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List of Q&A's

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:

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:

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:

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:

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:

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:

Access to national credit databases for all EU creditors for both cross-border and domestic mortgage loan transactions

Considering that Article 19 of Directive (EU) 2023/2225, repealing Directive 2008/48/EC (the ‘Consumer Credit Directive 2’), grants creditors from a Member State other than the one where a credit database is located access to that database only in relation to cross-border credit transactions, does the reference to the framework of Directive 2008/48/EC in Recital 20 of Directive 2014/17/EU (the ‘Mortgage Credit Directive’) imply that Article 21 MCD likewise provides creditors with access to databases solely for cross-border credit transactions?

  • Legal act: Directive 2014/17/EU (MCD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7588
  • Topic: Creditworthiness assessments
  • Date of submission:

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:

SPV repack transactions (collateral eligibility)

For recognising received financial collateral when calculating the exposure value under the counterparty credit risk (CCR) framework, does Article 207(2) CRR – which requires that the credit quality of the obligor and the value of the collateral shall not have a material positive correlation – apply?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7576
  • Topic: Market risk
  • Date of submission:

SPV repack transactions

Do SPV repackaging transaction on standardised platforms incur counterparty credit risk (CCR) or is the termination scenario considered a contractual feature that only results in market risk? If these transactions are subject to counterparty credit risk, how should the value of the collateral be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7575
  • Topic: Market risk
  • Date of submission:

fully and completely secured by mortgages for the purpose of the deduction of non performing exposures

In the context of the CRR3 and the application of the deduction of non-performing exposure from Common Equity Tier 1 as per article 47c, we would like to clarify the requirements of “ fully and completely secured by mortgages” in order to determine the "secured part of a non-performing exposure".

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7503
  • Topic: Credit risk
  • Date of submission:

Payment account definition

Does an account provided by a payment service provider, linked to a payment instrument that can be used to make payment transactions to [certain] third parties (e.g. merchants) from that account, as well as to withdraw cash from that account (e.g. from an ATM) and receive incoming payments in the respective account from the same payment users to which the funds were transferred (i.e, refunds from merchants) fall under the definition of a payment account in accordance with PSD2, even if the respective account cannot receive funds from third parties via credit transfers?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7463
  • Topic: Other topics
  • Date of submission:

Application of PSD2 provisions to the issuance and redemption of electronic money tokens

1) An EMI is acting solely as an issuer of EMTs ("EMTI") to its customers - crypto asset service providers (CASPs), these then provide the EMTs to their retail customers to be used for cryptoassets trading. EMTI does not maintain any fiat currency payment account for CASPs, nor provide any cryptocurrency services to them within the meaning of Articles 60(4) and 62 of the MICAR. Does the issuance of EMTs lead to a contractual relationship between the EMT holder (CASP, to whom the EMT is issued) and the EMTI within the meaning of PSD2 and EMD2? Is this contract passed on to the subsequent EMT holders who will acquire the EMTs from CASPs? 2) What is the legal nature of the acts of issuance and redemption of the EMTs?3) Which provisions of PSD2, if any, apply to issuance and redemption of the EMTs?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7457
  • Topic: Authorisation of issuers of ARTs and EMTs (MiCAR)
  • Date of submission:

Calculation of the standardised total risk exposure amount or S-TREA under Article 92(25)

Does the calculation of standardised total risk exposure amount, or S-TREA, require Firms to recalculate RWAs for standardised approaches where modelled inputs have been used? Specifically, do CVA RWAs calculated using IMM modelled EADs need to be re-calculated using EADs that have not been derived using a modelled approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7429
  • Topic: Own funds
  • Date of submission:

Calculation of COH according to Article 20 vs. Art. 12 (1) Subparagraph 2

How exactly does the calculation of COH, AUM, ASA, DTF, NPR and TCD on the basis of IFR Article 12 (1) Subparagraph 2 differ from the general method for calculation COH in IFR Article 20?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7359
  • Topic: Capital requirements
  • Date of submission:

Requirements for the purpose of treating exposures secured by mortgages on immovable property as duly secured from an RWA computation perspective under CRR Article 124(2) of the CRR.

Can a global insurance against damages on a portfolio of exposures secured by immovable properties subscribed directly by the lending institution be considered as compliant with the requirement of Article 208(5) of the CRR - that is to say considered, under the standardized approach, as meeting the operational requirements for the purpose of treating exposures secured by mortgages on immovable property (or in case an institution has opted for the application of article 108(5)(a) allowing to consider a guaranteed exposure as an exposure secured by a mortgage on immovable property) as duly secured from an RWA computation perspective under Article 124(2) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7293
  • Topic: Credit risk
  • Date of submission:

emission allowances

Sentence 2 of paragraph 3 of Annex II CRR refers to point (11) of Section C of Annex I MiFID, i.e. to emission allowances. Does that mean that spot market emission allowances are to be treated as derivative contracts listed in Annex II, even though they are not derivative in character?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7255
  • Topic: Other issues
  • Date of submission:

Application of Instant Payment Regulation (IPR) to Securities Providers

Do you agree on the non-applicability of the obligation to provide instant credit transfers (within a time horizon of 10 seconds), introduced by IPR, to depositaries, custodians, and entities responsible for payments or local facility for foreign CIUs distributed in a Member State, based on the exclusion provided by article 3, paragraph 1, letter i), of directive 2015/2366 (PSD2)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7249
  • Topic: Authorisation and registration
  • Date of submission:

Prudential treatment for exposures in leasing real estate under construction

Should exposures in "real estate under construction instrumental leasing" fall within the definition of ADC exposure of Article 4(78a) of Regulation (EU) No. 575/2013 as amended by Regulation (EU) No. 1623/2024, or instead be treated applying the RW provided for unsecured exposures towards the lessee?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7226
  • Topic: Credit risk
  • Date of submission: