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List of Q&A's

Definition of “Substitutability” of CCPs and the connected reporting of “Alternative Providers” for the purpose of the template Z 09.04 (RESOL II).

Should the concept of substitutability of CCPs, and consequently the identification of alternative providers to be reported in template Z 09.04, be interpreted restrictively, i.e. limited to CCPs or intermediaries that are capable of providing an equivalent clearing service for the same trading venue and/or market(s)? Or should a broader interpretation of substitutability be applied, focusing on the economic function, business and regulatory objectives as well as the post-trade nature of the clearing service, under which a CCP might be substitutable not only by a concurrent CCP active on the same market, but also by: the substitution of the entire trade value chain (e.g. trading venue – CCP – CSD or trading venue – CSD); or the use of an intermediary/broker capable of rerouting either the trading and clearing activity or the transactions executed on behalf of the reporting institution through alternative FMIs, provided that such arrangements achieve a comparable economic and functional outcome for the reporting institution.

  • 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_7912
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Changes between DPM 4.0 and DPM 4.2: An error has occurred while performing schema validation for the node '{http://www.eba.europa.eu/xbrl/crr/dict/met/4.2}ei86': "Other Countries" does not parse as a QName value. C_14.00 TC_14.00-L005-C0190 = Other Countries

Given that the "other countries" code was removed from  the DPM 4.2, how should these exposures be reported in COREP? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7908
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/10/2026

IPRE and Property Collateral for Credit Risk Mitigation

When assessing the eligibility of immovable property collateral for the purposes of credit risk mitigation (CRM), how should institutions interpret the interaction between the definition of income‑producing real estate (IPRE) exposures in Article 4(75b) CRR and the conditions set out in Article 199(2) CRR for recognising immovable property as eligible collateral under the IRB approach? In particular, can immovable property collateral be recognised for CRM purposes under Article 199(2) in situations where an exposure is classified as IPRE under Article 4(75b), where repayment of the exposure is supported by diversified rental income streams across multiple properties or tenants, such that the repayment of the facility does not materially depend on the performance or cash flows of any single underlying property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7898
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Reporting template RESOL 2 – Z.08.02

With reference to the reporting template RESOL2 - Z 08.02 SERV 2 we would kindly ask for a clarification: column “Contract ID - 0080” has obviously been defined as a primary key, which results in the fact, that values need to be submitted for this column in any case. However, the column “Contract ID - 0080” can only be filled out once column “Legal/ Contract Type - 0070” is not set to “owned”. An owned asset does not have a contract ID attached to it and is thus reported as an empty string. May we kindly ask you to confirm our view in this regard?

  • 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_7844
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Templates Z09.01 - Services provided to and received from FMI/Intermediary

Could the EBA please confirm instruction interpretation for col 0220 and Col0210 of Template 09.01 (FMI Services - Providers and Users).

  • 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_7824
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Template Z09.01: EBA Taxonomy alignment with ITS Requirements -Annex II instructions

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?

  • 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_7823
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Reporting of certain counterparty identifiers in templates Z 12.00 and Z 14.00

How should entities report the identifier and the type of identifier when reporting at an aggregate level or when the counterparty is unknown?

  • 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_7815
  • Topic: Resolution plans
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Where to classify Tier2 Subordinated issuances when they loss their MREL computability due to an earlier call (already announced on markets)

When a subordinated issuance loses its MREL eligibility due to an early call that has been announced to the market but not yet executed, should it be reported in row r037x or r0531? Additionally, if r037x is selected, should the Insolvency Ranking be adjusted accordingly under Spanish regulation?

  • 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_7797
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Clarification on whether non resident / cross border clients must be included in CFR reporting under the new ITS.

The new EBA draft ITS on resolution planning reporting contains several references to non‑resident clients within the Critical Functions Report (CFR). In previous years, the SRB instructed institutions to exclude non‑resident or cross‑border clients from the CFR. We would like to understand whether the new ITS now requires institutions to include non‑resident client figures, and if this reflects a change in reporting expectations.

  • 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_7725
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Accrued interest on withdrawable central bank reserves

Should accrued interest on withdrawable central bank reserves be reported on Row 050 and Row 100 of C72.00 template?

