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List of Q&A's

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

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

II.29 Z 09.04 - FMI Services – CCPs – Alternative Providers (FMI 4)

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?

  • 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_7739
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Inconsistency between ITS and Taxonomy

In the Annex II of the ITS for report Z0600, Column 0030 - DGS , the ITS clearly states that the value other can be reported :"If the officially recognised DGS of which the entity is member is not listed above, ‘oter shall be reported".   But the DPM 4.2 as a restriction fur such column based on subcateogy EN3 which does not allow any "other" value and just nammed the principal DGS to be used. In the previous version of the DPM, the DGS column was technically binded by another enumeration that was allowing an other value : x128 - Other deposit guarantee scheme.   Can you explain us : if it's normal that the DPM 4.2 is now excluding the Other value even if the ITS seems to say that it's a valid option if it's correct for a client for which some CI may used some DGS not listed in the subcateroy EN3, to let this column empty?  

  • 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_7737
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Definition of Default (CRR Article 178) – Application of contagion and the 20% “significant part” threshold in the presence of joint credit obligations where default is applied at facility level

When the Definition of Default for retail exposures is applied at facility level, how should institutions apply the contagion and pulling effects set out in Article 178 CRR and EBA/GL/2016/07 in the presence of joint credit obligations, given that paragraphs 96–99 are articulated for obligor level default, while Article 178 CRR allows default recognition at facility level. In particular: Should a joint obligor (i.e. a specific set of obligors jointly liable) be treated as a separate obligor for the purposes of assessing contagion and the “significant part” (20%) threshold? How should contagion be assessed between:  joint credit obligations of the same set of obligors, individual exposures of the obligors participating in the joint obligation, and other joint credit obligations of those individual obligors with different counterparties, where default is recognised at facility level (including defaults identified through indications of unlikeliness to pay)? How should this be applied in practice for the 3 illustrative examples given?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2026_7736
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 10/03/2026

Template Z 01.02 Resolution Planning – Uniqueness Requirement for Column 0020

In template Z01.02 in column 0020 the unique identifier of the legal entity or investor referred in column 0010 should be reported. In our ownership structure, several investors hold participations in multiple investee entities, meaning the same investor appears in multiple rows of Template Z 01.02. Because the identifier in Column 0020 must consistently represent the same legal entity, it must be repeated across those rows. This, however, conflicts with the requirement that Column 0020 contain a unique value for each 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_7735
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Treasury subsidiaries of non-financial corporates and “financial customer” definition

How should banks consider the “purpose” of treasury subsidiaries of non-financial corporates, when assessing whether the customer performs one or more of the CRD Annex I activities as its “main business”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7734
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/03/2026

Mapping of Critical Services to Critical Functions Z08.04

We need additional guidance in Z08.04 on how to report a critical service linked to multiple critical functions

  • 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_7732
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

COREP Additional Liquidity Monitoring Metrics - technical implementation of DPM v4.2 for template C_67.00.a and C_67.00.w - SubCategory "new_CO4" used instead of "new_CO1"

With DPM v4.2 the modeling of template C_67.00.a and C_67.00.w has been changed to use SubCategory new_CO4 instead of new_CO1. Now it is possible to submit the “LEI code”, the “MFI Code” and “Type of identifier, other than LEI or MFI code” but not the “National code”. How should a national code be reported in template C_67.00.a and C_67.00.w and what is the reason behind this change?

  • 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_7731
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/03/2026

Approach in case of misalignments in the taxonomy of the single data point model

Approach to be taken in case of misalignment in the taxonomy and the instructions provided in the single data point model.

  • 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_7730
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Z 09.01 (FMI 1) - Reporting of FMI services related to payment systems under EBA 4.2.

According to the Annex for IT Solutions related to the ITS on resolution reporting, entities should be allowed to report “Payment systems” as a type of system in Z 09.01, c0040. However, such possibility is not allowed under the DPM table layout and data point categorization (i.e. the annotated tables). This raises a question on how should entities ensure compliance with the ITS.

  • 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_7729
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Clarification on whether onboarding capacity should assume full KYC/CDD or simplified crisis mode checks in a resolution scenario.

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.

  • 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_7726
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

FMI Reporting

In defining field 0040 (System type) in the latest hotfix to EBA DPM 4.2 (January 14th), EBA did not include value eba_qMA:qx2046 Payment Systems in the list of accepted values in the Annotated Template Layout

  • 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_7723
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Assigning risk-weight to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdown are not met.

What risk-weight should be assigned to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdowns are not met per the reporting date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7722
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Z 09.01 FMI 1 - System type enumerated property

A clarification is needed regarding which option in the enumerated list used in the DPM for column 0040 of Z 09.01 should be selected to report the system type ‘Payment systems

  • 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_7721
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Inconsistencies Between ITS Templates and DPM 4.2 Annotated Table Layouts for RESOL 1/2

When inconsistencies exist between the ITS templates and the DPM 4.2 Annotated Table Layouts, which source should be considered authoritative for reporting purposes?

  • 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_7720
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026