Opinion of the European Central Bank of 15 July 2024 on the introduction of a reporting obligation in respect of mortgage-related data (CON/2024/25)
Date: 2024-07-15
Institutions: European Central Bank
Subjects: financial stability

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 15 July 2024  

on the introduction of a reporting obligation in respect of mortgage-related data 

(CON/2024/25) 

Introduction and legal basis 

On 23 May 2024 the European Central Bank (ECB) received a request from the Dutch Minister for Finance 

for an opinion on a draft law amending the Law on De Nederlandsche Bank (hereinafter the ‘draft law’). 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 
Functioning  of  the  European  Union  and  Article 2(1),  third,  fourth  and  sixth  indents,  of  Council  Decision 

98/415/EC1,  as  the  draft  law  relates  to  De  Nederlandsche  Bank  (DNB),  the  collection,  compilation  and 

distribution of monetary, financial, banking, payment systems and balance of payments statistics and rules 

applicable  to financial  institutions insofar as they materially influence the stability of  financial  institutions 

and markets. In accordance with Article 17.5, first sentence, of the Rules of Procedure of the European 

Central Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the draft law 

1.1  Under the draft law, banks, investment funds, pension funds and insurance corporations established 

in the Netherlands or acting through a branch located in the Netherlands are required to report to 

DNB via electronic means granular data on mortgage loans relating to residential and commercial 

real estate. According to the draft law, DNB needs such data in the context of two of its tasks2, namely 

to promote the stability of the financial system and the collection of statistical data and the production 

of statistics. 

1.2  The reporting obligation is to be further developed by an implementing decree3 that may set out the 

information to be provided, the periodicity and deadlines for the provision of this information, the way 

in which the data relating to loans for house purchases should be pseudonymised by the reporting 

parties, and the threshold below which a company is exempt from the reporting obligation. Broadly 

speaking, the information on a loan will include data on the borrower, and the collateral and the risk 

characteristics, including default, interest rate repricing and climate risks, but will not be able to be 

traced back to individual households. 

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2  
3  

Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national authorities 
regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 
As set out in Article 4 of the Law on De Nederlandsche Bank (Bankwet 1998, Staatsblad 26 March 1998, p. 200).  

See Law on De Nederlandsche Bank Implementing Decree.  

 
 
 
 
 
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1.3  According to the memorandum of understanding accompanying it, the draft law will re-establish a 

previously existing practice whereby DNB will request granular loan-level mortgage data from banks, 

pension funds, insurance corporations and investment funds under its supervision. This request is 

transformed into a periodic reporting obligation. At the same time, the draft law imposes certain legal 

safeguards, mainly in the area of data protection and privacy, for the acquisition and processing of 

this information. 

1.4  Under the draft law and its implementing decree, DNB may process and provide the collected data 

under certain conditions to organisational units of DNB that are entrusted with a different task, such 

as  the  part  of  DNB  dealing  with  prudential  supervision.  Such  supervision  must  focus  on  the 

soundness  of  financial  undertakings  and  the  stability  of  the  financial  system.  The  draft  law  also 

provides that DNB may share the data under certain conditions with the International Monetary Fund 

(IMF), the Financial Stability Board and the Bank for International Settlements in view of their tasks 

in the area of financial stability. In this regard, it is understood that the data to be collected under the 

draft law and that may also be shared under the specified conditions solely concerns data collected 

from the DNB.  

1.5  Under the  draft  law, granular loan-level residential  mortgage  data is collected. This aspect sets it 

apart from existing reporting requirements of credit institutions, such as under  Regulation (EU) No 

575/2013 of the European Parliament and of the Council4, which are aggregated at institution level.  

2. 

Observations 

2.1  For the analysis of the pass-through of monetary policy via the financial sector to the real economy, 

access to granular data on commercial and residential mortgage loans is highly valuable, as they 

allow  a  detailed  assessment  of  the  monetary  policy  transmission.  The  ECB  therefore  strongly 

supports  the  draft  law.  Granular  data  enhance  the  monetary  analysis  based  on  aggregate 

macroeconomic data, taking into account that the transmission of monetary policy differs depending 

on  borrower  characteristics.  Specifically,  detailed  data  such  as  data  on  household  income, 

indebtedness, the probability of their default as well as risks related to the interest fixation periods of 

mortgages  and  the  value  of  the  real  estate  collateral  for  the  mortgage  loan,  provide  crucial 

information  for  assessing  household  vulnerabilities.  In  addition,  granular  data  on  commercial  real 

estate are essential for assessing credit risks in this sector, which may spill over to other sectors. 

Credit  risks  related  to  vulnerabilities  of  households  and  firms  across  mortgage  market  segments 

have an impact on credit conditions, access to new credit, the prolongation of existing mortgages, 

and,  in  turn,  on  private  consumption,  investment  and  the  economy  as  a  whole.  In  addition,  the 

provision of the energy label of the real estate would add further value allowing for enhancement of 

the analysis of credit risks related to climate change.  The fact that  the  provisions of the draft  law 

apply  to  banks,  investment  funds,  pension  funds  and  insurance  corporations  allows  for  a  more 

holistic  characterisation  of  the  transmission  mechanisms  of  monetary  policy.  Against  this 

background, the ECB highly welcomes the objective and detail of the draft law.  

