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, paragraph 56
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Z 08.00 - Critical Services

What is the procedure that should be followed when the type of service is not in the predefined list available for selection, as one cannot add a new type?

Background on the question:

As indicated in Regulation (EU) No 2018/1624, annex II, paragraph 56 (page 56), in Z08.00, the combination of values reported in columns 0010 (Service Type), 0030 (Service recipient), 0050 (Service provider), 0070 (Critical function: country) and 0080 (Critical Function: ID) forms a primary key which must be unique for each row of the template. This means that for a certain type of service, there must be only a unique provider delivering the service to an entity and relating to a particular economic function.

This is an issue, since there is often more than one critical provider regarding the same type of service and associated to the same economic function in a certain country. Therefore, this situation leads to multiple keys that could be repeated and causes the unsuccessful validation of XBRL instances. In addition, the service type list is not exhaustive and one cannot add a new type to the predefined list. Furthermore, be also aware that there are services that fit into more than one type, but for filling purposes, it can only be selected one type.

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

The purpose of the reporting of template Z 08.00 is the assignment of the respective combination of service type / service recipient / service provider to a critical function. 

In situations where a specific service is provided by several service providers or several services are provided by the same service provider, another row for the same service type / service provider should be added. From version 3.1 of the reporting framework (end-2021 reporting) onwards, column 0005 of template Z 08.00 is part of the row key, to enable the reporting of multiple contracts between the same service recipient and provider regarding the same type of service and supporting the same critical function, but having different features in terms of estimated time to substitutability etc. 

Regarding the assignment of the service to a category, the listed main categories and sub-categories of services are sufficient for reporting purposes. The category that best suits the specific service should be selected. Where possible, the sub-category should be reported (two-digit identification).  

Where no sub-category exists or no sub-category properly describes the service provided, the main category (one-digit identification) should be reported. In light of the abovementioned purpose of the reporting and the possibility to allocate the service to the corresponding main category, a multiple selection of the service type and an additional field for a more precise description is not necessary. 

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