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Financial Conglomerates: Reporting of exposures by counterparty within the FC.06 template in light of the reference to “connected client groups” according to Article 4(1), point (39), of Regulation (EU) No 575/2013 and the response to Q&A “2025_7381"

We are seeking clarification about a possible mismatch between ITS and DPM 3.5 (ID v22748_u - T1 L 06.00, column c0020) as part of the compilation of the template FC.06 Template - “Risk Concentration - Exposure by counterparties" within the FiCoD supervisory reporting. In particular, Commission Implementing Regulation (EU) 2022/2454 of 14 December 2022 refers to Article 4(1), point (39), of Regulation (EU) No 575/2013 with reference to the concept of “group of connected clients” for the purposes of reporting in the FC.06 template Risk Concentration – Exposure by counterparties.  If applied the alternative approach, this could require representing on separate rows cases where the same external counterparty simultaneously belongs to a group of connected clients whose parent entity is the central government, as well as to another group of connected clients, resulting in the loss of the uniqueness criterion for records based on the current DPM and the responses provided by the EBA in Q&A ID_2025_7381. We therefore ask whether, for the purposes of reporting in the FC.06 template: the reference to Article 4(1), point (39), of Regulation (EU) No 575/2013 should be considered binding and, consequently, whether the FC0040 column “Name of the group (in case of group of counterparties)” should be regarded as a key value for the unique representation of exposures towards external counterparties in case of an affirmative answer, which would imply the repetition of the same exposures towards the same external counterparty across multiple rows of the FC.06 template, what the allocation criterion for the exposures across the rows should be. Additionally, in case of an affirmative answer for the purposes of reporting in the FC.06 template, we ask what the allocation criterion for the exposures for the purpose of reporting in FC.07 is, as the application of this regulatory reference would imply considering the same exposures to the same external counterparty multiple times.

Legal act: Directive 2002/87/EC (FiCOD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates

Reporting of minority interest on the NSFR

In the Annex XIII of the applicable reporting framework, and regarding the COREP C 81.00, within the NSFR ITS decision tree, Question 2 refers to “Additional Tier 1 capital” (ID 2.1.2), while Question 11 refers to “Minority interests” (ID 2.9.3). Should qualifying minority interests that relate to Additional Tier 1 capital instruments be reported: under the “Additional Tier 1 capital” row (ID 2.1.2), or under the “Minority interests” row (ID 2.9.3)? 

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Ban imposed by certain national authorities on the use of the term “neobank” for payment institution

Does the divergence of positions among national authorities regarding the freedom to use the term "neobank" for payment institutions not compromise the consistent application of EU law in the banking sector and the objective of convergence of supervisory practices, and does it not hinder competition and the development of cross-border activities? 

Legal act: Directive 2015/2366/EU (PSD2)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Requirement for a consolidated ICARA process under Directive (EU) 2019/2034

Does Directive (EU) 2019/2034 require investment firms that are subject to prudential consolidation under Article 7 IFR to prepare, maintain and document an ICARA process on a consolidated basis? In particular, does Article 25(4) IFD impose an obligation to perform the ICARA at consolidated level, or does it merely extend the application of Part Three without creating a standalone consolidated‑ICARA requirement?

Legal act: Directive (EU) 2019/2034 (IFD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Reporting of registered covered bonds issued by the reporting institution

Is the definition of covered bonds issued in the context of F 35.00 ("Covered bond issuance") also applicable for F32.04 ("Sources of encumbrance");  i.e. should registered covered bonds issued by the reporting institution in compliance with 2009/65/EG; article 52; paragraph 4 be reported in lines 90 ("Debt securities issued") and 100 ( "of which: covered bonds issued") of F32.04?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Identical cell F_13.02.1 Collateral obtained during the period

Could you pls de-activate the 'identical cells' below in DPM 4.2.1? VariableVID = 5459395 ---> {F_13.02.1.a, r0020, c0010}=={F_13.02.1.c, r0080, c0040} ----> 120783==366904 VariableVID = 5460187 ---> {F_13.02.1.a, r0020, c0020}=={F_13.02.1.c, r0080, c0050} ----> 120791==366905    

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Scope of the exemption under Article 7(7) with respect to Level 1 assets referred to in Article 10(1)(c)

Do the requirements laid down in Articles 7(5) and 7(6) of Delegated Regulation (EU) 2015/61 apply to assets referred to in Article 10(1)(c)?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

When trying to submit reports to our portal Finanssivalvonta it gives us this error: An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing

When trying to submit reports to our portal Finanssivalvonta it gives us this error:     An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing. What does this mean? we cant seem to figure that out

Legal act: Other
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Own funds requirement for entities authorized as Crypto Asset Service Provider (CASP), Electronic Money Institution (EMI) and Investment Firm (IF)

How should own funds requirements be determined for a legal entity authorised as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCAR), as an electronic money institution (EMI) under Directive 2009/110/EC, and as an investment firm under Regulation (EU) 2019/2033 (IFR) and Directive (EU) 2019/2034 (IFD), in particular where certain crypto asset services – such as the transfer of crypto assets on behalf of clients – require a specific CASP authorization rather than a notification regime, and given the absence of explicit provisions governing the interaction between the two prudential frameworks?

