EN ECB -PUBLIC 
 
 
OPINION OF THE EUROPEAN CENTRAL BANK  
of 25 March 2013  
on balance of payments reporting  
(CON/201 3/22) 
 
Introduction and legal basis  
On 20 February 2013,  the European Central Bank (ECB) received a request from the Oesterreichische 
Nationalbank (OeNB) for an opinion on a draft regulation of the OeNB governing balance of payments 
reporting (hereinafter the ‘draft regulation’).  
The ECB’s competence to deliver an opinion is based on Article 1 27(4) and Article 282 (5) of the Treaty 
on the Functioning of the Europe an Union as well as the third and fourth  indent of Article  2(1) of Council 
Decision 98/415/EC of 29  June 1998 on the consultation of the European Central Bank by national 
authorities regarding draft legislative provisions1, as the draft regulation  relates to the OeNB and the 
collection of balance of payments statistics . In accordance with the first sentence of Article 17.5 of the 
Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.  
 
1. Purpose of the draft regulation  
1.1 Since the beginning of 2006, two OeNB balance of payments reporting regulations have been in 
effect : ZABIL 1/20052, as amended by ZABIL 1/2009, governed the collection of statistical data 
required for compiling current account s, in particular data on cross -border services. Due to 
international standards as well as E uropean Union and ECB requirements, t he necessary 
adap tations to this regulation were implemented by the adoption of the balance of payments 
regulation (ZABIL 1/2012) , which entered into force o n 1 January 20133. 
1.2 The second reporting regulation, ZABIL 1/2004, as amended by ZABIL 2/20094, governs the 
collection of statistical data for financial account s, in particular data on a security -by-security basis, 
direct investments, cross- border loans and deposits of non- banks. The draft regulation shall replace 
ZABIL 1/2004, as amended. The replacement of this regulation is necessary due to new 
international standards, namely the sixth edition of the International Monetary Fund’s Balance of 
Payments and I nternational Investment Position Manual, and new Union legal requirements based 
thereon. The Union legal requirements include in particular Guideline ECB/2011/23 of 
                                                 
1  OJ L 189, 3.7.1998, p. 42.  
2  See Opinion CON/2005/23.  
3  See Opinion CON/2012/67.  
4 See Opinion CON/2004/26.  
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2 9 December  2011 on the statistical reporting requirements of the European Central Bank  in the 
field of external statistics5 and Commission Regulation (EU) No 555/2012 of 22 June 2012 
amending Regulation (EC) No 184/2005 of the European Parliament and of the Council on 
Community statistics concerning balance of payments, international trade in se rvices and foreign 
direct investment , as regards the update of data requirements and definition s6. The draft regulation 
also implements Article 6 of the Exchange Control Act 2004, under which the OeNB is responsible 
for compiling the Austrian balance of pa yments, international investment position statistics, direct 
investment statistics and all statistics regarding cross- border transactions and positions in the 
context of the abovementioned statistics , based on Union regulations.  
 
2. General observation  
In ac cordance with Article 14.3 of the Statute of the European System of Central Banks and the European 
Central Bank (hereinafter the ‘Statute of the ESCB’), national central banks must act in accordance with 
the guidelines of the ECB. The ECB generally welcomes the draft regulation, which will ensure consistency with the reporting requirements under Guideline ECB/2011/23 following the basic principles 
of the ECB Statistics Quality Framework
7. The main purpose of euro area balance of payments and 
international i nvestment position statistics is to support the ECB’s monetary policy and other Eurosystem 
tasks. Moreover, as stated in the Eurosystem’s mission statement8, accountability, transparency and good 
governance are important values supporting the integrity of the statistical functions defined by Article 5 
of the Statute of the ESCB.  
  