4  

Regulation  (EU)  No  575/2013  of  the  European  Parliament  and  of  the  Council  of  26  June  2013  on  prudential 
requirements for credit institutions and amending Regulation (EU) No 648/2012 (OJ L 176, 27.6.2013, p. 1). 

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2.2  Having  access  to  granular  data  on  mortgages  is  essential  for  a  macroprudential  authority  to 

adequately perform its financial stability tasks. Shocks in the housing market are often a determining 

factor in the materialisation or amplification of vulnerabilities  in  the financial system with negative 

effects on the real economy. These risks are particularly important for the Netherlands, which has a 

tight  housing  market,  elevated  housing  prices  and  generous  mortgage  standards.  A  detailed  and 

structural monitoring of the developments in housing prices, indebtedness of households and firms, 

and the credit quality of mortgage portfolios is therefore key in identifying and addressing potential 

risks for financial stability. Because of the heterogeneity of the market, the granularity of the data is 

needed across regions, households and characteristics of the real estate and mortgage loan. For 

example,  a recent  study on the impact  of floods in  the Netherlands on credit risks in the housing 

market5  used  geographical-specific  data  to  perform  its  analysis  and  concluded  that  loan-to-value 

ratios are an important driver of the impact on capital ratios for banks. Granular data are also needed 

to implement targeted macroprudential policies to mitigate systemic risks. The measure that imposes 

a floor on the risk weights of mortgage portfolios is calibrated on the specifics of the underlying loan-

to-value ratios6. Finally,  in its recent  report on financial stability  in the Netherlands7, the IMF also 

recommended the creation of a clear legal basis for access to granular data. 

2.3  The ECB supports the proposed granular reporting as it offers several significant advantages. By 

analysing individual loans, their terms, and borrower profiles, analysts gain a deep understanding of 

market  dynamics,  which  is  especially  relevant  in  the  multifaceted  Dutch  mortgage  market. 

Policymakers benefit from this agility, which allows them to make informed decisions and implement 

targeted policies. Additionally, the flexibility of  granular data ensures that such data serve various 

purposes, from risk assessment to policy formulation. The ECB welcomes the proposed reporting 

scheme; reusing the AnaCredit data model, it concentrates on real estate loans and their features, 

and includes non-bank lenders to achieve comprehensive Dutch real estate loan market coverage. 

Moreover,  the  draft  law  respects  the  proportionality  principle,  balancing  adequate  coverage  with 

reporting burden, and allowing lenders with small mortgage portfolios to be exempted from reporting.  

2.4 

It is crucial to note that the goals of the forthcoming Integrated Reporting Framework (IReF), which 

include the reduction of the reporting burden on reporting agents and enhancing the quality of the 

data, are taken into account in the implementing decree. 

2.5  Regarding the content to be reported by banks, the ECB considers that providing not only the energy 

label, but also the data underpinning it, especially the level of primary energy use in kWh/(m2.y) and, 

where possible, greenhouse gas emissions and the life-cycle global warming potential, would allow 

DNB or  external stakeholders to better compare the  performance  of the real estate assets at the 

international level. Indeed, the methodologies and thresholds used to determine energy labels may 

differ  considerably  across  countries,  even  after  the  revision  of  Directive  (EU)  2024/1275  of  the 

5  

6  

7  

See  DNB  Working  Paper  796,  ‘Floods  and  financial  stability:  Scenario-based  evidence  from  below  sea  level’, 
Francesco  Caloia,  David-Jan  Jansen  and  Kees  van  Ginkel,  20  December  2023,  available  on  DNB’s  website  at 
www.dnb.nl. 

See  DNB  consultation,  ‘Consultatie  verlenging  regeling  risicoweging  hypothecaire  leningen  2024’,  14  May  2024, 
available on DNB’s website at www.dnb.nl. 
See  IMF  Staff  Country  Reports,  ‘Kingdom  of  the  Netherlands-The  Netherlands:  Financial  System  Stability 
Assessment’, 8 April 2024, available on the IMF’s website at www.imf.org. 

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European Parliament and of the Council8, and access to data on the underlying metrics may be of 

importance for external stakeholders, in order to better assess climate change-related risks9. 

ECB-PUBLIC 

This opinion will be published on EUR-Lex.  

Done at Frankfurt am Main, 15 July 2024. 

[signed] 

The President of the ECB 

Christine LAGARDE 

8  

9  

Directive (EU) 2024/1275 of the European Parliament and of the Council of 24 April 2024 on the energy performance 
of buildings (OJ L, 2024/1275, 8.5.2024, ELI: http://data.europa.eu/eli/dir/2024/1275/oj). 
See  paragraph  3  of  Opinion  CON/2023/2  of  the  European  Central  Bank  of  16  January  2023  on  a  proposal  for  a 
Directive on the energy performance of buildings (OJ C 89, 10.3.2023, p. 1). 

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