Question ID
2026_7726
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 onboarding capacity should assume full KYC/CDD or simplified crisis mode checks in a resolution scenario.
Question

The onboarding capacity metric requires an estimate of how many clients an institution could onboard at short notice during a crisis or resolution event. With current KYC/CDD rules, onboarding large volumes of clients within a short timeframe is operationally difficult. We would like to understand whether the EBA expects institutions to assume a full standard KYC/CDD procedures, or simplified crisis‑mode checks, particularly when clients have already undergone due‑diligence at another bank.

Background on the question

Different locations provide differing views on how KYC/CDD should be reflected in onboarding capacity calculations. In a real crisis, standard KYC/CDD processes may not be feasible at speed, yet the ITS does not clearly specify what level of due‑diligence should be assumed for this metric. Institutions need clarity to ensure consistent and realistic reporting across jurisdictions.

Submission date
Final publishing date
Final answer

The notion of onboarding capacity aims to assess the theoretical capacity of an entity to absorb the critical functions of a failing bank. Specifically, the number of applications from new customers that can be processed over 1 and 7 working days is used as a proxy to assess the onboarding capacity. 

For this purpose, the definition used for assessing the onboarding capacity implies that KYC was done. 

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.