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List of Q&A's

Resolution Templates

We need additional guidance in Z08.02 on how to report the field Governing Law (0090) when the field 0070 is reported as owned. 

  • 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_7733
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Pillar 3 Data Hub CONDIS: ITS and reporting framework modelling constraint affecting EU LI1/LI2/CC2

In the P3DH Common Disclosure “CODIS” module technical package (taxonomy applied from Reporting framework 4.1 and 4.2), the following data points appear to be modelled as the same underlying data point (they share the same data point identifier within the module): template EU LI2, (table K_64_03_a, column a, rows 10, 20); template EU LI1, (table K_64_01_b, column b, row 10 and table K_64_01_d, column b, row 10); template EU CC2 (table K_66_02_b, column b, row 10, table K_66_02_d, column b, row 10) Therefore, the platform rejects XBRL/CSV submissions where different values are reported for these locations (e.g., “duplicate facts”). How should institutions proceed for the purposes of the structured submission (XBRL/CSV) in this situation? How should any resulting differences between the information prepared in accordance with the ITS disclosure instructions and the EU LI2 be addressed? (i.e. the figures disclosed in the published PDF: for example, where EU LI1 column g is populated (being different from zero) and EU LI2 is expected to exclude exposures not subject to RW / subject to capital deductions).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7745
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Reporting of deposits fully secured by collateral with a value of zero

In which row of the Z02.00 template of the ‘Resolution Planning’ reporting, and in which granular template (Z13.00 or Z16.00), should deposits fully secured by collateral with a value of zero be reported? It should be noted that these exposures are not eligible for bail-in.  

  • 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_7771
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Article 2.2 Reporting by credit institutions permanently affiliated to a central body

In a particular case of an atypical structure of credit institutions permanently affiliated to a central body when: a) none of them is a resolution entity and the central body is a liquidation entity b) the cohort of institutions does not formally qualify as a group nor as a resolution group due to their atypical association c) the cohort is prudentially supervised individually at the level of the central body and in aggregate at the cohort level (our regulations use the term aggregate level, not the consolidated level) d) in case that the central body is liquidated, the whole cohort can no longer function and has to be dissolved, thus, for resolution purposes, the whole construction can be treated as a single liquidation entity.       In this case, is it correct, to read art. 2.2 in conjunction with recital no. 4 and ask the central body to report the templates on an individual basis and by that understand the aggregate level of the whole cohort?

  • 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_7777
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

The question pertains to resolution template Z.07.01, in which deposits are evaluated to determine whether they should be classified as a CEF.

In column 0035 of template Z.07.01, where the amount of uncovered deposits must be reported, should the amount provided be the portion exceeding €100,000 per deposit, or the portion exceeding €100,000 per depositor?

  • 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_7781
  • Topic: Recovery plans
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Reporting of intragroup transactions in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5

We kindly ask for clarification on the intragroup transactions reporting in the context of the criticality assessment of economic functions. Should the intragroup transactions be included or excluded from the data provided in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 ?

  • 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_7784
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Critical Functions - Z.07.03

Could you please clarify, with regard to completing template Z 07.03 (FUNC 3), whether core business lines not included in the predefined list should be reported under “Other” with an appropriate description or mapped to the closest predefined category?

  • 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_7801
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Granular Reporting of Liability data: Currency designation for precious metals

According to "Annex II: Instructions" for (EU) 2025/2303, the currency designation in, for example, c0120 of Template Z14.00 - Other Financial Liabilities (not included in other tabs, excluding intragroup) should follow ISO 4217. In the currency selection list of the Annotated Table Layout, there are no specifications for precious metals such as gold. Which value has to be chosen from the list of currencies 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
  • ID: 2026_7802
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Granular reporting of liability data: currency designation for XAF / XOF

Annex II - Instructions refers to the ISO-4217 codes for the currencies selectable in the templates. Upon comparing the Annotated Table Layout with the ISO-4217 contents, we noticed the absence of the entries for XAF (Central African CFA Franc) and XOF (West African CFA Franc). Which currency code should 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
  • ID: 2026_7805
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 26/06/2026

Obstacle assessment of a mandatory client segment selection screen in a redirection journey

Does a mandatory step in a redirection journey, where a Payment Service User (PSU) must manually select their client segment (e.g., retail or corporate) on an intermediary screen (web interface) before being redirected to the ASPSP's authentication app, constitute an obstacle under Article 32(3) of the RTS, if such a step is not present when the PSU accesses their account directly via the ASPSP's native mobile application?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2025_7602
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/06/2026

