- Question ID
-
2026_7763
- Legal act
- Directive 2014/59/EU (BRRD)
- Topic
- BRRD Reporting
- Article
-
4
- Paragraph
-
11
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
- Article/Paragraph
-
3/1
- Name of institution / submitter
-
BPCE Group
- Country of incorporation / residence
-
FRANCE
- Type of submitter
-
Credit institution
- Subject matter
-
Z08 Report Submission Anomaly - Control on Fields 0030/0040 vs. 0050/0060
- Question
-
Is it possible to change or remove the two controls on fields 0030/0040 vs. 0050/0060?
- Background on the question
-
We are writing to report a critical anomaly concerning the validation controls during the submission process of our Z08 reports.
Our understanding is that two specific controls within the Z08.01 report validation set require fields 0030 and 0040 to be different from fields 0050 and 0060, respectively. However, the official specification dictates that for "Intra-entity" transactions, these fields (0030 vs. 0050 and 0040 vs. 0060) must be equal.
This discrepancy results in a blocking control on field 0030. In the last delivery (27/02) of our Regnology program, this validation rule remains active. The only workaround we can implement is to filter out all Intra-entity data, which unfortunately leads to the submission of incomplete Z08 files.
We have taken the following steps to address this issue:
- On January 8th, we informed our Regnology software editor, who subsequently notified the EBA.
- On January 29th, we informed the Single Resolution Board (SRB).
- On February 27th, I requested access to post a question on the EBA's Q&A platform, and I receive the acesss on March 11th.
We strongly suspect that this issue may affect other reporting institutions and is not isolated to our firm.
We kindly request your guidance and assistance in resolving this validation anomaly to ensure accurate and complete Z08 report submissions.
- 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