Question ID
2026_7725
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
4
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
3
Type of submitter
Credit institution
Subject matter
Clarification on whether non resident / cross border clients must be included in CFR reporting under the new ITS.
Question

The new EBA draft ITS on resolution planning reporting contains several references to non‑resident clients within the Critical Functions Report (CFR). In previous years, the SRB instructed institutions to exclude non‑resident or cross‑border clients from the CFR. We would like to understand whether the new ITS now requires institutions to include non‑resident client figures, and if this reflects a change in reporting expectations.

Background on the question

In past resolution cycles, SRB guidance indicated that non‑resident or cross‑border client data should be excluded from CFR templates as part of MS-CFR reporting. The new EBA ITS instructions appear to broaden the scope by explicitly mentioning non‑resident clients for several data fields. This creates uncertainty about whether the reporting scope has now changed. We are seeking EBA guidance to ensure a harmonised application of the reporting requirements.

Submission date
Final publishing date
Final answer

In line with paragraph 21 of the Annex for IT solutions (instructions on RESOL1 and RESOL2 reports), template Z07.01 covers economic functions performed in a given Member state or region by any group entity. As such, unless it is explicitly requested otherwise in the instructions, entities are expected to report only values related to residents or counterparties in the relevant Member State or region. Values related to non-resident counterparties should be excluded and reported separately in the dedicated cross-border fields, where applicable. Otherwise, the value reported would not only reflect the economic function performed to counterparties in one state or region but also functions provided to any other state or region in which an institution is active.

References to FINREP across the instructions for Z07.01 intend to enhance the consistency of the definition and the underlying accounting aggregates across regulatory reports. Those references are not meant to determine the geographical perimeter of the amounts to be reported in each country or regional sheet. Where a referenced FINREP aggregate covers more than one country, it should therefore be broken down by the residence of the client or counterparty so that the value reported in the quantitative field relates only to the relevant Member State or region, unless otherwise stated.

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

Disclaimer

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