EBA E-mail alert 30 April, 2026

We are writing to request a clarification regarding the latest DPM update dated 13 January, with specific reference to Template Z8.04.
In the current version, the “Critical Function - ID” field (column 0040) is not included among the key fields. However, in Template Z8.05, the “Business Line ID” is defined as a key field.
This difference creates a reporting challenge for us. A single service, identified by a unique Service Identifier, may support more than one critical function. If the “Critical Function” field is not part of the key, it is not possible to link multiple critical functions to the same service within the template.
As a result, we would need to create multiple Service Identifiers for the same service, leading to an increased number of records across other templates, including Template Z8.01.
Could you please confirm whether the exclusion of the “Critical Function - ID” from the key fields in Template Z8.04 reflects the intended approach?

We request confirmation that in the Z 07.02 only the contribution of legal entities to the Group critical functions  should be reported in the template, and not their contribution to all economic functions considering that in the Annotated Table the key value is represented by the column 0020 ID - Critical function (CF to LE) .

The onboarding capacity metric requires an estimate of how many clients an institution could onboard at short notice during a crisis or resolution event. With current KYC/CDD rules, onboarding large volumes of clients within a short timeframe is operationally difficult. We would like to understand whether the EBA expects institutions to assume a full standard KYC/CDD procedures, or simplified crisis‑mode checks, particularly when clients have already undergone due‑diligence at another bank.

According to c0050 "ID alternative provider" definition it looks like the entity should only report Alternative Provider when these providers are already reported in Z09.01.
In the case an entity has a contingent contract of substitution with an alternative provider which currently doesn't provide any services to the entity, should the entity report this alternative provider? In affirmative case, which c0050 ID should we provide?

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL2RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z08.01, column 0010 Service Type? 

1. Does the “Unique service title” in Column 0020 of Z08.01 need to be unique to every contract i.e, if we have 150 different contracts should we have 150 different “Unique service titles” or can we have multiple contracts sharing the same service title?
2. If we can have multiple contracts sharing the same “Unique service title”, should the “Service identifier” in column 0005 of Z08.01 be the same for each contract having a particular “Unique service title”?
3. In Z08.01 can we assign multiple “Unique service titles” (Column 0020) and multiple “Service types” (Column 0010) to the same contract?
4. In Z08.02 should the “Asset identifier” in Column 0030 be unique to each asset or to each contract? By way of example, if we have two contracts for leasing of two different premises, should we assign them the same asset identifier or a different one?
5. In Z08.02 Column 0120, should contracts which require us to pay for the service in advance be considered to have an “Alternative mitigating action”?
6. In Z08.03 Column 0030, if we have the same role name (e.g. “analyst”) across multiple departments should that role have the same “Role ID” across all departments or should we assign one ID per department?
7. In Z08.03 Column 0060, should the “Criticality” value be the same as that in Column 0120 of Z08.01?
8. If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.03 can represent multiple contracts?
9. In Z08.03 can we assign multiple roles to the same contract?
10. If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.04 can represent multiple contracts?
11. In Z08.04, can we assign multiple critical functions (Columns 0030 and 0040) to the same contract?
12. If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.05 can represent multiple contracts?
13. In Z08.05 can we assign multiple core business lines (Column 0030) to the same contract?

Regarding the templates Z 07.01.1 to Z 07.01.5 that should be reported for each Member State in which the group is active (as specified in Annex 1 to the regulation mentioned above), the question is: Could you please confirm if the bank can include separate templates for each country in a single individual resolution report?

Regarding the templates that should be reported on an individual basis, for itself and for each relevant legal entity in the group (for example, the information specified in template Z 02.00 that should be reported according to the art. 4 letter (b) of CIR 2025/2303), the question is: Can the bank include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group or the relevant legal entities have to report the templates on an individual basis for themselves? If the bank can include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group, how can this be done from a technical point of view?