Question ID
2026_7781
Legal act
Directive 2014/59/EU (BRRD)
Topic
Recovery plans
Article
Annex
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
Annex II: Instructions on how to complete Resolution Templates
Type of submitter
Credit institution
Subject matter
The question pertains to resolution template Z.07.01, in which deposits are evaluated to determine whether they should be classified as a CEF.
Question

In column 0035 of template Z.07.01, where the amount of uncovered deposits must be reported, should the amount provided be the portion exceeding €100,000 per deposit, or the portion exceeding €100,000 per depositor?

Background on the question

Initially, we believed that the correct way to report this data was by indicating the amount exceeding €100,000 per depositor, aggregating all deposits held by a single depositor.

However, after reviewing the instructions provided by the EBA, we noted the following: “Carrying amount (including accrued interest) of deposits accepted with the balance of their account higher than €100,000. Only the amount exceeding €100,000 is to be reported.”

By “deposits accepted,” we are unsure whether we should report the excess amount for each individual deposit, regardless of whether a depositor holds multiple deposits with the bank.

Submission date
Final publishing date
Final answer

The instructions are clear on the fact that the amount should be the excess over EUR 100,000 for each individual deposit. 

However, the bank is correct on flagging that this approach does not represent the value of non-covered deposits (as for non-covered deposits the threshold should be set at EUR 100,000 per depositor, rather than per deposit). 

This will be reviewed in an upcoming review of the instructions to clarify that it refers to the coverage of the depositor.

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.