Question ID
2026_7799
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
II.27 Z 09.02 – Mapping to Critical and Essential FMIs (FMI 2)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
II.27 Z 09.02 – Mapping to Critical and Essential FMIs (FMI 2)
Type of submitter
Credit institution
Subject matter
Z09.02 Requirement to Report CEF and Its Country When an FMI Only Supports a CBL
Question

According to the EBA instructions, columns c0020, c0030, and c0040 are exclusively intended for essential FMIs (CEFs). However, in the template taxonomy, even when selecting “No” in column c0020 to indicate that the FMI is not a CEF, the system still requires completion of columns c0030 and c0040.

We do not fully understand this requirement: if we have indicated that the FMI is not a CEF, we should not be expected to provide any CEF in column c0040, nor the CEF country in column c0030.

Could you please advise on how we should proceed? As it stands, we would either need to enter an arbitrary CEF for FMIs that support a CBL but not a CEF, or the system should allow leaving columns c0030 and c0040 blank when c0020 = “No”.

Background on the question
0020-0040

Critical FMIs
0020

Critical FMI: Y/N

  • ‘Yes’ if the FMI is critical

  • ‘No’ if the FMI is not critical 

Columns 0020 and 0050 are not mutually exclusive.
0030

Country

Country in which the critical function is provided, as reported in Z 07.01 
0040

Critical function ID

Critical function(s) performed by the entity, the performance of which would be impeded or prevented by the disruption of access to the FMI service provider.

ID of the critical functions as reported in Z07.01 :

 

Deposits

Deposits from Households

Deposits from Non-financial corporations 

Deposits from Non-financial corporations SMEs

Deposits from Non-financial corporations non-SMEs

Deposits from General Governments

Deposits from other sectors / counterparties (1)

Deposits from other sectors / counterparties (2)

Deposits from other sectors / counterparties (3)

 

Lending

Lending to Households

Lending to Households for house purchase

Lending to Households for other than house purchase

Lending to Non-financial corporations

Lending to Non-financial corporations SMEs

Lending to Non-financial corporations non-SMEs

Lending to General Governments

Lending to other sectors / counterparties (1)

Lending to other sectors / counterparties (2)

Lending to other sectors / counterparties (3)

 

Payment, Cash, Settlement, Clearing, Custody 

Payment services to MFIs

Payment services to non-MFIs

Payment services to non-MFIs for Households

Payment services to non-MFIs for Non-financial corporations

Payment services to non-MFIs for Non-financial corporations SMEs

Payment services to non-MFIs for Non-financial corporations non-SMEs

Cash services

Securities settlement services

CCP clearing services

Custody services

Other services / activities / functions (1) on payments, cash, settlement, clearing and custody services

Other services / activities / functions (2) on payments, cash, settlement, clearing and custody services

Other services / activities / functions (3) on payments, cash, settlement, clearing and custody services

 

Capital Markets

Derivatives held for trading 

Derivatives held for trading in OTC

Derivatives held for trading in non-OTC

Secondary markets / trading

Primary Markets / underwriting

Other services / activities / functions (1) in capital markets

Other services / activities / functions (2) in capital markets

Other services / activities / functions (3) in capital markets

 

Wholesale Funding

Borrowing

Derivatives (assets)

Lending

Derivatives (liabilities)

Other product types (1) in wholesale markets

Other product types (2) in wholesale markets

Other product types (3) in wholesale markets

 
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