Question ID
2025_7614
Legal act
Directive 2014/59/EU (BRRD)
Topic
Resolution plans
Article
Article 45b
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on the provision of information for the purpose of resolution plans
Article/Paragraph
II.32
Type of submitter
Consultancy firm
Subject matter
Amount to be reported as MREL eligible amount and amount qualifying as Own Funds non-CET1 instruments, taking into account phase-out as applicable
Question

Could you please clarify whether in granular Resolution Plans reports (formerly SRB LDR) Z11.00, Z12.00, Z13.00 and Z14.00 the amount to be reported for Own Funds instruments (columns labelled Amount meeting the conditions for MREL eligibility ) and columns reporting on the Amount qualifying as Own Funds is:

  • the carrying value + accrued interest as recommended for the measurement of non-CET1 instruments or

  • the outstanding amount (outstanding principal + accrued interest) as mentioned for the Amount meeting the conditions for MREL eligibility? 

    For the columns reporting Own Funds there is no specific guidance on the amount type to be reported other than the amount of the instrument qualifying as Own Funds. 

Background on the question

There is some uncertainty since EBA has published the Report on monitoring AT1 and MREL.pdf, where the recommendation is to measure non-CET1 instruments at carrying amount including accrued interest rather than outstanding amount, not to over- or underestimate the loss-absorption capacity of the total capital.

Submission date
Status
Question under review
Answer prepared by
Answer prepared by the EBA.