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List of Q&A's

Annex II of Instructions for resolution planning reports vs defined drop downs in DPM model

Annex II specifies that for template Z 09.01, the allowed value for column c0040 should be “Payment systems”, so why is that not included in DPM and what would then be correct system type for e.g. NKS/STEP2/TARGET2?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7754
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Annex II of Instructions for resolution planning report template Z03.01 vs EBA validation rule v7511_m

Could you please check the logic behind the EBA validation rules regarding Combined Buffer Requirement in RESOL report? Details are stated in the background section.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7751
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Template Z 03.01 Own funds requirements– validation rule v7511_m

In template Z03.01 column 0010 row 0400 Combined buffer requirement according to instructions should be equal to COREP (OF): {C 04.00;740;010}). However, the hotfix validation rule v 7511_m of the EBA creates a discrepancy. The validation rule v7511_m is: with {tZ_03.01, c*, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max( {r0440}, {r0450} ) (i.e the Combined Buffer Requirement in Z 03.01-r0400 must be equal to the sum of r0410  + r0420 + r0430 + the highest of (r0440; r0450)) The validation rule is has an error status, but its referencing appears incorrect. Can the Q&A please be amended?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7749
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Missing value in DPM Z09.01, column 0040 System type

'- In the DPM 4,2 file in tab Z_09.01 the column 0040 (System type) there is a missing value 'Payment system'. This value is used by the bank and was present in the previous taxonomy 4.0. with the value qx2049 Payment systems. The value is also present in the EBA guidance. Could you please add the value qx2049 Payment systems in the taxonomy 4.2 in the Z09.01, column 0040?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7748
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Error in Validation rule v7511_m

'- In the Validation rules for DPM 4.2, the validation rule v7511_m seems wrong. The current formula {r0400} = {r0410} + {r0420} + {r0430} + max( {r0440}, {r0450} ) doesn't include the line r0460 in the sum. Indeed, for for the entities which are not GSIIB and which report their requirement only on r0460 line dedicated for the OSIIB, the sum is wrongly calculated.  Could you please update the validation rule including the line 460 in the formula?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7747
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Blocking Key Value (qLEC:qLE) Legal entity

'- In the DPM 4,2 file in tab Z_01.02 the fields 0020 (Code) there is a blocking Key value which prevents the declaration of all the ownerships inside of the consolidated group. The field 0020 (Code) is set up as a unique value which can be declared only once in the tab while according to the guidance the institution should declare in this tab all the investors and investees entities. A s one investor entity can have several invetsees entities, the institution shloud be able to declare several line with the same code.    Could you please confirm if the Key value (qLEC:qLE) as a unique value should be removed from the taxonomy? for information, it's an urgent question for RESOLUTION

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7746
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Reporting of multiple investees per investor in template Z_01.02 (Ownership structure)

In template Z_01.02, how should institutions report cases where one investor is linked to more than one investee, given that column 0020 (code of investor) is defined as the Key value and columns 0040 and 0050 identify the investee?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7743
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

RES 4.2 taxonomy - template Z_01.02 “Ownership Structure”

The bank has noticed an inconsistency identified in the RES 4.2 taxonomy regarding template Z_01.02 “Ownership Structure”. In this template, the technical key is currently set only on field 0020 – “Investor Code” (Unique identifier of the legal entity or investor). Since each investor may be associated with more than one investee, this results in a duplication of the key whenever multiple relationships exist for the same investor. Given that the key must be unique, it is not possible under the current setup to correctly represent the group structure. Otherwise, generating a duplicated key would make the file incorrect and not processable and would result in an error of the whole RESOL1 package.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7742
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Classification of payment systems providers in Resol2 Z_09.01 template.

How it’s possible to classify FMI Providers for Payment systems in template Z_09.01?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7741
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Inconsistency between ITS and Taxonomy

In the Annex II of the ITS for report Z0600, Column 0030 - DGS , the ITS clearly states that the value other can be reported :"If the officially recognised DGS of which the entity is member is not listed above, ‘oter shall be reported".   But the DPM 4.2 as a restriction fur such column based on subcateogy EN3 which does not allow any "other" value and just nammed the principal DGS to be used. In the previous version of the DPM, the DGS column was technically binded by another enumeration that was allowing an other value : x128 - Other deposit guarantee scheme.   Can you explain us : if it's normal that the DPM 4.2 is now excluding the Other value even if the ITS seems to say that it's a valid option if it's correct for a client for which some CI may used some DGS not listed in the subcateroy EN3, to let this column empty?  

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7737
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Template Z 01.02 Resolution Planning – Uniqueness Requirement for Column 0020

In template Z01.02 in column 0020 the unique identifier of the legal entity or investor referred in column 0010 should be reported. In our ownership structure, several investors hold participations in multiple investee entities, meaning the same investor appears in multiple rows of Template Z 01.02. Because the identifier in Column 0020 must consistently represent the same legal entity, it must be repeated across those rows. This, however, conflicts with the requirement that Column 0020 contain a unique value for each row. 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7735
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Mapping of Critical Services to Critical Functions Z08.04

We need additional guidance in Z08.04 on how to report a critical service linked to multiple critical functions

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7732
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

FMI Reporting

In defining field 0040 (System type) in the latest hotfix to EBA DPM 4.2 (January 14th), EBA did not include value eba_qMA:qx2046 Payment Systems in the list of accepted values in the Annotated Template Layout

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7723
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Z 09.01 FMI 1 - System type enumerated property

A clarification is needed regarding which option in the enumerated list used in the DPM for column 0040 of Z 09.01 should be selected to report the system type ‘Payment systems

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7721
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Inconsistencies Between ITS Templates and DPM 4.2 Annotated Table Layouts for RESOL 1/2

When inconsistencies exist between the ITS templates and the DPM 4.2 Annotated Table Layouts, which source should be considered authoritative for reporting purposes?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7720
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

EBA RESOLUTION TEMPLATE Z09.02 ON FINANCIAL MARKETS INFRASTRUCTURES

We need additional guidance in Z0902 on how to report FMIs related to Core Business Lines only, or FMIs related to more than a single Core Business Line. We kindly ask your guidance on how to report the following use cases: A purely Essential FMI, that is an FMI not linked to any Critical Economic Function (hence, with 0060 set to empty), but linked to one Core Business Line; An FMI that needs to be linked to more than one Core Business Line (hence, where we would need to insert several distinct values in 0060)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7713
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Z 01.02 - Ownership structure (ORG 2)

The template require to report all the shareholders (or equivalent) of the group’s entities with more than 2% of share capital (or equivalent) or voting rights, and all the shareholdings (or equivalent) held by entities of the group. In the annotated table for the Z_01.02, the key value is represented only by the column 0020 “Code”. In the event that the same investor holds shares in multiple entities of the Group, it is not possible to report all the shares as an investor can only be reported once.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7706
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Net liquidity outflows over a 30 calendar day stress period

If a facility agreement includes a condition that causes a committed revolving facility to become non‑revolving during a period of stress for the credit institution, should the net liquidity outflow for LCR purposes then be calculated based on the maturity date of each individual drawing rather than the overall facility maturity date?

  • 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
  • ID: 2026_7719
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026