used by the declaring agent to establish its statistical balance sheet or 
nominal value in the case of debt instruments) could be used on a “best efforts” 
basis where the market value is not available. In addition, the relevant NCB may 
request reporting agents to also provide the holding amount in nominal value of non -
ISIN securities.  
Additional non -ISIN attributes listed below  
The attributes listed below are those that are relevant for non -ISIN holdings 
only. Please refer to the previous sub -sections for a description of the other ISIN 
attributes that have to be reported for the holdings of securities without an ISIN code. 
Please note that non -ISIN issuers are to be reported at the level of the institutional 
unit (e.g. the fund itself – and not  the investment company – is to be reported as the 
issuer of investment funds).  
Different dimensional attributes for the identification of non -ISIN 
securities compared with ISIN securities  
With regard to the previous sub -sections, the attribute “ISIN code ” is used for the 
unique identification of securities with an ISIN code. For non -ISIN securities, the 
unique identification needs to be ensured based on an alternative security 
identifier code  as described below.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  52 5.4.1  Security identifier code  
Use 
Mandatory . 
Description  
A standard code, agreed with the relevant NCB, that uniquely identifies the security 
and information on the type of code used to uniquely identify the security . 
Additional clarifications  
This is a security identification number of a non -ISIN instr ument, which should 
ensure the unique and time -consistent i dentification of the security.  
Moreover, the type of identifier used for the non -ISIN security should be provided as 
a separate variable, e.g. to specify that the Committee on Uniform Securities 
Identification Procedures (CUSIP) code has been used as an identification number 
for the non -ISIN instrument.  
5.4.2  Instrument ESA 2010 class  
Use 
Mandatory . 
Description  
Classification of the security according to ESA 2010 and Regulation (EU) No 
1011/2012 (ECB/2012/24) . 
Additional clarifications  
The following ESA 2010 instrument types should be provided:  
 short -term debt securities (F.31)  
 long-term debt securities (F.32)  
 listed shares (F.511)  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  53  money market funds (MMF) shares or units (F.521)  
 non-MMF investmen t fund shares or units (F.522).  
Please refer to the more detailed description of the categories in the above section 
on the instruments covered by the SHSG data collection.  
5.4.3  Issue date  
Use 
Mandatory . 
Description  
The issue date is the point in time at which the security is issued . 
Additional clarifications  
The date on which the securities are delivered to the underwriter by the issuer 
against payment. This is the date when the securities are available for delivery to 
investors for the first time.  
In the case of a strip, this column indicates the date on which the coupon/principal is 
stripped.  
The reporting of the issue date is also mandatory for shares/investment funds. In the 
case of shares, the date on which a corporation first issued securities to the publi c 
should be reported, i.e. the date of the initial public offering. Investment funds should 
be treated similarly, i.e. the date of the first offering should be used. The issuance is 
usually recorded at the point when payment is made to the issuer.  
5.4.4  Maturity  date 
Use 
Mandatory . 
Description  
Date on which the instrument is redeemed . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  54 Additional clarifications  
The redemption (or maturity) date is the point in time at which the final contractually 
scheduled repayment of the principal is due.  
Instruments giving the  holder the option of early redemption are classified according 
to the original maturity date.  
Securities in which a certain portion of the issue is retired periodically (sinking fund 
provision) are classified according to the earliest date on which the de bt sec urity can 
be completely repaid.  
A maturity date is not obligatory for securities that do not mature at all (i.e. that do 
not have a stated maturity date), such as perpetual debt securities and most equity 
instruments  as well as  investment fund shares  or units . 
5.4.5  Nominal currency of the security  
Use 
Mandatory . 
Description  
Currency in which the security is denominated . 
Additional clarifications  
Nominal currency of the instrument expressed as ISO 4217 code.  
5.4.6  Primary asset classification  
Use 
Mandatory . 
Descr iption  
Classification of the instrument . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  55 Additional clarifications  
The securities are classified according to their asset type in accordance with the 
definitions laid down in the Handbook on Securities Statistics and other sources, 
such as ESA 2010, Classi fication of financial instruments (CFI code) and Asset types 
of the list of eligible marketable assets (ECB General Documentation).  
The instruments are to be classified in accordance with their main characteristics if 
potentially more than one code is appl icable.  
5.4.7  Instrument seniority type  
Use 
Mandatory . 
Description  
This attribute indicates whether the instrument is guaranteed or not, its rank level 
and whether it is secured or not.  
Additional clarifications  
The attribute indicates how the instrument is secu red in the event of the issuer’s 
insolvency. The value  “X” is not valid for this attribute. In case certain information is 
unknown, “9” should be provided.  Please refer to the Code list repository for specific 
examples.  
The attribute covers the following three dimensions: (1) guarantee level, (2) rank 
level and (3) security level.  
 The “guarantee level” indicates whether the instrument is guaranteed by an 
entity other than the issuer, e.g. the government.  
 The “rank level” indicates where the instrument ran ks in the event of liquidation 
in relation to other instruments issued by the same issuer.  
 The “security level” indicates whether an instrument is secured or unsecured, 
i.e. whether there is recourse to the cash flows of a securitised portfolio.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  56 5.4.8  Asset sec uritisation type  
Use 
Mandatory . 
Description  
Type of asset provided as security . 
Additional clarifications  
The asset securitisation type distinguishes between securitisation and covered 
bonds, with a further breakdown by the underlying asset ty pe for the tw o main 
categories.  
The breakdowns aim to follow the classifications used by the Handbook on 
Securities Statistics, the European and American Securitisation Forum as well as the 
European Covered  Bond Council.  
5.4.9  Security status  
Use 
Mandatory . 
Description  
The attribute indicates the status of the security, i.e. whether the instrument is alive 
(active) or not alive (not active).  
Additional clarifications  
The instruments held by the reporting agent are classified as alive (active) or not 
alive (not active). Secur ities have to be reported as alive for as long as a claim by 
any holder with respect to the corresponding security exists (objective criterion). 
Subjective criteria (e.g. “unlikely to pay”) should not be considered for the derivation 
of this attribute.  
The above definition of the alive status also applies to matured securities (i.e. after 
the maturity date) where the issuer is in an ongoing liquidation process or in similar 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attribute s 57 cases where claims of security holders against the issuer remain to be settled after  
the maturity date of the security. During such a process, the security is still regarded 
as outstanding until final settlement of the liquidation and needs to be flagged with 
the appropriate alive classification.  
Given that security holdings are consider ed as claims of the holder against the 
issuer, it is not expected that not alive classifications will be received in the context of 
the securities holdings reporting.  
5.4.10  Security status date  
Use 
Mandatory . 
Description  
The date on which a security status, as r eported under “sec urity status”, came into 
effect.  
Additional clarifications  
Where the security status is alive, the security status date is expected to be the 
same as the issue date.  
If the security is classified as alive with outstanding amounts after the maturity date, 
the security status date should be the date when the reported status came into effect 
(i.e. presumably the maturity date).  
5.4.11  Arrears for the instrument  
Use 
Mandatory . 
Description  
Aggregate amount of principal, interest and any fee payment outstanding at the 
reference date, which is contractually due an d has not been paid (past due).  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  58 This amount must always be reported. 0 is to be reported if the instrument was not 
past due on the reference date.  
The amount of arrears that is related to the holding amount has to be reported, as 
presumably the amount that relates to the complete issuance is not available to the 
holder.  
Additional clarifications  
If in accordance with the accounting standard or in the case of equity and investment 
fund shares or  units the attribute is not applicable, 0 is to be reported.  
The amount of arrears of the instrument is the part of the nominal outstanding 
amount that is legally past due. The amount which can be due includes principal, 
interest, late interest and claimab le expenses that are due under the terms and 
conditions of the issue, and which are past due on the reference date of the 
reporting.  
The amount in arrears does not include any accrued interest, because accrued 
interest amounts are not past due.  
It should be noted that an instrument is past due as soon as any amount arising 
under the instrument is past due.  
If a positive amount is reported in the attribute “arrears for the instrument”, the 
attribute “date of arrears for the instrument” is reported, indicati ng the date on which 
the first unpaid amount became past due.  
5.4.12  Date of arrears for the instrument  
Use 
Mandatory . 
Description  
The date on which the instrument became past due in accordance with Part 2.48 of 
Annex V to Implementing Regulation (EU) No 680/2014 . This is the date of the first 
amount unpaid that remains unpaid at the reference date . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  59 Additional clarifications  
If a positive amount is reported in the attribute “arrears for the instrument”, the 
attribute “date of arrears for the instrument” is reporte d, indicating the date on which 
the amount became past due.  
By contrast, if the instrument is not past due at the reporting reference date (i.e. 
when the amount in the attribute “arrears for the instrument” is reported as zero), the 
relevant NCB may dispen se with the requirement to fill the attribute.  
The attribute is the date of the first amount unpaid (principal, interest and expenses 
due) that remains unpaid at the reference reporting date. This means that the 
requested date might be earlier than the pur chase date, if the security is already past 
due when it is purchased. Moreover, if the amount of arrears for the instrument is 
reduced to zero, the counting of days past due must start anew.  
5.4.13  Collateral geographical location  
Use 
Mandatory . 
Description  
Geographical allocation of the underlying assets . 
Additional clarifications  
The collateral geographical location is the region or the country where the assets 
underlying the security are located. For example, if an SPV located in France issues 
a securitisa tion backed by German household mortgages, Germany as the country 
of the underlying assets has to be reported.  
If the assets are located in more than one country, either the sub -region, e.g. the 
euro area, or the main country should be reported.  
If the at tribute is not applicable to the security (for example, if it is not a covered 
bond, or a security issued as part of a securitisation), the relevant NCB may 
dispense with the requirement to fill the attribute.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  60 5.4.14  Guarantor identifier code  
Use 
Mandatory . 
Descr iption  
A standard code, agreed with the relevant NCB, that uniquely identifies the guarantor 
of the security and information on the identifier type of the code that is used, e.g. an 
EU identifier or national identifier/or LEI . 
Additional clarifications  
The guarantor is obliged to make payments to the holder of the security if the issuer 
fails to meet the obligation to make repayments arising under the instrument secured 
by the guarantor. Providers of a “financial guarantee”, as defined in Annex V to 
Regulat ion (EU) No 680/2014, should be covered.  
Protection may be provided by several guarantors, in which case only one of the 
guarantors is to be reported based on reasonable and risk -prudent considerations 
(e.g., subordination of liabilities, extent of the con tribution to the joint protection).  
If the attribute is not applicable to the security due to the unavailability of guarantees, 
the relevant NCB may dispense with the requirement to fill the attribute.  
An EU identifier means a commonly used identification code, agreed with the 
relevant NCB, which enables the unambiguous identification of any entity within the 
European Union.  
A national identifier means a commonly used identification code, agreed with the 
relevant NCB, which enables the unambiguous identific ation of any entity within its 
country of residency.  
Moreover, the type of identifier that is used as an identifier code should be specified 
as a separate variable, for example, what type of national identifier (such as a tax 
number) has been used. The sam e identifier type should be used for an entity 
reported in the different attributes “holder identifier code”, “identifier code of the 
immediate parent of the holder”, “guarantor identifier code” and “issuer identifier 
code”.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  61 5.4.15  Issuer  identifier code  
Use 
Mandatory . 
Description  
A standard code, agreed with the relevant NCB, that uniquely identifies the issuer of 
the security and information on the identifier type of code used, e.g. EU identifier or 
national identifier . 
Additional clarifications  
An EU identi fier means a commonly used identification code, agreed with the 
relevant NCB, which enables the unambiguous identification of any entity within the 
European Union.  
