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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

List of Q&A's

Inability to Assign More than One CEF or CBL to an FMI

It is currently not possible to report more than one CBL (c0050–c0060) per FMI (Z09.02).Historically, several FMIs have been reported as contributing to two Core Business Lines; however, upon uploading the data now, the system only accepts one CBL per FMI. Could you please confirm whether this is the expected treatment? If so, which CBL should be selected when both are equally relevant and one must be discarded in order to complete the submission?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 03.01 - Validation rule V7511_m_0

We encounter an error on template Z 03.01 due to validation rule v7511_m_0. For the total amount c0010 in row r0400 the validation rules checks if the sum of r0410 + r0420 + r0430 + (max r0440; r0450) = r0400. Should the validation rule not also take into account the row r0460? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting - Template Z 08.04

According to ITS, the c0040 "ID" column should be key, but in reality it is not. This does not allow for the representation of the connections between Critical Services (combination of c0005, c0010, and c0020) and multiple Critical Functions (c0040).

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Instructions to follow regarding new EBA Resolution Reporting - Z 09.02

The key values ​​of the templates are c0010 (ID representing the combination of user, FMI, system type, and intermediary), c0030 (Country), and c0040 (Critical Function ID). The c0060 "Core Business Line ID" is not set as a key. However, this does not allow for granular representation of multiple business lines associated with the same FMI–Critical Function combination. As communicated to us by our national authority, the EBA will not be providing a hotfix for DPM 4.2, and therefore the bank will adhere to the technical constraints imposed by the current technical documentation.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Technical problem due to validation

The current validation logic effectively forces the submission of an incomplete and therefore factually incorrect report, as only one participation can be reported per investor. We kindly ask you to review this issue and inform us promptly how institutions should proceed in this case. Please confirm whether an adjustment of the validation rule is planned or whether there is an alternative approach to correctly reflect our group structure.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Erroneous configuration Z 07.01.2 FUNC 1 LEN

Given the absence of any specified time bands for the “Lending” template in the Annex, it appears likely that this may be due to an erroneous configuration. In this context, we respectfully request the EBA to review the matter and provide guidance at your earliest convenience regarding the appropriate procedure for institutions in this case.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Validation in Z_01.02

According to the EBA instructions for validating Template Z 01_02 (source: DPM table layout and data point categorization), the validation key for this template is the code in column 0020 (expected to be unique). This is the investor code (also with validation on number of characters), which may actually have more than one investment within the group (as is the case with our bank). The existing validation rule prevents correct reporting. Please provide instructions on how to proceed with this template.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z0200 - templates that should be reported on an individual basis

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?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 07.01.1 to Z 07.01.5 consolidated reporting

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?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Completion of Z08.x Templates

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? 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”? In Z08.01 can we assign multiple “Unique service titles” (Column 0020) and multiple “Service types” (Column 0010) to the same contract? 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? 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”? 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? In Z08.03 Column 0060, should the “Criticality” value be the same as that in Column 0120 of Z08.01? 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? In Z08.03 can we assign multiple roles to the same contract? 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? In Z08.04, can we assign multiple critical functions (Columns 0030 and 0040) to the same contract? 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? In Z08.05 can we assign multiple core business lines (Column 0030) to the same contract?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

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 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z11.00, column 0060 Governing Law (as well in Z12.00 column 0070, Z13.00 column 005, Z14.00 column 0070, Z15.00 column 0100, Z08.01 column 0140, Z08.02 column 0090, Z09.01 column 0130)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

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 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z11.00, column 0100 Currency (as well in Z12.00 column 0090, Z13.00 column 0060, Z14.00 column 0120, Z17.00 column 0100, Z09.01 columns 0150-0200)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

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 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z05.01/Z05.02, column 0040 Country? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

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? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

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 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z01.01, column 0070 Article 7 CRR Waiver (and all other cells where ITS states the selection options Yes/No and the Annotated Table Layout states TRUE/FALSE instead)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

RESOL 1 - Z.01.02

Considering: 1) that the key of the Z.01.02 template is represented by field 20 only (investor code); 2) the template representation methods as regulated by the Annex of Reg. 2025/2303 require that field 20 be repeated across multiple records (for example: Investor 1 can hold more than n Investors). Therefore, it is necessary to replicate the aforementioned key. Given the absence of field 50 in the key, the template representation method is required.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting

The Z_01.02 template of the RESOL1 survey, according to “Annex II – instructions”, should represent the situation of the shareholdings of the companies in a group, greater than 2%. The template requires that in the “code of Investor (c0020)” column we enter the code of the company that holds the participation, and in the “code of Investee (c0050)” column we enter the code of the company that is being participated. In some cases, the relationship between the two columns (Investor/Investee) is “1 to 1”: one Investor holds a participation in only one Investee. In other cases, the relationship between the two columns can be “1 to many”: one Investor holds participations in multiple Investees. However, in the annotated table layout of sheet Z_01.02, the only key value is indicated as “code of Investor – c0020” only, which therefore cannot be duplicated in the template in the situation where one investor holds participations in many investees. This rule does not allow us to correctly represent the information required by the template, because the case of a group company (investor) that holds participations in “n” other companies (investees) would violate the rule of the single key value (code of Investor – c0020). The filling of this template with exclusively the key value of column 0020, would give an incorrect representation of the requested data.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z08 Report Submission Anomaly - Control on Fields 0030/0040 vs. 0050/0060

Is it possible to change or remove the two controls on fields 0030/0040 vs. 0050/0060?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Key Value Template Z01.02

Good morning, could you please verify whether, in template Z01.02, it is necessary to integrate the Key Value in the Annotated Table as the metric for column 0050.In the absence of the Key Value in column 0050, it would not be possible to highlight all the participations held by the entity reported in column 0020, as they would be aggregated into a single row.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

FMIR (Z.09) – Scope of ECMS as an FMI and clarification on “Operator of the FMI” (0080)

CaixaBank began operating with ECMS (Eurosystem Collateral Management System) in 2025. We wanted to understand whether it is actually considered an FMI and whether it should be included in the Z.09 reporting, since, being an ECB collateral management platform, it does not fit into any of the existing categories such as payment systems, CSDs/SSSs, CCPs or trade repositories. We have also reviewed the list included in the annex to the EBA reporting instructions, and it does not appear there. In Z.09.01. there is a new field called “Operator of the FMI (0080)”, and we have many doubts about what is expected to be reported. The instructions only state the following: “Name of the operator of the FMI”. Is it expected that the legal entity should be completed? For example, for the FMI Euroclear, should it be reported as → Euroclear Bank SA/NV; and similarly for TARGET2 → ECB – Eurosystem? Or, in the case of direct connectivity with the FMI (for example, TARGET2), should Banco de España be indicated as the operator? In that case, how should this be handled for custodians and other FMIs?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting