- Question ID
-
2026_7797
- Legal act
- Directive 2014/59/EU (BRRD)
- Topic
- BRRD Reporting
- Article
-
Z02.00 and Z12.00
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
- Article/Paragraph
-
II.3 Z 02.00 - Liability Structure (LIAB 1)
- Type of submitter
-
Credit institution
- Subject matter
-
Where to classify Tier2 Subordinated issuances when they loss their MREL computability due to an earlier call (already announced on markets)
- Question
-
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?
- Background on the question
-
r037x:
Subordinated liabilities (not recognised as own funds)Liabilities which will only be repaid under national insolvency law after all classes of ordinary creditors and senior non-preferred creditors have been repaid in full. This includes both contractually and statutorily subordinated liabilities. In the case of holding companies, unsubordinated debt securities may also be reported in this category (i.e. structural subordination).
Only subordinated instruments that are not recognized as own funds shall be included in this category.
This row shall also include that part of subordinated liabilities that qualifies in principle as own funds, but is not included in own funds due to phase-out provisions such as Article 64 of Regulation (EU) No 575/2013 (remaining maturity) or Part 10 of the Regulation (EU) No 575/2013 (grandfathering impact).
r0531:
Of which: (part of) subordinated liabilities recognised as own funds
This breakdown identifies the legal instruments that constitute (part of) Tier 2 own funds.
- Submission date
- Status
-
Question under review
