Since Article 1 (1) (c) of Directive 2014/59/EU (BRRD) includes mixed-activities holding companies within the scope of application of the Directive, excluding mixed-activities holding companies from the group recovery plan would run against the latter article, regardless of the fact that the draft of the group recovery plan is to be drafted by the Union parent undertaking, which is not the mixed activity holding company.

The reading of Article 7 comes out more clearly if read in conjunction with Articles 1 (1) (c) and (33) of Directive 2014/59/EU (BRRD): The wording of "the undertaking as a whole" in Article 7 (1) is meant to be read together with the reference to "the group" in that same article, so that the content of the recovery plan should cover the group as a whole, including the mixed activity holding company. The "headed by the Union parent undertaking" in Article 7 (1) refers to the level of the drafter of the plan, namely the EU parent holding company.

Disclaimer:

This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate General of the Commission (Directorate General Financial Stability, Financial Services and Capital Markets Union) has prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.