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Q&As refer 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.

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List of Q&A's

Instructions to follow regarding new EBA Resolution Reporting - Z 09.02

The key values ​​of the templates are c0010 (ID representing the combination of user, FMI, system type, and intermediary), c0030 (Country), and c0040 (Critical Function ID). The c0060 "Core Business Line ID" is not set as a key. However, this does not allow for granular representation of multiple business lines associated with the same FMI–Critical Function combination. As communicated to us by our national authority, the EBA will not be providing a hotfix for DPM 4.2, and therefore the bank will adhere to the technical constraints imposed by the current technical documentation.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Technical problem due to validation

The current validation logic effectively forces the submission of an incomplete and therefore factually incorrect report, as only one participation can be reported per investor. We kindly ask you to review this issue and inform us promptly how institutions should proceed in this case. Please confirm whether an adjustment of the validation rule is planned or whether there is an alternative approach to correctly reflect our group structure.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Erroneous configuration Z 07.01.2 FUNC 1 LEN

Given the absence of any specified time bands for the “Lending” template in the Annex, it appears likely that this may be due to an erroneous configuration. In this context, we respectfully request the EBA to review the matter and provide guidance at your earliest convenience regarding the appropriate procedure for institutions in this case.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Validation in Z_01.02

According to the EBA instructions for validating Template Z 01_02 (source: DPM table layout and data point categorization), the validation key for this template is the code in column 0020 (expected to be unique). This is the investor code (also with validation on number of characters), which may actually have more than one investment within the group (as is the case with our bank). The existing validation rule prevents correct reporting. Please provide instructions on how to proceed with this template.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting

The Z_01.02 template of the RESOL1 survey, according to “Annex II – instructions”, should represent the situation of the shareholdings of the companies in a group, greater than 2%. The template requires that in the “code of Investor (c0020)” column we enter the code of the company that holds the participation, and in the “code of Investee (c0050)” column we enter the code of the company that is being participated. In some cases, the relationship between the two columns (Investor/Investee) is “1 to 1”: one Investor holds a participation in only one Investee. In other cases, the relationship between the two columns can be “1 to many”: one Investor holds participations in multiple Investees. However, in the annotated table layout of sheet Z_01.02, the only key value is indicated as “code of Investor – c0020” only, which therefore cannot be duplicated in the template in the situation where one investor holds participations in many investees. This rule does not allow us to correctly represent the information required by the template, because the case of a group company (investor) that holds participations in “n” other companies (investees) would violate the rule of the single key value (code of Investor – c0020). The filling of this template with exclusively the key value of column 0020, would give an incorrect representation of the requested data.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Clarification on the use of PSU-linked tokens in payment initiation services under the RTS

In the context of payment initiation services, we would appreciate clarification from the EBA as to whether an ASPSP may require a PISP to use a specific token replacing the PSU’s online banking credentials, and whether such token must be reused by the PISP across the different stages of the payment order, in particular at the payment initiation stage and for subsequent query following the execution of the payment order. Furthermore, we would welcome clarification on the conditions under which this practice would be compatible with the provisions of Commission Delegated Regulation (EU) 2018/389.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Z01.02 - Ownership structure: Investor code and type of code for multiple investments

According to the Annotated Table Layout of DPM 4.2, c0020 - Code (Investor Code), is specified as a unique ID in the template. According to the instructions for filling out the template, the specification must maintain referential integrity with Z01.01, provided that the investor is a group company.Since there can exist multiple investments per investor, it is not possible to comply with these requirements completely. How shall c0020 and c0030 (Type of code) be reported in such cases ? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Unique values in Z.01.02 in column 0020

How are institutions expected to report repeated values in column 0020 of template Z 01.02?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Concerns on reporting on all relationships between investor and investee in Z01.02 of RESOL1 in alignment with the indication of key value as marked in the DPM 4.2 module

How to report correctly on the relationship of the investor (Z01.02, column 0020 “Code”) and the investee (Z01.02, column 0050 “Code”) when the investor invests in multiple investees? Could you please adjust the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) and apply the setting of ‘Key value’ to both column 0020 as well as to column 0050?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 09.02 (FMI2) FMI services reporting criteria

Could the EBA confirm the correct reporting criteria for columns 0040 (Critical Function ID) and 0060 (Core Business Line ID) in template Z 09.02 when an FMI is classified as either essential or critical, but not both, and the procedure to follow when an FMI maps to multiple functions or business lines?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

incoherent formulae

The formula of control v90322_m seems not relevant.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae of the validation rule v90315_m

The control formula currently in place for column 0070 / row 0260 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae of the validation rule v90316_m

The control formula currently in place for column 0070 / row 0310 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae of the validation rule v90317_m

The control formula currently in place for column 0070 / row 0340 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

C 14.00, column 0040 Securitisation Type

How should a credit institution populate column 0040 of COREP table C 14.00 in the event that (i) the transaction has all the characteristics to meet the definition of ‘securitisation’ as defined in point (1) of Article 2 of Regulation (EU) 2017/2402, and; (ii) the transaction does not fully satisfy the definition of any of the securitisation types available to select from on the reporting form. For example, a transaction that meets the definition of ‘securitisation’ per point (1) of Article 2 of Regulation (EU) 2017/2402 and whose structure closely resembles that of a traditional securitisation, however does not involve an SSPE (i.e. the transfer of the economic interest in the exposures being securitised occur directly between originator and investor / sponsor).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Form ‘F 32.01’ on asset encumbrance: Market value including or excluding accrued interest?

Ist im Bogen „F 32.01“ zur Asset Encumbrance der Marktwert inklusive oder exklusive Stückzinsen auszuweisen? In form ‘F 32.01’ on asset encumbrance, should the market value be reported including or excluding accrued interest?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

incoherent formulae

Is the v90304_m control formula consistent with the other controls on C16.02 ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

incoherent formulae

Should the v903188_s control apply for establishments that do not supply the C16.04 status?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

incoherent formulae

Should the v903188_s control formula apply to columns 0010 and 0020?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

PILLAR 3 - form EU CMS2 mapping for row EU 7d: Categorised as subordinated debt exposures in SA

According to official mapping for row EU 7d: Categorised as subordinated debt exposures in SA, column "d" and "EU d" include form c07-qx2062 that refers to CRE IPRE OTHER. Is intention to see CRE IPRE OTHER , or maping should be changed and include subordinated debt exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3