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List of Q&A's

RESOL1 - how balance of cash collateral received as variation margin for intra group Repurchase Agreements should be reported in Z11.00 and Z02.00

How cash collateral received as variation margin for intragroup Repo trades be reported in Z11.00 and Z02.00 when the underlying Repo has already matured? What should be the insolvency ranking (c0030) of this balance intragroup variation margin in Z11.00?

  • 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_7895
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Template Z08.02: Reporting of applications owned and operated by affiliated service providers

Where a reporting entity receives services from an affiliated entity and relies on applications that are owned, managed and operated by that affiliated service provider, should those applications be reported in template Z08.02 by the receiving entity?Alternatively, should template Z08.02 be limited to operational assets that are owned, managed or directly controlled by the reporting entity, with dependencies on affiliate-owned applications being reflected through the relevant service provider and outsourcing/inter-affiliate reporting templates?

  • 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_7926
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Completion of the Z08.02 Template

In Z_08.02, are we expected to map operational assets to external services or only to intra-entity services?  If we are expected to map operational assets to external services, for external services which relate to support we receive on IT systems, should columns 0030, 0080, 0040 and 0050 be populated with data related to the respective IT system or should they be left blank? Additionally, if we report a service related to physical transportation of cash, should columns 0030, 0080, 0040 and 0050 be left blank considering that we don't need any asset to receive the service from the external provider?    

  • 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_7927
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Application of the currency mismatch treatment to self-employed individuals (natural persons carrying out an economic activity) under Article 123a CRR.

Does the currency mismatch treatment set out in Article 123a of Regulation (EU) No 575/2013 (CRR) apply to exposures to self-employed individuals (natural persons carrying out an economic activity), where such individuals are natural persons that meet the criteria of Article 123 CRR, even if they are considered SMEs in accordance with Article 5(9) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7724
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/07/2026

Sectoral classification of UK credit institutions

In the context of FINREP reporting, institutions are required to apply counterparty sector classifications as laid down in Annex V to Regulation (EU) No 680/2014. Following the withdrawal of the United Kingdom from the European Union, banks established in the UK are considered third‑country institutions and are no longer subject to the CRR/CRD framework. This has raised interpretative questions regarding their appropriate sectoral classification as counterparties in FINREP, in particular when ensuring consistency across EU supervisory reporting frameworks.    

  • 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
  • ID: 2026_7843
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/07/2026

To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7753
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as final Q&A: 03/07/2026

Validation rules taxonomy V4.0 C_47.00, C_43.00.a, C_43.00.b, C_43.00.c - v4456_m

Validation rule v4456_m is a consistency check between the total leverage exposure value before "Asset amount deducted - Tier 1 capital" in C 47.00 (LRCalc) and exposure values reported in C 43.00.a/b/c: sum ({tC_47.00, r0010-0269, c0010}) + {tC_47.00, r0900, c0010} + {tC_47.00, r0910, c0010} = sum ({tC_43.00.a, (r0010, r0040, r0050, r0060, r0065, r0070), c0010}) + sum ({tC_43.00.b, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0010}) + sum ({tC_43.00.c, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0020}) Validation rule v4456_m and the instructions provided by the EBA for forms LR4 and LRCalc are inconsistent with respect to “General credit risk adjustments to off balance sheet items” (LRCalc row 0181) and “Excluded guaranteed parts of exposures arising from export credits” (if related to off balance sheet exposures, part of LRCalc row 0252). Please provide instructions in which row(s) the amounts in LRCalc in rows 0181 and 0252 (if related to off balance sheet exposures) should be reflected in form LR4.

  • 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
  • ID: 2025_7664
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/07/2026

Reporting additional leverage ratio exposure amount in accordance with Article 3 CRR in C43.00

Where should additional leverage ratio exposure amount in accordance with Article 3 CRR be reported in Leverage ratio template C43.00?

  • 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
  • ID: 2025_7587
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/07/2026

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