Question ID:
Legal Act:
Directive 2014/59/EU (BRRD)
BRRD Reporting
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
Annex II
Disclose name of institution / entity:
Type of submitter:
Resolution authority
Subject Matter:
P2G ratio in template Z 03.00

Based on Annex II to Regulation (EU) 2018/1264, OCR and Pillar 2 Guidance (P2G) (row 0600 to row 0620 of template Z 03.00) is the sum of OCR ratio (r0500) for row 0600 and the P2G communicated by the competent authority. Should any relief measures due to the COVID-19 outbreak for P2G be taken into account or not?

Background on the question:

Many credit Institutions need a clarification regarding whether they should take into consideration any relief measure for P2G, in the context of COVID-19, for the calculation of OCR and Pillar 2 Guidance (P2G) in reporting or not. Competent authorities have communicated to them a P2G ratio but due to COVID-19 outbreak and the financial consequences, they can operate below this requirement.

Date of submission:
Published as Final Q&A:
Final Answer:

Rows 0600 to 0620 of template Z 03.00 of Annex I to Regulation (EU) 2018/1624 (ITS on Resolution Planning Reporting) show the sum of the OCR ratio and Pillar 2 Guidance – thus target levels of capital to be met (‘to-be-ratios’), not actual levels of capital (‘as-is-ratios’) as of the reporting reference date. The information reporting should reflect the decision by the competent authority communicated to the entity. 

If a relief measure entails a change to the ‘to-be-ratio’, i.e. effectively changes the decision communicated by the competent authority, the relief measure should be reflected in template Z 03.00. 

However, if the relief measure does not entail such a change – i.e. the decision communicated by the competent authority and the ‘to-be-ratios’ remain effectively the same – the relief measure does not impact the information reported in rows 0600 to 0620 of Z 03.00. 

Final Q&A
Answer prepared by:
Answer prepared by the EBA.