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List of Q&A's

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
  • ID: 2026_7761
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Ban imposed by certain national authorities on the use of the term “neobank” for payment institution

Does the divergence of positions among national authorities regarding the freedom to use the term "neobank" for payment institutions not compromise the consistent application of EU law in the banking sector and the objective of convergence of supervisory practices, and does it not hinder competition and the development of cross-border activities? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7760
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 15/06/2026

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
  • ID: 2026_7759
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Source of information for determining percentage of market share of Payment services to non-MFIs split into segments (RESOL2 - Template Z 07.01.3 FUNC 1 PAY)

Where can we find source of information for determining percentage of market share of Payment services to non-MFIs split into segments (consumers, non-consumers - SME, and non-consumers - non-SME)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7758
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Annex II of Instructions for resolution planning reports vs defined drop downs in DPM model

Annex II specifies that for template Z 09.01, the allowed value for column c0040 should be “Payment systems”, so why is that not included in DPM and what would then be correct system type for e.g. NKS/STEP2/TARGET2?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7754
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7753
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as final Q&A: 03/07/2026

Annex II of Instructions for resolution planning report template Z03.01 vs EBA validation rule v7511_m

Could you please check the logic behind the EBA validation rules regarding Combined Buffer Requirement in RESOL report? Details are stated in the background section.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7751
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Template Z 03.01 Own funds requirements– validation rule v7511_m

In template Z03.01 column 0010 row 0400 Combined buffer requirement according to instructions should be equal to COREP (OF): {C 04.00;740;010}). However, the hotfix validation rule v 7511_m of the EBA creates a discrepancy. The validation rule v7511_m is: with {tZ_03.01, c*, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max( {r0440}, {r0450} ) (i.e the Combined Buffer Requirement in Z 03.01-r0400 must be equal to the sum of r0410  + r0420 + r0430 + the highest of (r0440; r0450)) The validation rule is has an error status, but its referencing appears incorrect. Can the Q&A please be amended?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7749
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Missing value in DPM Z09.01, column 0040 System type

'- In the DPM 4,2 file in tab Z_09.01 the column 0040 (System type) there is a missing value 'Payment system'. This value is used by the bank and was present in the previous taxonomy 4.0. with the value qx2049 Payment systems. The value is also present in the EBA guidance. Could you please add the value qx2049 Payment systems in the taxonomy 4.2 in the Z09.01, column 0040?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7748
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Error in Validation rule v7511_m

'- In the Validation rules for DPM 4.2, the validation rule v7511_m seems wrong. The current formula {r0400} = {r0410} + {r0420} + {r0430} + max( {r0440}, {r0450} ) doesn't include the line r0460 in the sum. Indeed, for for the entities which are not GSIIB and which report their requirement only on r0460 line dedicated for the OSIIB, the sum is wrongly calculated.  Could you please update the validation rule including the line 460 in the formula?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7747
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Blocking Key Value (qLEC:qLE) Legal entity

'- In the DPM 4,2 file in tab Z_01.02 the fields 0020 (Code) there is a blocking Key value which prevents the declaration of all the ownerships inside of the consolidated group. The field 0020 (Code) is set up as a unique value which can be declared only once in the tab while according to the guidance the institution should declare in this tab all the investors and investees entities. A s one investor entity can have several invetsees entities, the institution shloud be able to declare several line with the same code.    Could you please confirm if the Key value (qLEC:qLE) as a unique value should be removed from the taxonomy? for information, it's an urgent question for RESOLUTION

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7746
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Pillar 3 Data Hub CONDIS: ITS and reporting framework modelling constraint affecting EU LI1/LI2/CC2

In the P3DH Common Disclosure “CODIS” module technical package (taxonomy applied from Reporting framework 4.1 and 4.2), the following data points appear to be modelled as the same underlying data point (they share the same data point identifier within the module): template EU LI2, (table K_64_03_a, column a, rows 10, 20); template EU LI1, (table K_64_01_b, column b, row 10 and table K_64_01_d, column b, row 10); template EU CC2 (table K_66_02_b, column b, row 10, table K_66_02_d, column b, row 10) Therefore, the platform rejects XBRL/CSV submissions where different values are reported for these locations (e.g., “duplicate facts”). How should institutions proceed for the purposes of the structured submission (XBRL/CSV) in this situation? How should any resulting differences between the information prepared in accordance with the ITS disclosure instructions and the EU LI2 be addressed? (i.e. the figures disclosed in the published PDF: for example, where EU LI1 column g is populated (being different from zero) and EU LI2 is expected to exclude exposures not subject to RW / subject to capital deductions).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7745
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Reporting guarantees that are received to secure a pool of underlying securitized exposures/securitisation positions in a synthetic securitisation transaction

Should guarantees that are received for securitisation positions in a synthetic securitisation transaction and treated as unfunded credit protection for prudential requirements purposes be reported in FINREP? If so, in which FINREP templates these guarantees should be reported? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2026_7744
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/05/2026

Reporting of multiple investees per investor in template Z_01.02 (Ownership structure)

In template Z_01.02, how should institutions report cases where one investor is linked to more than one investee, given that column 0020 (code of investor) is defined as the Key value and columns 0040 and 0050 identify the investee?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7743
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

RES 4.2 taxonomy - template Z_01.02 “Ownership Structure”

The bank has noticed an inconsistency identified in the RES 4.2 taxonomy regarding template Z_01.02 “Ownership Structure”. In this template, the technical key is currently set only on field 0020 – “Investor Code” (Unique identifier of the legal entity or investor). Since each investor may be associated with more than one investee, this results in a duplication of the key whenever multiple relationships exist for the same investor. Given that the key must be unique, it is not possible under the current setup to correctly represent the group structure. Otherwise, generating a duplicated key would make the file incorrect and not processable and would result in an error of the whole RESOL1 package.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7742
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Classification of payment systems providers in Resol2 Z_09.01 template.

How it’s possible to classify FMI Providers for Payment systems in template Z_09.01?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7741
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026