Question ID
2026_7784
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
11
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
Annex II, templates Z 07.01
Type of submitter
Other
Subject matter
Reporting of intragroup transactions in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5
Question

We kindly ask for clarification on the intragroup transactions reporting in the context of the criticality assessment of economic functions. Should the intragroup transactions be included or excluded from the data provided in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 ?

Background on the question

In the instructions in Annex II a reference is made to Article 6(1) of Commission Regulation (EU) 2016/778 for the criteria for determination of critical functions. Both criteria relate to economic functions provided to third parties. However, according to the instructions to templates Z 07.01 the reporting entities should provide information for the economic functions no matter whether the function is provided to third parties or not. As a matter of fact, in Annex II there is no explicit instruction on whether the intragroup transactions should be reported in templates Z 07.01 or not. Moreover, references to FINREP are provided on several places in the instructions to the templates Z 07.01 (for instance, with regard to Z 07.01.1, c0030; Z 07.01.4, c0030-c0050; Z 07.01.5, c0030; etc.), which implicitly instruct the reporting of all transactions with both intragroup parties and third parties. This way, the criticality assessment of the economic functions is based on quantitative data for the functions provided to all parties, which contradicts the definition of critical function under Article 6(1) of Commission Regulation (EU) 2016/778. 

That is why, given the lack of clear instruction and in order to avoid any inconsistent interpretation of the instructions across the reporting entities, we would like to ask for EBA’s guidance on the matter whether the intragroup transactions should be excluded in the data provided in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5.

Submission date
Final publishing date
Final answer

Intragroup transactions should be excluded in the data provided in templates Z 07.01 as the criticality assessment should be performed with regard to the economic functions provided by the reporting entities to third parties. FINREP references are provided purely as guidance on the requested information. Taking note on the different scope of reported information, reconciliation between the corresponding data in FINREP and templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 is not obligatory. 

Intragroup transactions should be excluded in the data provided in templates Z 07.01 as the criticality assessment should be performed with regard to the economic functions provided by the reporting entities to third parties. FINREP references are provided purely as guidance on the requested information. Taking note on the different scope of reported information, reconciliation between the corresponding data in FINREP and templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 is not obligatory. 

Nevertheless, reporting entities should be aware that certain SRB data quality and validation rules (e.g. SRBDQ_0452 to SRBDQ_0497) may assess the consistency between information reported in resolution planning templates and corresponding FINREP data. While such validations do not alter the reporting scope of templates Z 07.01 or create a requirement for a full reconciliation with FINREP, differences arising from the exclusion of intragroup transactions or other scope-related considerations may need to be appropriately documented and explained. Institutions should therefore ensure that any material discrepancies can be justified in the context of the applicable validation framework and supervisory expectations. 

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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