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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

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

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

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

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

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

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

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

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

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

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

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

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

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

Net liquidity outflows over a 30 calendar day stress period

If a facility agreement includes a condition that causes a committed revolving facility to become non‑revolving during a period of stress for the credit institution, should the net liquidity outflow for LCR purposes then be calculated based on the maturity date of each individual drawing rather than the overall facility maturity date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

Dropdown lists are invalid

Dear Sir/Madam  We have noticed that in the templates published by the EBA, the name manager reference for templates containing dropdown fields shows a #REF! error, causing the dropdown lists to be invalid. If possible, could you please provide us with the correct version of the template?  Kind Regards

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

LCR treatment of issuances with automatic optionality/knock-out features

What is the LCR treatment of issuances with automatic optionality/knock-out features (hereinafter: ‘auto-callable issuances’) whereby notes are automatically redeemed should the underlier meet a strike level on specified observation dates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

EBA RESOLUTION TEMPLATE Z09.02 ON FINANCIAL MARKETS INFRASTRUCTURES

We need additional guidance in Z0902 on how to report FMIs related to Core Business Lines only, or FMIs related to more than a single Core Business Line. We kindly ask your guidance on how to report the following use cases: A purely Essential FMI, that is an FMI not linked to any Critical Economic Function (hence, with 0060 set to empty), but linked to one Core Business Line; An FMI that needs to be linked to more than one Core Business Line (hence, where we would need to insert several distinct values in 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

Deduction of goodwill included in the valuation of significant investments in entities included in prudential consolidation

For the purposes of calculating own funds on an individual basis and a sub-consolidated basis, are institutions subject to supervision on a consolidated basis required to deduct goodwill included in the valuation of significant investments of the institution, for holdings in such entities that are included in the scope of consolidated supervision?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Z 01.02 - Ownership structure (ORG 2)

The template require to report all the shareholders (or equivalent) of the group’s entities with more than 2% of share capital (or equivalent) or voting rights, and all the shareholdings (or equivalent) held by entities of the group. In the annotated table for the Z_01.02, the key value is represented only by the column 0020 “Code”. In the event that the same investor holds shares in multiple entities of the Group, it is not possible to report all the shares as an investor can only be reported once.

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