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  1. Home
  2. Single Rulebook Q&A
  3. 2026_7827 Templates Z07.01.2 - Timing of substitution for Lending
Question ID
2026_7827
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
7
Type of submitter
Credit institution
Subject matter
Templates Z07.01.2 - Timing of substitution for Lending
Question

Please confirm the time buckets to be used for reporting col 0130 'Timing of Substitution' in template Z07.01.02 FUNC1 Lending

Background on the question

Annex II instructions (see below) do not define the buckets for reporting 'Timing of Substitution' for Lending function. Note that buckets have been defined for other economic functions templates.

 

The Axiom reporting solution is using the same timing of substitution bucket as Payments economic function, which may not be appropriate for lending.

Annext II instruction for Lending:
"Timing - Expected time for substitution
Estimate the time necessary for the economic function provided by the reporting
entity to be absorbed by the market in a crisis situation. This includes: 
•  the expected time needed by one or several competitor(s) to accomplish the legal and technical steps to take over the function; as well as  
•  the time required by users of the service to move to another service provider.

 

For lending, for example, this does not refers to a run-off of the outstanding portfolio or the transfer of that portfolio to a prospective buyer, but rather to the ability of households corporates and governments to obtain similar loans from other providers.

 

As a proxy for the former, provide an estimate of the time it would take the reporting entity to absorb in its own business (part of) the service provided by another institution, at a reasonable cost, in a crisis situation. Report the estimated time to substitution in the buckets provided in the template:"

Submission date
10/04/2026
Rejected publishing date
15/09/2026
Rationale for rejection

This question has been rejected because the matter it refers to has already been identified and the issue has been addressed through the technical amendments to DPM 4.4 Phase 1. The related instructions will be clarified at the next available opportunity.

Status
Rejected question

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