Question ID
2026_7730
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
11
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
7/1
Type of submitter
Resolution authority
Subject matter
Approach in case of misalignments in the taxonomy of the single data point model
Question

Approach to be taken in case of misalignment in the taxonomy and the instructions provided in the single data point model.

Background on the question

According to Article 7(1) of Commission Implementing Regulation (EU) 2025/2303 ("CIR on resolution planning reporting"), reporting entities shall submit the information referred to in Articles 2 to 5, as specified in the templates set out in Annex I of the CIR on resolution planning reporting, respecting the data point definitions included in the single data point model referred to in Annex II and the validation rules referred to in Annex III.
However, for some particular data points, the instructions and the annotated tables published by the EBA as at 20 February 2026 may incur in some inconsistencies which might not be fixed ahead of the reporting deadline. And example is the case raised in Q&A 2026_7729.

Against this background, guidance is requested on what instructions should be prioritised in case of misalignment or contradiction.

Submission date
Final publishing date
Final answer

If a potential misalignment or contradiction is identified in the technical packages conforming (i) the IT solutions and (ii) the DPM table layout and data point categorization (i.e. the annotated tables), the reporting entities are requested to raise a Q&A to confirm the existence of such misalignment or contradiction, so that it can be duly corrected or clarified accordingly in upcoming technical packages. 

In the absence of a reply or formal guidance, as a general rule priority should be given to the instructions available in the DPM table layout and data point categorization (i.e. the annotated tables), as these are the documents that (i) contain the most relevant technical specifications necessary for developing IT reporting solutions and (ii) allow reporting entities and resolution authorities to perform the validation rules envisaged in Annex III of the CIR. Otherwise, reliance on the IT solutions alone would not guarantee the ability of the bank to successfully submit the report and might prevent the execution of validation rules.

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.