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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

DPM 4.2 on SERV Template (Z.08.04)

We are writing to request a clarification regarding the latest DPM update dated 13 January, with specific reference to Template Z8.04.In the current version, the “Critical Function - ID” field (column 0040) is not included among the key fields. However, in Template Z8.05, the “Business Line ID” is defined as a key field.This difference creates a reporting challenge for us. A single service, identified by a unique Service Identifier, may support more than one critical function. If the “Critical Function” field is not part of the key, it is not possible to link multiple critical functions to the same service within the template.As a result, we would need to create multiple Service Identifiers for the same service, leading to an increased number of records across other templates, including Template Z8.01.Could you please confirm whether the exclusion of the “Critical Function - ID” from the key fields in Template Z8.04 reflects the intended approach?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7703
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Z 07.02 - Mapping of economic functions to legal entities (FUNC 2)

We request confirmation that in the Z 07.02 only the contribution of legal entities to the Group critical functions  should be reported in the template, and not their contribution to all economic functions considering that in the Annotated Table the key value is represented by the column 0020 ID - Critical function (CF to LE) .

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7707
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Clarification on whether onboarding capacity should assume full KYC/CDD or simplified crisis mode checks in a resolution scenario.

The onboarding capacity metric requires an estimate of how many clients an institution could onboard at short notice during a crisis or resolution event. With current KYC/CDD rules, onboarding large volumes of clients within a short timeframe is operationally difficult. We would like to understand whether the EBA expects institutions to assume a full standard KYC/CDD procedures, or simplified crisis‑mode checks, particularly when clients have already undergone due‑diligence at another bank.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7726
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

II.29 Z 09.04 - FMI Services – CCPs – Alternative Providers (FMI 4)

According to c0050 "ID alternative provider" definition it looks like the entity should only report Alternative Provider when these providers are already reported in Z09.01.In the case an entity has a contingent contract of substitution with an alternative provider which currently doesn't provide any services to the entity, should the entity report this alternative provider? In affirmative case, which c0050 ID should we provide?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7739
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL2RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z08.01, column 0010 Service Type? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7767
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Completion of Z08.x Templates

Does the “Unique service title” in Column 0020 of Z08.01 need to be unique to every contract i.e, if we have 150 different contracts should we have 150 different “Unique service titles” or can we have multiple contracts sharing the same service title? If we can have multiple contracts sharing the same “Unique service title”, should the “Service identifier” in column 0005 of Z08.01 be the same for each contract having a particular “Unique service title”? In Z08.01 can we assign multiple “Unique service titles” (Column 0020) and multiple “Service types” (Column 0010) to the same contract? In Z08.02 should the “Asset identifier” in Column 0030 be unique to each asset or to each contract? By way of example, if we have two contracts for leasing of two different premises, should we assign them the same asset identifier or a different one? In Z08.02 Column 0120, should contracts which require us to pay for the service in advance be considered to have an “Alternative mitigating action”? In Z08.03 Column 0030, if we have the same role name (e.g. “analyst”) across multiple departments should that role have the same “Role ID” across all departments or should we assign one ID per department? In Z08.03 Column 0060, should the “Criticality” value be the same as that in Column 0120 of Z08.01? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.03 can represent multiple contracts? In Z08.03 can we assign multiple roles to the same contract? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.04 can represent multiple contracts? In Z08.04, can we assign multiple critical functions (Columns 0030 and 0040) to the same contract? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.05 can represent multiple contracts? In Z08.05 can we assign multiple core business lines (Column 0030) to the same contract?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7775
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Z 07.01.1 to Z 07.01.5 consolidated reporting

Regarding the templates Z 07.01.1 to Z 07.01.5 that should be reported for each Member State in which the group is active (as specified in Annex 1 to the regulation mentioned above), the question is: Could you please confirm if the bank can include separate templates for each country in a single individual resolution report?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7776
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Z0200 - templates that should be reported on an individual basis

Regarding the templates that should be reported on an individual basis, for itself and for each relevant legal entity in the group (for example, the information specified in template Z 02.00 that should be reported according to the art. 4 letter (b) of CIR 2025/2303), the question is: Can the bank include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group or the relevant legal entities have to report the templates on an individual basis for themselves? If the bank can include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group, how can this be done from a technical point of view?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7778
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

LCR treatment of issuances with automatic optionality/knock-out features

What is the LCR treatment of issuances with automatic optionality/knock-out features (hereinafter: ‘auto-callable issuances’) whereby notes are automatically redeemed should the underlier meet a strike level on specified observation dates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2026_7716
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 24/04/2026

Reporting of debt securities issued but not yet paid up

What is the expected representation for a debt security issued but not yet paid up in the templates REPRICING CASH FLOWS (J05, J06 and J07)? Is the expected monetary inflow supposed to be reported and if so in which row?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
  • ID: 2025_7610
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as final Q&A: 24/04/2026

Approach in case of misalignments in the taxonomy of the single data point model

Approach to be taken in case of misalignment in the taxonomy and the instructions provided in the single data point model.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7730
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Z 09.01 (FMI 1) - Reporting of FMI services related to payment systems under EBA 4.2.