A national identifier means a commonly used identification code, agreed with the 
relevant NC B, which enables the unambiguous identification of any entity within its 
country of residency.  
Moreover, the type of identifier that is used as an identifier code should be specified 
as a separate variable, e.g. what type of national identifier (such as a tax number) 
has been used. The same identifier type should be used for an entity reported in the 
different attributes “holder identifier code”, “identifier code of the immediate parent of 
the holder”, “guarantor identifier code” and “issuer identifier code ”. 
5.4.16  Issuer  LEI 
Use 
Mandatory . 
Description  
Legal Entity Identifier (LEI) in line with ISO 17442 of the issuer of the security . 
Additional clarifications  
This is the LEI of the issuer of the security.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  62 If the LEI is  not available, the relevant NCB may dispense with the requirement to fill 
the attribute.  
5.4.17  Issuer n ame 
Use 
Mandatory . 
Description  
Name of the issuer . 
Additional clarifications  
Full legal name of the issuer of the security . 
5.4.18  Issuer country  
Use 
Mandatory . 
Desc ription  
Country of legal incorporation of the issuer of the security . 
Additional clarifications  
ISO 3166 -1 alpha -2 code of the country where the is suer of the security is located.  
5.4.19  Issuer ESA 2010 sector  
Use 
Mandatory . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  63 Description  
Institutional sector of th e issuer according to ESA 2010 and Regulation (EU) No 
1011/2012 (ECB/2012/24) . 
Additional clarifications  
The issuers of the securities held should be specified in accordance with ESA 2010 
sector classes, e.g. non -financial corporations (S.11).  
Please refer  to the more detailed description of the categories in Part 2 of Annex II of 
the SHS Regulation.  
5.4.20  Issuer NACE sector  
Use 
Mandatory . 
Description  
Classification of counterparties according to their economic activities, in accordance 
with the NACE revision 2 s tatistical classification laid down in Regulation (EC) No 
1893/2006 of the European Parliament and of the Council . 
Additional clarifications  
In general, the level four NACE code in accordance with Regulation (EC) No 
1893/2006 has to be reported. If the lev el four NACE code is not available, the level 
three or level two NACE code should be provided.  
Where an issuer is engaged in several activities, the principal one should be taken 
into account when deciding on its most appropriate NACE code.  
5.4.21  Entity  status  
Use 
Mandatory . 
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  64 Description  
The attribute indicates the status of the issuer, i.e. whether the issuer is alive (active) 
or not alive (not active).  
Additional clarifications  
The issuers of instruments held by the reporting agent are classified as alive (activ e) 
or not alive (not active). Issuers have to be reported as alive for as long as a claim by 
any holder against any of the issuer’s securities exists (objective criterion). 
Subjective criteria (e.g. “unlikely to pay”) should not be considered for th e deriv ation 
of this attribute.  
The above definition of the alive status also applies to matured securities (i.e. after 
the maturity date) whose issuer is in an ongoing liquidation process or in similar 
cases where claims of security holders against the issuer re main to be settled after 
the maturity date of the security. During such a process, the security is still regarded 
as outstanding until final settlement of the liquidation and the issuer needs to be 
flagged with the appropriate alive classification.  
Given t hat security holdings are considered as claims of the holder against the 
issuer, it is not expected that not alive classifications will be received in the context of 
the securities holdings reporting.  
5.4.22  Entity  status date  
Use 
Mandatory . 
Description  
The date on which an entity status, as reported under “entity status”, came into 
effect.  
Additional clarifications  
Where the entity status is alive, the entity status date is normally the date when the 
entity was established.  
If the entity is classified with an ali ve code for an ongoing liquidation process or 
similar cases of unsettled claims, the entity status date should be the date when the 
reported status came into effect, for example, the date when the liquidation process 
started.  
 
Guidance notes to reporting agents on  SHS regulation  − Reported attributes  65  
 
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