Question ID
2020_5293
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
4
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
Article/Paragraph
Annex II, paragraph 56
Type of submitter
Credit institution
Subject matter
Z 08.00 - Critical Services
Question
What is the procedure that should be followed when the type of service is not in the predefined list available for selection, as one cannot add a new type?
Background on the question
As indicated in Regulation (EU) No 2018/1624, annex II, paragraph 56 (page 56), in Z08.00, the combination of values reported in columns 0010 (Service Type), 0030 (Service recipient), 0050 (Service provider), 0070 (Critical function: country) and 0080 (Critical Function: ID) forms a primary key which must be unique for each row of the template. This means that for a certain type of service, there must be only a unique provider delivering the service to an entity and relating to a particular economic function. This is an issue, since there is often more than one critical provider regarding the same type of service and associated to the same economic function in a certain country. Therefore, this situation leads to multiple keys that could be repeated and causes the unsuccessful validation of XBRL instances. In addition, the service type list is not exhaustive and one cannot add a new type to the predefined list. Furthermore, be also aware that there are services that fit into more than one type, but for filling purposes, it can only be selected one type.
Submission date
Final publishing date
Final answer

The purpose of the reporting of template Z 08.00 is the assignment of the respective combination of service type / service recipient / service provider to a critical function. 

In situations where a specific service is provided by several service providers or several services are provided by the same service provider, another row for the same service type / service provider should be added. From version 3.1 of the reporting framework (end-2021 reporting) onwards, column 0005 of template Z 08.00 is part of the row key, to enable the reporting of multiple contracts between the same service recipient and provider regarding the same type of service and supporting the same critical function, but having different features in terms of estimated time to substitutability etc. 

Regarding the assignment of the service to a category, the listed main categories and sub-categories of services are sufficient for reporting purposes. The category that best suits the specific service should be selected. Where possible, the sub-category should be reported (two-digit identification).  

Where no sub-category exists or no sub-category properly describes the service provided, the main category (one-digit identification) should be reported. In light of the abovementioned purpose of the reporting and the possibility to allocate the service to the corresponding main category, a multiple selection of the service type and an additional field for a more precise description is not necessary. 

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

Disclaimer

The Q&A refers 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.