Legal act: Regulation (EU) No 2023/1114 (MiCAR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Shadow Banking Definition - Alternative Investment Funds

Where an entity qualifies as an alternative investment fund (“AIF”) for the purposes of Directive 2011/61/EU, but its constitutive documents do not explicitly prohibit loan origination or the purchase of third‑party lending exposures, should that entity be regarded as meeting the criterion in Article 1(c)(iii) of the relevant Delegated Regulation 2023/2779 (Identification of Shadow Banking) solely on the basis of what it is permitted to do, notwithstanding that it does not in practice carry out banking activities, as referred to in Article 394(2) CRR? In particular, should the assessment of whether an AIF falls within the definition of a shadow banking entity be determined by: the theoretical scope of permitted activities under its rules or instruments of incorporation, or the actual activities carried out by the AIF in the ordinary course of its business?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Z03.01 - Own funds requirements on individual level: r0300 / r0500 if a waiver exists

According to EBA validation rule v6433_m a minimum Total SREP Capital Requirement (TSCR) ratio (r0300) of 0.08 should be reported. However, the reporting subject has been granted a waiver from the minimum capital requirements under Article 92 CRR and is not required to comply with the 8% Total Capital ratios on a standalone basis, as these requirements are fulfilled and monitored at the consolidated group level. This also affects the "Overall capital requirement (OCR) ratio" (r0500) due to validation rule v6436_m. If the validation rule v6433_m will not be deactivated, which value needs to be reported in such cases?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z09.02 Requirement to Report CEF and Its Country When an FMI Only Supports a CBL

According to the EBA instructions, columns c0020, c0030, and c0040 are exclusively intended for essential FMIs (CEFs). However, in the template taxonomy, even when selecting “No” in column c0020 to indicate that the FMI is not a CEF, the system still requires completion of columns c0030 and c0040. We do not fully understand this requirement: if we have indicated that the FMI is not a CEF, we should not be expected to provide any CEF in column c0040, nor the CEF country in column c0030. Could you please advise on how we should proceed? As it stands, we would either need to enter an arbitrary CEF for FMIs that support a CBL but not a CEF, or the system should allow leaving columns c0030 and c0040 blank when c0020 = “No”.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inability to Assign More than One CEF or CBL to an FMI

It is currently not possible to report more than one CBL (c0050–c0060) per FMI (Z09.02).Historically, several FMIs have been reported as contributing to two Core Business Lines; however, upon uploading the data now, the system only accepts one CBL per FMI. Could you please confirm whether this is the expected treatment? If so, which CBL should be selected when both are equally relevant and one must be discarded in order to complete the submission?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 03.01 - Validation rule V7511_m_0

We encounter an error on template Z 03.01 due to validation rule v7511_m_0. For the total amount c0010 in row r0400 the validation rules checks if the sum of r0410 + r0420 + r0430 + (max r0440; r0450) = r0400. Should the validation rule not also take into account the row r0460? 

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting - Template Z 08.04

According to ITS, the c0040 "ID" column should be key, but in reality it is not. This does not allow for the representation of the connections between Critical Services (combination of c0005, c0010, and c0020) and multiple Critical Functions (c0040).

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Instructions to follow regarding new EBA Resolution Reporting - Z 09.02

The key values of the templates are c0010 (ID representing the combination of user, FMI, system type, and intermediary), c0030 (Country), and c0040 (Critical Function ID). The c0060 "Core Business Line ID" is not set as a key. However, this does not allow for granular representation of multiple business lines associated with the same FMI–Critical Function combination. As communicated to us by our national authority, the EBA will not be providing a hotfix for DPM 4.2, and therefore the bank will adhere to the technical constraints imposed by the current technical documentation.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Technical problem due to validation

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.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Erroneous configuration Z 07.01.2 FUNC 1 LEN

Given the absence of any specified time bands for the “Lending” template in the Annex, it appears likely that this may be due to an erroneous configuration. In this context, we respectfully request the EBA to review the matter and provide guidance at your earliest convenience regarding the appropriate procedure for institutions in this case.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Validation in Z_01.02

According to the EBA instructions for validating Template Z 01_02 (source: DPM table layout and data point categorization), the validation key for this template is the code in column 0020 (expected to be unique). This is the investor code (also with validation on number of characters), which may actually have more than one investment within the group (as is the case with our bank). The existing validation rule prevents correct reporting. Please provide instructions on how to proceed with this template.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting

The Z_01.02 template of the RESOL1 survey, according to “Annex II – instructions”, should represent the situation of the shareholdings of the companies in a group, greater than 2%. The template requires that in the “code of Investor (c0020)” column we enter the code of the company that holds the participation, and in the “code of Investee (c0050)” column we enter the code of the company that is being participated. In some cases, the relationship between the two columns (Investor/Investee) is “1 to 1”: one Investor holds a participation in only one Investee. In other cases, the relationship between the two columns can be “1 to many”: one Investor holds participations in multiple Investees. However, in the annotated table layout of sheet Z_01.02, the only key value is indicated as “code of Investor – c0020” only, which therefore cannot be duplicated in the template in the situation where one investor holds participations in many investees. This rule does not allow us to correctly represent the information required by the template, because the case of a group company (investor) that holds participations in “n” other companies (investees) would violate the rule of the single key value (code of Investor – c0020). The filling of this template with exclusively the key value of column 0020, would give an incorrect representation of the requested data.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

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