Clarification of the scope of the term "authentication procedures" in the context of the RTS and the EBA Opinion on obstacles

Does the term "authentication procedures" in the context of the EBA Opinion on obstacles (EBA/OP/2020/10) refer only to the final SCA method, or does it encompass the entire end-to-end user journey required to complete the authentication? Does this mean that any additional steps in the TPP flow, such as the need to click on a QR code image or manually enter a username to invoke the authentication app, which are not present in the direct channel, constitute a failure to support the same "authentication procedure"?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2025_7606
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/06/2026

Definition of "equivalent authentication procedure" for journeys initiated from a mobile application

When a Payment Service User (PSU) initiates a service from a Third Party Provider's (TPP) mobile application, what is the correct "equivalent authentication procedure" of the ASPSP that should be used as the benchmark for assessing whether "unnecessary steps" have been added? Is it the ASPSP's mobile web browser authentication journey, or is it the ASPSP's native mobile banking application authentication journey?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2025_7607
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/06/2026

Obligations of ASPSPs to inform PISPs about the execution status of individual payments executed under a standing order initiated via API.

Under PSD2, when a PISP initiates a standing order on behalf of a PSU, the ASPSP generally communicates only the result of the standing order setup (i.e. whether the standing order has been accepted or rejected). In practice, PISPs typically do not receive information on the execution status of each individual payment transaction carried out under that standing order, even though each execution constitutes a separate payment transaction under PSD2. This creates uncertainty as to whether ASPSPs are required to make this information available to PISPs in the same way it is made available to PSUs in online banking channels.   Should ASPSPs provide PISPs with information on the execution status (e.g. executed or rejected) of each individual payment transaction executed under a standing order initiated by a PISP?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7644
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 12/06/2026

PSU support in dedicated and redirected interfaces.

In the context of Article 32 of the RTS (Commission Delegated Regulation (EU) 2018/389), are ASPSPs required to provide PSUs with access to support channels (e.g., helpdesk, chat, telephone) within redirected authentication and authorisation interfaces for payment initiation, at a level equivalent to that in their standard online banking interfaces? Additionally, could you please clarify whether the absence of such support channels in the redirected payment initiation interface constitutes a functional obstacle under paragraph 3 of Article 32?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2025_7672
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 12/06/2026

Provision of rejection reasons for payment orders initiated via PISPs.

When an ASPSP provides a PSU, through its online banking channels, with specific information on the reason for the rejection of a payment order, in accordance with Article 36(1)(b) of Commission Delegated Regulation (EU) 2018/389, should that same information also be provided to the PSU via the interface made available for a payment initiation order, whether through a decoupled or redirection flow? Furthermore, should that information also be communicated to the PISP through the dedicated interface?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2025_7675
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 12/06/2026

Disclosure – Template EU CQ4: Treatment of cash balances at central banks and other demand deposits

Should cash balances at central banks and other demand deposits be included in disclosure template EU CQ4 as provided in the EBA IT Solutions / Mapping Tool (versions 4.1 and 4.2) even though such positions are not mentioned in Article 442(c) and (e) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2026_7812
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 05/06/2026

Clarification on validation v3078m under FINREP reporting

In reference to the validation rule 'v3078_m' should the held for trading positions be excluded while reporting the maximum amount of the guarantee received in FINREP F_09.02

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2026_7807
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/06/2026

Access to national credit databases for all EU creditors for both cross-border and domestic mortgage loan transactions

Should Article 21 MCD be interpreted as requiring a Member State to ensure that a credit database established in that Member State can be accessed also by creditors from a Member State other than the one where a credit database is located for the purpose of granting a mortgage loan to consumers and monitoring consumers’ compliance with the credit obligations over the life of the credit agreement?

  • Legal act: Directive 2014/17/EU (MCD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7588
  • Topic: Creditworthiness assessments
  • Date of submission:
  • Published as final Q&A: 05/06/2026

SPV repack transactions

Do SPV repackaging transaction on standardised platforms incur counterparty credit risk (CCR) or is the termination scenario considered a contractual feature that only results in market risk? If these transactions are subject to counterparty credit risk, how should the value of the collateral be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7575
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 29/05/2026