3. Specific observations  
3.1 Electronic reporting  
The ECB welcomes the OeNB’s emphasis on the greater use of electronic reporting  as the main 
channel  for data transmission, as this could  assist in the provision of more timely and accurate 
reporting.  
3.2 Reporting thresholds  
The ECB accepts that , for the purpose of reducing the collection burden on reporting agents, an 
increase in the reporting thresholds , as specified below, is envisaged . 
(a) For data on end- month stocks of cross -border loans, trade credit and deposits  and for all  
investment  categories, the threshold is raised to EUR  10 million (formerly EUR  3 million 
and EUR  5 million , respectively ). 
                                                 
5  OJ L 65, 3.3.2012, p. 1.  
6  OJ L 166, 27.6.2012, p. 22.  
7  Available on the ECB’s website at www.ecb.europa.eu.  
8  Available on the  ECB’s website at www.ecb.europa.eu.  
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3 (b) For data on direct investment transactions, th e threshold is raised to EUR  500 000 (formerly 
EUR  100 000) per transaction; additionally, the reporting deadline  is brought forward by  five 
days.  
(c) For data on quarterly stocks of claims and liabilities under cross -border financial derivatives, 
the threshol d is raised to EUR  5 million (formerly EUR  1 million).  
Furthermore, the ECB understands that intermediary measures, such as estimat es and recourse to 
secondary sources, may  become necessary to fill the gaps arising from  the increased th resholds . 
Nevertheless this would  still result in freeing up resources which can be used to improv e the quality 
of data reported by statistically significant reporting agents.  
3.3 Direct investment transactions  
For data on direct investment transactions, the ECB welcomes the intr oduction of additional data 
collection categories and changes to the reporting period , as set out  below:  
(a) The inclusion of two new indicators , namely to differentiate between ‘purchase of shares ’ 
and ‘sales of shares ’ could enable improved data analysis, pa rticularly  for Foreign Direct 
Investment (FDI) purposes.  
(b) The mandatory disclosure of the t ax ID or commercial register number  will facilitate faster 
and unambiguous identification of foreign (i.e. non- residen t) direct investment 
enterprise s/direct investor s, which are located in the EEA and Switzerland . This is 
particularly important from the perspective of the joint ECB/Eurostat project on the FDI 
Network , which aims to harmonise and improve statistics on FDI . Moreover, the ECB 
invites the OeNB to closely monitor  the developments in the Global Legal Entity Identifier 
(LEI) Initiative9. 
(c) The change of the report submission deadline  to five days earlier, i.e. the 15th calendar day of 
the month following the reporting period, could  ensure more timely availabili ty of data for 
the OeNB’s and ECB’s monthly data analysis production rounds.  
3.4 Portfolio investment transactions  
With respect to  data on portfolio investment transactions , the ECB welcomes the introduction of 
new data collection categories, as outlined below : 
(a) Extension of the existing reports  on securities by custodians  in the context of breakdowns of 
customer accounts by report category, i.e. by  adding (i) the  country of residence of the 
account holder, (ii) changes in the definitions of the report ing catego ries, and  (iii) a new 
category of non- resident public entities. In addition, the following will be collected: (i)  new 
mandatory items  for stating the market value,  (ii) a value field for short positions , and (iii) a 
field for the nominal currency of banks’  and customers’ stocks. However, t he reporting of 
data on securities prices will be discontinued.  
                                                 
9   Financial Stability Board reports on the LEI: 
http://www.financialstabilityboard.org/list/f sb_publications/tid_156/index. htm  
ECB -PUBLIC  
4 (b) New annual a ccount holder reports  by custodian banks will be included in the reporting 
framework.  
The collection of additional information , as above, could  support  compliance with the updated  
European System of Accounts (ESA 2010)  as well as with any potential future requirements for 
extended  institutional sector breakdowns  in the balance of payments reporting framework. 
Furthermore,  the additional variables co uld enable better facilities for data analysis and quality 
checking . 
3.5 Other investment transactions  
With respect to  data on other investment transactions, the ECB welcomes the introduction of a 
separate category for participations of less than 10  % in other  enterprises , which could assist in the 
compilation of the new ‘Other Equity ’ item in the other investments account.  
 
This opinion will be published on the ECB’s w ebsite.  
 
 Done at Frankfurt am Main, 25 March 2013.  
 
[signed]  
 
The Vice -President of the ECB  
Vítor CO NSTÂNCIO