According to the Annex for IT Solutions related to the ITS on resolution reporting, entities should be allowed to report “Payment systems” as a type of system in Z 09.01, c0040. However, such possibility is not allowed under the DPM table layout and data point categorization (i.e. the annotated tables). This raises a question on how should entities ensure compliance with the ITS.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7729
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Template Z08.01: Validation rules contradict ITS requirements

Do validation rules v6446_m and v6447_m for template Z 08.01 (Relevant services) correctly apply in all reporting situations, given that they enforce the condition {c0030} ≠ {c0050} (Service Recipient must differ from Service Provider)? Should these rules be amended or removed to correctly reflect cases of intra‑entity services, where both fields may legitimately contain the same entity name according to the IT Annex II: Instructions of EBA/ITS/2025/04?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7683
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Reporting of key values for open sheet tables starting with Z 07.01

We kindly ask for clarification regarding the reporting of key values in case of open sheet tables starting with Z_07.01 for the RESOL2 module. How should the information regarding the location of critical function be reported considering there are two mandatory keys?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7681
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Résolution 1 - how liabilities have to be reported on column 0056 of Z11.00

We want to confirm how liabilities have to be reported on column 0056 of Z11.00 ? It is indicated in "Annex II: Instructions": Type of Liability For liabilities which are reported under Z02.00-c0020-Row as “r0210 - Liabilities towards other entities of the resolution group”, indicate the type of liability as it would have been reported in Z02.00, had the liability not been considered as excluded. We would like to know if operations that are not subject to reclassification in line 0210 of Z02.00 will have to be reported ? Indeed, following the final taxonomy, we note that control e7484 from the validation rules indicates that column C0056 "type of liability" must not be null: In Z 11.00, no empty value in columns (c0020, c0021, c0030, c0040, c0045, c0050, c0053, c0055, c0056, c0060, c0080, c0100, c0110, c0120, c0130, c0150) Furthermore, we note that the list of accepted values for column C0056 is extended to all liabilities in Z02 and not just to liabilities reclassified in line 210.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7679
  • Topic: Resolution plans
  • Date of submission:
  • Published as final Q&A: 03/04/2026

ITS (Annex II: Instructions), II.20.4, p. 64 II. 20 Z 08.01— Relevant services (SERV 1) II.8.1; General instructions

We would appreciate a confirmation of the following interpretation: In the context of a group level resolution planning reporting, only services associated with core business lines, whose continuity is necessary for the effective execution of the resolution strategy and any consequent restructuring are reported in Z08.01 of the 2026 Resolution Reporting. Is the understanding correct, that essential services of core business lines which are mapped in Z07.03 only to legal entities that are classified as liquidation entities in the PIA Assessment of the Resolution Authority must not be reported by the Union Parent Undertaking or Resolution Entity on a consolidated basis in Z08.01?

  • 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
  • ID: 2025_7671
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Amount to be reported as MREL eligible amount and amount qualifying as Own Funds non-CET1 instruments, taking into account phase-out as applicable

Could you please clarify whether in granular Resolution Plans reports (formerly SRB LDR) Z11.00, Z12.00, Z13.00 and Z14.00 the amount to be reported for Own Funds instruments (columns labelled Amount meeting the conditions for MREL eligibility ) and columns reporting on the Amount qualifying as Own Funds is: the carrying value + accrued interest as recommended for the measurement of non-CET1 instruments or the outstanding amount (outstanding principal + accrued interest) as mentioned for the Amount meeting the conditions for MREL eligibility?  For the columns reporting Own Funds there is no specific guidance on the amount type to be reported other than the amount of the instrument qualifying as Own Funds. 

  • 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
  • ID: 2025_7614
  • Topic: Resolution plans
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Reporting of unused prior permission amounts with no specification of subordination

How should banks report the unused prior permission amount in case the insolvency rank is not specified, and the unused prior permission amount exceeds the amount of eligible liabilities subordinated to excluded liabilities before the deduction of prior permission amounts (M02.00-r0100 to M02.00-r0130)? Furthermore, how should the unused prior permission amount be reported in cases where the subordinated layer only includes Tier 2 instruments, as T2 in phase-out is not covered by a general prior permission amount for eligible liabilities.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2025_7580
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 03/04/2026

COREP Additional Liquidity Monitoring Metrics - technical implementation of DPM v4.2 for template C_67.00.a and C_67.00.w - SubCategory "new_CO4" used instead of "new_CO1"

With DPM v4.2 the modeling of template C_67.00.a and C_67.00.w has been changed to use SubCategory new_CO4 instead of new_CO1. Now it is possible to submit the “LEI code”, the “MFI Code” and “Type of identifier, other than LEI or MFI code” but not the “National code”. How should a national code be reported in template C_67.00.a and C_67.00.w and what is the reason behind this change?

  • 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
  • ID: 2026_7731
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/03/2026