Question ID
2026_7735
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
1
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
Annex II, Z01.02, C0020
Type of submitter
Credit institution
Subject matter
Template Z 01.02 Resolution Planning – Uniqueness Requirement for Column 0020
Question

In template Z01.02 in column 0020 the unique identifier of the legal entity or investor referred in column 0010 should be reported. In our ownership structure, several investors hold participations in multiple investee entities, meaning the same investor appears in multiple rows of Template Z 01.02. Because the identifier in Column 0020 must consistently represent the same legal entity, it must be repeated across those rows. This, however, conflicts with the requirement that Column 0020 contain a unique value for each row. 

Background on the question

In the ownership structure template Z01.02 all the shareholders (or equivalent) of the group’s entities with more than 2% of share capital (or equivalent) or voting rights, and all the shareholdings (or equivalent) held by entities of the group shall be the listed. 

Since one investor -being the parent entity of the group, can hold participations in multiple investees entities-being the subsidiaries, the same legal entity (investor) must be repeated across rows. Because the identifier in Column 0020 must contain a unique value for each row we are unable to report the total ownership structure. 

We would greatly appreciate an answer to be able to report properly the ownership structure 

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because EBA guidance or clarification is not needed. This can be the case where harmonisation of practices through the Q&A process is not considered necessary; or that the issue is not material, for example because it is considered to be relevant only to a limited set of institutions or other stakeholders.

Status
Rejected question