Question ID
2026_7703
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
Reporting Framework 4.2
Paragraph
DPM 4.2 uploaded 13/01/2026
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
Reporting Framework 4.2 - DPM 4.2 uploaded 13/01/2026
Type of submitter
Credit institution
Subject matter
DPM 4.2 on SERV Template (Z.08.04)
Question

We are writing to request a clarification regarding the latest DPM update dated 13 January, with specific reference to Template Z8.04.
In the current version, the “Critical Function - ID” field (column 0040) is not included among the key fields. However, in Template Z8.05, the “Business Line ID” is defined as a key field.
This difference creates a reporting challenge for us. A single service, identified by a unique Service Identifier, may support more than one critical function. If the “Critical Function” field is not part of the key, it is not possible to link multiple critical functions to the same service within the template.
As a result, we would need to create multiple Service Identifiers for the same service, leading to an increased number of records across other templates, including Template Z8.01.
Could you please confirm whether the exclusion of the “Critical Function - ID” from the key fields in Template Z8.04 reflects the intended approach?

Background on the question

Difference in the key fields in comparison to the previous version, it seems not coherent with the overall framework, considering that "Business Line ID" in the Z 08.05 is instead considered key field

Submission date
Final publishing date
Final answer

This is an issue that has been identified for a forthcoming update to the reporting framework.  

Until the misalignment is duly corrected or clarified in upcoming technical packages, adjust relevant row entries by iteratively numbering the end of the entry for c0020 “Unique service title as per bank taxonomy” as follows: _1, _2.

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

Disclaimer

The Q&A refers 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.