EBA E-mail alert 3 April, 2026

How should banks report the unused prior permission amount in case the insolvency rank is not specified, and the unused prior permission amount exceeds the amount of eligible liabilities subordinated to excluded liabilities before the deduction of prior permission amounts (M02.00-r0100 to M02.00-r0130)? Furthermore, how should the unused prior permission amount be reported in cases where the subordinated layer only includes Tier 2 instruments, as T2 in phase-out is not covered by a general prior permission amount for eligible liabilities.

Could you please clarify whether in granular Resolution Plans reports (formerly SRB LDR) Z11.00, Z12.00, Z13.00 and Z14.00 the amount to be reported for Own Funds instruments (columns labelled Amount meeting the conditions for MREL eligibility ) and columns reporting on the Amount qualifying as Own Funds is:

• the carrying value + accrued interest as recommended for the measurement of non-CET1 instruments or

• the outstanding amount (outstanding principal + accrued interest) as mentioned for the Amount meeting the conditions for MREL eligibility? 

  For the columns reporting Own Funds there is no specific guidance on the amount type to be reported other than the amount of the instrument qualifying as Own Funds. 

How should the template z09.02 be filled?

We would appreciate a confirmation of the following interpretation:

In the context of a group level resolution planning reporting, only services associated with core business lines, whose continuity is necessary for the effective execution of the resolution strategy and any consequent restructuring are reported in Z08.01 of the 2026 Resolution Reporting.

Is the understanding correct, that essential services of core business lines which are mapped in Z07.03 only to legal entities that are classified as liquidation entities in the PIA Assessment of the Resolution Authority must not be reported by the Union Parent Undertaking or Resolution Entity on a consolidated basis in Z08.01?

We want to confirm how liabilities have to be reported on column 0056 of Z11.00 ?

It is indicated in "Annex II: Instructions":

Type of Liability

For liabilities which are reported under Z02.00-c0020-Row as “r0210 - Liabilities towards other entities of the resolution group”, indicate the type of liability as it would have been reported in Z02.00, had the liability not been considered as excluded.

We would like to know if operations that are not subject to reclassification in line 0210 of Z02.00 will have to be reported ?

Indeed, following the final taxonomy, we note that control e7484 from the validation rules indicates that column C0056 "type of liability" must not be null:

In Z 11.00, no empty value in columns (c0020, c0021, c0030, c0040, c0045, c0050, c0053, c0055, c0056, c0060, c0080, c0100, c0110, c0120, c0130, c0150)

Furthermore, we note that the list of accepted values for column C0056 is extended to all liabilities in Z02 and not just to liabilities reclassified in line 210.

We kindly ask for clarification regarding the reporting of key values in case of open sheet tables starting with Z_07.01 for the RESOL2 module. How should the information regarding the location of critical function be reported considering there are two mandatory keys?

Do validation rules v6446_m and v6447_m for template Z 08.01 (Relevant services) correctly apply in all reporting situations, given that they enforce the condition {c0030} ≠ {c0050} (Service Recipient must differ from Service Provider)? Should these rules be amended or removed to correctly reflect cases of intra‑entity services, where both fields may legitimately contain the same entity name according to the IT Annex II: Instructions of EBA/ITS/2025/04?

According to the Annex for IT Solutions related to the ITS on resolution reporting, entities should be allowed to report “Payment systems” as a type of system in Z 09.01, c0040. However, such possibility is not allowed under the DPM table layout and data point categorization (i.e. the annotated tables). This raises a question on how should entities ensure compliance with the ITS.

Approach to be taken in case of misalignment in the taxonomy and the instructions provided in the single data point model.