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List of Q&A's

Templates Z9.03 - Null values reportable in col 0020 Segment

Please confirm what should be populated in Template 9.03 col 0020 Segment as the taxonomy does not allow null values whereas Annex II instructions specify this should be reported for CCPs only.

  • 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_7826
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z09.02 - 'Country 0030 ' and 'Critical functions ID 0040' for Essential FMIs

Please confirm what should firms populate in Template 9.02 columns 'Country 0030 ' and 'Critical functions ID 0040' for non-critical FMIs as these columns cannot have null values.

  • 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_7825
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Template Z08.01: Reporting on intra-group services with identical LEI codes

Per EBA taxonomy, concatenation of col 0005, 0010, 0020, 0040, 0060 and 0130 in Template 8.01 should be unique (unique key).  This causes duplication error across rows reporting similar intra-entity services between different branches, i.e. identical providers/receiver codes and identical other fields required for unique key.Does the taxonomy need to be amended to allow such reporting?

  • 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_7822
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

incoherent formulae

The formula of control v90322_m seems not relevant.

  • 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_7821
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

When trying to submit reports to our portal Finanssivalvonta it gives us this error: An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing

When trying to submit reports to our portal Finanssivalvonta it gives us this error:     An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing. What does this mean? we cant seem to figure that out

  • Legal act: Other
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7820
  • Topic: Not applicable
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Pillar 3 Transparency - Risk weight missing in Template CCR3

Values with risk weight 30% are not allocated (according to the EBA Mapping Tool) to template CCR3, although these values appear in Row 185 of template COROFC C07.00. Is it intended to exclude values with 30% risk weight from template CCR3 (if yes, please provide the reasons for that) or is this a bug in die EBA mapping tool?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7819
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Definition of "official export credit agency" for the calculation of deduction for non-performing exposures

Article 47c(4a) of the CRR exempts the part of a non‑performing exposure guaranteed or insured by an “official export credit agency” (ECA) from the deduction requirements laid down in Article 47c. However, the CRR does not define the term “official export credit agency”. In this context, what are the criteria for qualifying as an “official export credit agency” and how can it be determined whether an export credit agency and the guarantee or insurance provided meets the criteria for applying the derogation as provided in CRR Article 47c(4a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7818
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

Z 09.02 (FMI2) FMI services reporting criteria

Could the EBA confirm the correct reporting criteria for columns 0040 (Critical Function ID) and 0060 (Core Business Line ID) in template Z 09.02 when an FMI is classified as either essential or critical, but not both, and the procedure to follow when an FMI maps to multiple functions or business lines?

  • 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_7814
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Concerns on reporting on all relationships between investor and investee in Z01.02 of RESOL1 in alignment with the indication of key value as marked in the DPM 4.2 module

How to report correctly on the relationship of the investor (Z01.02, column 0020 “Code”) and the investee (Z01.02, column 0050 “Code”) when the investor invests in multiple investees? Could you please adjust 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) and apply the setting of ‘Key value’ to both column 0020 as well as to column 0050?

  • 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_7813
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Disclosure – Template EU CQ4: Treatment of cash balances at central banks and other demand deposits

Should cash balances at central banks and other demand deposits be included in disclosure template EU CQ4 as provided in the EBA IT Solutions / Mapping Tool (versions 4.1 and 4.2) even though such positions are not mentioned in Article 442(c) and (e) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2026_7812
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 05/06/2026

Historical valuation series considered in determining the average value of real estate collateral

