Question ID
2026_7785
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
11
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
Templates Z_01.02 („Ownership Structure“)
Type of submitter
Industry association
Subject matter
Technical problem due to validation
Question

The current validation logic effectively forces the submission of an incomplete and therefore factually incorrect report, as only one participation can be reported per investor. We kindly ask you to review this issue and inform us promptly how institutions should proceed in this case. Please confirm whether an adjustment of the validation rule is planned or whether there is an alternative approach to correctly reflect our group structure.

Background on the question

According to the reporting requirements, template Z_01.02 is intended to reflect the full ownership structure of the group. This includes all participation relationships. A key aspect of our group structure is that a single legal entity (e.g. the parent company) may act as an investor in multiple subsidiaries.
 

Template Z_01.02 is structured such that each row represents a single ownership relationship (investor → investee). To correctly reflect the situation described above, it is essential to list the parent company as the investor (columns 0010/0020) in multiple rows, each time in combination with the respective participation (investee, columns 0040/0050).

However, we observe that an explicit validation rule enforces the uniqueness of column 0020 (Investor Code) across all rows of the template.


This validation rule directly contradicts the requirement to report a complete group structure. It makes it technically impossible to report an entity that holds more than a single participation.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because EBA guidance or clarification is not needed. This can be the case where harmonisation of practices through the Q&A process is not considered necessary; or that the issue is not material, for example because it is considered to be relevant only to a limited set of institutions or other stakeholders.

Status
Rejected question