- Question ID
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2026_7749
- Legal act
- Directive 2014/59/EU (BRRD)
- Topic
- BRRD Reporting
- Article
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1
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
- Article/Paragraph
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Annex II, Z03.01 c0010, r0400
- Type of submitter
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Credit institution
- Subject matter
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Template Z 03.01 Own funds requirements– validation rule v7511_m
- Question
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In template Z03.01 column 0010 row 0400 Combined buffer requirement according to instructions should be equal to COREP (OF): {C 04.00;740;010}). However, the hotfix validation rule v 7511_m of the EBA creates a discrepancy.
The validation rule v7511_m is: with {tZ_03.01, c*, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max( {r0440}, {r0450} ) (i.e the Combined Buffer Requirement in Z 03.01-r0400 must be equal to the sum of r0410 + r0420 + r0430 + the highest of (r0440; r0450))
The validation rule is has an error status, but its referencing appears incorrect. Can the Q&A please be amended?
- Background on the question
-
In template Z03.01 column 0010 row 0400 Combined buffer requirement according to instructions should be equal to COREP (OF): {C 04.00;740;010}). However, the hotfix validation rule v 7511_m of the EBA creates a discrepancy.
The validation rule v7511_m is: with {tZ_03.01, c*, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max( {r0440}, {r0450} ) (i.e the Combined Buffer Requirement in Z 03.01-r0400 must be equal to the sum of r0410 + r0420 + r0430 + the highest of (r0440; r0450))
However, the corresponding validation rule for Corep reporting v6290_m is: with {tC_04.00, c0010, default: 0, interval: true}: {r0740} = {r0750} + {r0760} + {r0770} + {r0780} + max( {r0800}, {r0810} ) (i.e {r0740} = {r0750} + {r0760} + {r0770} + {r0780} + max({r0800}, {r0810})
The issue arises because v7511_m does not correctly reference rows 0440 (systemic risk buffer) and rows 0450 and 0460 (respectively G-SII and O-SII buffer). Based on CRD art. 128(6) the systemic risk buffer should always be included. Consistent with the validation rule in COREP, the highest of the O-SII and G-SII buffer should be included. It appears the referencing in v7511_m has inadvertently been set-up incorrectly.
The validation rule has an error status but following the validation rule would in this case result in an incorrect combined buffer requirement being reported in Z03.01.
We would greatly appreciate an answer to be able to report properly template Z03.01 according to instructions.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
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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
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Rejected question