Considering that institutions may rely on comparable real estate valuation indices to fill in periods where no formal property revaluation exists, in order to construct the required equally distant interval valuation points, is there any requirement or expectation to extend the historical series beyond the minimum three data points, covering the full reference period (e.g., six years for RRE and eight years for CRE)?  The reasoning underlying this question is illustrated in the following example: RRE: Case 1 - Exclusive reliance on three data points derived from formal property revaluation exercises Period 0: Property value at origination Period 1: -- Period 2: -- Period 3: First formal property revaluation Period 4: -- Period 5: -- Period 6: Second formal property revaluation RRE: Case 2 - Use of real‑estate price valuation indices to construct the historical period Period 0: Property value at origination Period 1: First property value collected using real‑estate valuation indices Period 2: Second property value collected using real‑estate valuation indices Period 3: Third property value collected using real‑estate valuation indices Period 4: Fourth property value collected using real‑estate valuation indices Period 5: Fifth property value collected using real‑estate valuation indices Period 6: First formal property revaluation RRE: Case 3 - Use of real‑estate price valuation and indices to construct the historical period Period 0: Property value at origination Period 1: First formal property revaluation Period 2: First property value collected using real‑estate valuation indices Period 3: Second property value collected using real‑estate valuation indices Period 4: Third property value collected using real‑estate valuation indices Period 5: Fourth property value collected using real‑estate valuation indices Period 6: Second formal property revaluation

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7810
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Application of the current market value as a cap for immovable property collateral

Should the most recent market value constitute the maximum permissible (“cap”) for prudential purposes, even when the revaluation mechanisms under Article 229 would otherwise yield a higher value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7809
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Unique values in Z.01.02 in column 0020

How are institutions expected to report repeated values in column 0020 of template Z 01.02?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2026_7808
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Clarification on validation v3078m under FINREP reporting

In reference to the validation rule 'v3078_m' should the held for trading positions be excluded while reporting the maximum amount of the guarantee received in FINREP F_09.02

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2026_7807
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/06/2026

Application of Article 199(6)(d) for low default portfolios

In cases where institutions do not have a sufficient internal track record of default and liquidation events due to the low-default nature of certain portfolios, is there an alternative approach, such as the use of relevant external data, market evidence, or a combination of internal and external information, that could be considered acceptable to demonstrate compliance with Article 199(6)(d) for eligible physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7806
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Granular reporting of liability data: currency designation for XAF / XOF

Annex II - Instructions refers to the ISO-4217 codes for the currencies selectable in the templates. Upon comparing the Annotated Table Layout with the ISO-4217 contents, we noticed the absence of the entries for XAF (Central African CFA Franc) and XOF (West African CFA Franc). Which currency code should be reported in such cases?

  • 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_7805
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Z03.01 - Own funds requirements on individual level: r0300 / r0500 if a waiver exists

According to EBA validation rule v6433_m a minimum Total SREP Capital Requirement (TSCR) ratio (r0300) of 0.08 should be reported. However, the reporting subject has been granted a waiver from the minimum capital requirements under Article 92 CRR and is not required to comply with the 8% Total Capital ratios on a standalone basis, as these requirements are fulfilled and monitored at the consolidated group level. This also affects the "Overall capital requirement (OCR) ratio" (r0500) due to validation rule v6436_m. If the validation rule v6433_m will not be deactivated, which value needs to be reported in such cases?

  • 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_7804
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Z01.02 - Ownership structure: Investor code and type of code for multiple investments

According to the Annotated Table Layout of DPM 4.2, c0020 - Code (Investor Code), is specified as a unique ID in the template. According to the instructions for filling out the template, the specification must maintain referential integrity with Z01.01, provided that the investor is a group company.Since there can exist multiple investments per investor, it is not possible to comply with these requirements completely. How shall c0020 and c0030 (Type of code) be reported in such cases ? 

  • 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_7803
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Granular Reporting of Liability data: Currency designation for precious metals

According to "Annex II: Instructions" for (EU) 2025/2303, the currency designation in, for example, c0120 of Template Z14.00 - Other Financial Liabilities (not included in other tabs, excluding intragroup) should follow ISO 4217. In the currency selection list of the Annotated Table Layout, there are no specifications for precious metals such as gold. Which value has to be chosen from the list of currencies in such cases ?

  • 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_7802
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Critical Functions - Z.07.03

Could you please clarify, with regard to completing template Z 07.03 (FUNC 3), whether core business lines not included in the predefined list should be reported under “Other” with an appropriate description or mapped to the closest predefined category?

  • 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_7801
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026