Template Z_01.02 provides an overview of the legal and ownership structure of the group. According to Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting, the template shall include all shareholders (or equivalents) of group entities holding more than 2% of the share capital (or equivalent) or voting rights, as well as participations (or equivalents) held by group entities. 

In DPM 4.2, column 0020 (code of investor) is indicated as the Key value. The definition of Key value states that "the key value or the combination of all key value columns, where more than one applies must uniquely specify each row". At the same time, column 0050 (Code of investee) is used to identify the investee. 
In practice, situations frequently arise where one investor is linked to more than one investee within the group. 

For example, Investor A may hold participations above 2% threshold in Entity B and Entity C. In such cases, uncertainty arises as to how the requirement that the Key value must uniquely specify each row should be applied, given that the template also requires the identification of each investee through dedicated columns.

This raises the question of whether:

• each investor-investee relationship should be reported in a separate row, repeating the investor in columns 0010-0020 and identifying each investee separately in colum 0040-0050;  
• the information on multiple investees linked to the same investor should be aggregated in a single row.