Question ID
2026_7823
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
7
Type of submitter
Credit institution
Subject matter
Template Z09.01: EBA Taxonomy alignment with ITS Requirements -Annex II instructions
Question

Does the EBA taxonomy need to be updated to allow column 0110 of template Z09.01 to be left null when col 0090 is 'Direct', consistent with the Annex II instructions?

Background on the question

For template Z09.01 – FMI Services (Providers and Users), the Annex II instructions state that column 0110 (“Criticality assessment by provider”) may remain empty when 'Direct' is reported in col 0090.

 

However, the technical taxonomy currently does not permit column 0110 to be left blank. This is confirmed per following response from Nasdaq:
"From the perspective of the EBA XBRL Taxonomy and the relevant annotated templates for the RES module, column 0110 is defined as one of the key fields in report Z 09.01. Consequently, this column, together with the other applicable key columns, forms a unique key combination for each row of the template, thereby preventing the duplication of records.
In addition, Annex II – Instructions on Resolution Planning Reporting published by the EBA also identifies this column as participating in the formation of a primary key, which must be unique for each row of the template.
Therefore, from a technical standpoint, the presence of an empty value for the data driven dimension “qIFM – Intermediary facilitating access to a FMI” does not appear feasible. Such a scenario may prevent the correct generation of the relevant hypercube and, as a result, may not allow the creation of valid cell contexts for facts in the final XBRL output file."

Submission date
Final publishing date
Final answer

Column 0110 of template Z 09.01 will remain part of the primary key and therefore cannot be reported as null. Where “Direct” is reported in column 0090, “Not applicable” shall be reported in column 0110 instead. The instructions will be amended at the next available opportunity to reflect this treatment.

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

Disclaimer

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