EBA E-mail alert 9 October, 2026

Should accrued interest on withdrawable central bank reserves be reported on Row 050 and Row 100 of C72.00 template?

The new EBA draft ITS on resolution planning reporting contains several references to non‑resident clients within the Critical Functions Report (CFR). In previous years, the SRB instructed institutions to exclude non‑resident or cross‑border clients from the CFR. We would like to understand whether the new ITS now requires institutions to include non‑resident client figures, and if this reflects a change in reporting expectations.

When a subordinated issuance loses its MREL eligibility due to an early call that has been announced to the market but not yet executed, should it be reported in row r037x or r0531?

Additionally, if r037x is selected, should the Insolvency Ranking be adjusted accordingly under Spanish regulation?

How should entities report the identifier and the type of identifier when reporting at an aggregate level or when the counterparty is unknown?

Does the EBA taxonomy need to be updated to allow column 0110 of template Z09.01 to be left null when col 0090 is 'Direct', consistent with the Annex II instructions?

Could the EBA please confirm instruction interpretation for col 0220 and Col0210 of Template 09.01 (FMI Services - Providers and Users).

With reference to the reporting template RESOL2 - Z 08.02 SERV 2 we would kindly ask for a clarification: column “Contract ID - 0080” has obviously been defined as a primary key, which results in the fact, that values need to be submitted for this column in any case.

However, the column “Contract ID - 0080” can only be filled out once column “Legal/ Contract Type - 0070” is not set to “owned”. An owned asset does not have a contract ID attached to it and is thus reported as an empty string.

May we kindly ask you to confirm our view in this regard?

When assessing the eligibility of immovable property collateral for the purposes of credit risk mitigation (CRM), how should institutions interpret the interaction between the definition of income‑producing real estate (IPRE) exposures in Article 4(75b) CRR and the conditions set out in Article 199(2) CRR for recognising immovable property as eligible collateral under the IRB approach?

In particular, can immovable property collateral be recognised for CRM purposes under Article 199(2) in situations where an exposure is classified as IPRE under Article 4(75b), where repayment of the exposure is supported by diversified rental income streams across multiple properties or tenants, such that the repayment of the facility does not materially depend on the performance or cash flows of any single underlying property?

Given that the "other countries" code was removed from  the DPM 4.2, how should these exposures be reported in COREP? 

Should the concept of substitutability of CCPs, and consequently the identification of alternative providers to be reported in template Z 09.04, be interpreted restrictively, i.e. limited to CCPs or intermediaries that are capable of providing an equivalent clearing service for the same trading venue and/or market(s)?

Or should a broader interpretation of substitutability be applied, focusing on the economic function, business and regulatory objectives as well as the post-trade nature of the clearing service, under which a CCP might be substitutable not only by a concurrent CCP active on the same market, but also by:

1. the substitution of the entire trade value chain (e.g. trading venue – CCP – CSD or trading venue – CSD); or

2. the use of an intermediary/broker capable of rerouting either the trading and clearing activity or the transactions executed on behalf of the reporting institution through alternative FMIs, provided that such arrangements achieve a comparable economic and functional outcome for the reporting institution.