External code lists (ISO, NUTS, etc.)
The AnaCredit Regulation stipulates that some data attributes are reported following code lists such as the NUTS or ISO codes. For example, the data attribute “address: country” is reported in accordance with the ISO 3166 standard and the data attribute “address: county/administrative division” follows the NUTS 3 region classification. However, as the code lists may be modified over time, the question arises of whether the data previously reported to AnaCredit should be retroactively resent using the amended code lists?
The external code lists to which the AnaCredit Regulation refers can change for various reasons. For example, in regard to the NUTS 3 codes, sometimes national interests require a change in the regional breakdown of a country. Or, regarding the ISO country codes, country names might be amended or even removed from ISO 3166-1 because a country might change a significant part of its name, or a country may divide into two or more new ones, or two or more countries may merge into one.
However, a version of the external code lists is valid for a certain period of time before it is replaced by a newer version (for example, Commission Regulation (EC) No 1059/2003 specifies that the NUTS classification must be stable for at least three years). Therefore, there is only one version of a code list valid at a given moment in time.
In the context of AnaCredit, at a reporting reference date reporting agents are required to report data to AnaCredit using the codes that are valid as of the reporting reference date. In particular, in the case of an amendment to a classification, reporting agents are required to take into account the new classification for any data reported after the amendment and submit updates to any static data that is affected by the amendment. However, unlike what is required by Commission Regulation No 1059/2003 (cf. Article 5(5)), in the context of AnaCredit, reporting agents are generally not required to update historical data if there is a new classification.
For example, the NUTS 3 classification that is valid at present will be effectively replaced by its fifth version as of 1 January 2018. Accordingly, any counterparty reference data reported to AnaCredit before 1 January 2018 will be based on the current version of the classification. However, any counterparty reference data reported from 1 January 2018 onwards will be based on the amended classification. Furthermore, as the counterparty reference data of a given counterparty have to be updated if a change takes place, an additional record of the counterparty reference data will have to be reported as of 31 January 2018 for those counterparties whose counterparty reference data was reported throughout 2017 and which are affected by the change in the classification (to reflect the new classification for these counterparties). Nevertheless, in no instances do the data reported throughout 2017 have to be changed in line with the amended classification.
In other words, if a new version of an external classification is released, only those entities in the counterparty reference data for which the classification actually changed will have to be updated.
See also ISO country codes