  • 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_7617
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Scope of Article 6 lit. c RTS

Is the criticality of the services affected pursuant to Article 6 (c) RTS to be assumed for every successful, malicious and unauthorised access to the network and information systems of the financial entity, regardless of whether the affected systems support critical or important functions? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/1772 - RTS on the classification of ICT-related incidents and cyber threats
  • ID: 2026_7779
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as final Q&A: 02/10/2026

RESOL1 - how balance of cash collateral received as variation margin for intra group Repurchase Agreements should be reported in Z11.00 and Z02.00

How cash collateral received as variation margin for intragroup Repo trades be reported in Z11.00 and Z02.00 when the underlying Repo has already matured? What should be the insolvency ranking (c0030) of this balance intragroup variation margin in Z11.00?

  • 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_7895
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Template Z08.02: Reporting of applications owned and operated by affiliated service providers

Where a reporting entity receives services from an affiliated entity and relies on applications that are owned, managed and operated by that affiliated service provider, should those applications be reported in template Z08.02 by the receiving entity?Alternatively, should template Z08.02 be limited to operational assets that are owned, managed or directly controlled by the reporting entity, with dependencies on affiliate-owned applications being reflected through the relevant service provider and outsourcing/inter-affiliate reporting templates?

  • 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_7926
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Completion of the Z08.02 Template

In Z_08.02, are we expected to map operational assets to external services or only to intra-entity services?  If we are expected to map operational assets to external services, for external services which relate to support we receive on IT systems, should columns 0030, 0080, 0040 and 0050 be populated with data related to the respective IT system or should they be left blank? Additionally, if we report a service related to physical transportation of cash, should columns 0030, 0080, 0040 and 0050 be left blank considering that we don't need any asset to receive the service from the external provider?    

  • 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_7927
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Application of the currency mismatch treatment to self-employed individuals (natural persons carrying out an economic activity) under Article 123a CRR.

Does the currency mismatch treatment set out in Article 123a of Regulation (EU) No 575/2013 (CRR) apply to exposures to self-employed individuals (natural persons carrying out an economic activity), where such individuals are natural persons that meet the criteria of Article 123 CRR, even if they are considered SMEs in accordance with Article 5(9) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7724
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/07/2026

Sectoral classification of UK credit institutions

In the context of FINREP reporting, institutions are required to apply counterparty sector classifications as laid down in Annex V to Regulation (EU) No 680/2014. Following the withdrawal of the United Kingdom from the European Union, banks established in the UK are considered third‑country institutions and are no longer subject to the CRR/CRD framework. This has raised interpretative questions regarding their appropriate sectoral classification as counterparties in FINREP, in particular when ensuring consistency across EU supervisory reporting frameworks.    

  • 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_7843
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/07/2026

To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7753
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as final Q&A: 03/07/2026

Validation rules taxonomy V4.0 C_47.00, C_43.00.a, C_43.00.b, C_43.00.c - v4456_m

Validation rule v4456_m is a consistency check between the total leverage exposure value before "Asset amount deducted - Tier 1 capital" in C 47.00 (LRCalc) and exposure values reported in C 43.00.a/b/c: sum ({tC_47.00, r0010-0269, c0010}) + {tC_47.00, r0900, c0010} + {tC_47.00, r0910, c0010} = sum ({tC_43.00.a, (r0010, r0040, r0050, r0060, r0065, r0070), c0010}) + sum ({tC_43.00.b, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0010}) + sum ({tC_43.00.c, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0020}) Validation rule v4456_m and the instructions provided by the EBA for forms LR4 and LRCalc are inconsistent with respect to “General credit risk adjustments to off balance sheet items” (LRCalc row 0181) and “Excluded guaranteed parts of exposures arising from export credits” (if related to off balance sheet exposures, part of LRCalc row 0252). Please provide instructions in which row(s) the amounts in LRCalc in rows 0181 and 0252 (if related to off balance sheet exposures) should be reflected in form LR4.

  • 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: 2025_7664
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/07/2026

Reporting additional leverage ratio exposure amount in accordance with Article 3 CRR in C43.00

Where should additional leverage ratio exposure amount in accordance with Article 3 CRR be reported in Leverage ratio template C43.00?

  • 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: 2025_7587
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/07/2026