Article 3, paragraph 8 of the EBA ITS on Resolution Planning reporting states:

"The Union parent undertaking shall submit to the group-level resolution authority, on an individual basis, the information specified in templates Z 05.01, Z 05.02, Z 06.00, Z 07.01.1 to Z 07.01.5 and Z 07.04 set out in Annex I for all the relevant legal entities that are institutions."

When receiving the reporting scope from the SRB (IRT says that it is based on the table included in the ITS, under section 2.2.4) we noticed that every single RLE was expected to submit a Z06.00 template at individual level to its national resolution authority. It is quite surprising because in the Annex I of the EBA Final Draft Implementing Technical Standards on the provision of information for the purposes of resolution plans pursuant to Directive 2014/59/EU and repealing Commission Implementing Regulation (EU) 2018/1624, it is indicated:

“This template provides an overview of deposits insurance within a group and the Deposit Guarantee Schemes of which credit institutions which are relevant legal entities are a member. Every credit institution belonging to the group shall be reported in a separate row.”

Indeed, this is a more pragmatic approach because there is no added value at reporting several different templates for different RLEs when we could report each RLE in a separate row for the whole group, in a single template. Moreover, this corresponds to the way this information was collected in the previous years by the SRB. This approach satisfies also the expectation laid out in article 3, paragraph 8 of the EBA ITS: the information is still reported on an individual basis for each RLE but in a single template for the whole group.