- Final EBA Single Rulebook Q&As, newest first. Older answers refer to the text (and numbering) in force when they were given.
Template Z08.02: Reporting of applications owned and operated by affiliated service providers
2026_7926 · 18 Sept 2026 · BRRD Article 11(3)
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?
Answer
According to Article 3(1) of the ITS, the information reported in template Z 08.02 covers all group entities. Since Z 08.02 is reported once at group level, it is not limited to operational assets owned, managed or directly controlled by the receiving entity. It should also include operational assets owned and operated by affiliated entities where those assets underpin services supporting the group's critical functions or core business lines. The assets should be reported once at group level and linked to the relevant service as required by the template. The information in column 0070 (legal/contract type) should be provided from the perspective of the entity to which the intra-group or intra-entity service provider belongs.
Completion of the Z08.02 Template
2026_7927 · 18 Sept 2026 · BRRD Article 11
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?
Answer
Z 08.02 identifies operational assets that underpin services supporting critical functions or core business lines, including where the related service is provided externally. However, an asset owned and operated solely by a third-party service provider is outside the scope of Z 08.02 where no intra-group or intra-entity service provider requires access to it. Where an external provider supports an IT system or application that is owned, leased or licensed by a group entity and that asset supports the relevant service, the asset should be reported and columns 0030, 0040, 0050 and 0080 should be completed as applicable. Conversely, where an external service, such as physical cash transportation, does not depend on an operational asset of a group entity, no asset should be reported in Z 08.02 merely because the third party uses its own assets to provide the service. The relevant columns should therefore not be left blank for an asset that is otherwise reported; rather, no Z 08.02 asset record is required in that case.
Clarification on the reporting of negative fair value changes of hedged items in the Annual Resolution reporting
2026_7795 · 18 Sept 2026 · BRRD Article 11(3)
How a negative amount of fair value changes of hedged items should be reported in template Z02.00?
Answer
Where the amount of “Fair value changes of the hedged items in portfolio hedge of interest rate risk”, corresponding to FINREP F 01.02 row 0160, is negative and is reported separately in template Z 02.00, that negative amount shall be reported in row 0400 “Residual liabilities” in the relevant carrying amount column.
The corresponding outstanding amount shall be reported as zero. Under the instructions for template Z 02.00, the outstanding amount represents the principal and accrued interest constituting the claim that the creditor would file in insolvency proceedings. The fair value change arising from hedge accounting does not itself modify that claim.
Where a warning validation rule is triggered solely as a consequence of reporting such a negative fair value change in row 0400, this should not prevent submission of the report.
Reporting of deposits fully secured by collateral with a value of zero
2026_7771 · 26 Jun 2026 · BRRD Article 11
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.
Answer
According to the third paragraph of Article 44(2) BRRD, neither (i) the requirement to ensure that all secured assets relating to a covered bond cover pool remain unaffected by the bail-in tool, nor (ii) the exclusion of secured liabilities envisage in Article 44(2)(b) BRRD shall prevent resolution authorities, where appropriate, from applying the bail-in tool in relation to any part of a secured liability or a liability for which collateral has been pledged that exceeds the value of the assets, pledge, lien or collateral against which it is secured.
Against this backdrop, it should also be noted that secured finance transactions (such as central bank financing or repurchase agreements) are to be reported in Z 16.00, by netting set.
Finally, contrary to the statement made in the question, reference to row 0120 of Z02.00 (Secured liabilities - collateralized part) is available in the list of possible values for Z 13.00;c0020. The value of the pledge, lien or collateral is to be reported in Z 13.00,c0110.
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
2026_7784 · 26 Jun 2026 · BRRD Article 11
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 ?
Answer
Intragroup transactions should be excluded in the data provided in templates Z 07.01 as the criticality assessment should be performed with regard to the economic functions provided by the reporting entities to third parties. FINREP references are provided purely as guidance on the requested information. Taking note on the different scope of reported information, reconciliation between the corresponding data in FINREP and templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 is not obligatory.
Intragroup transactions should be excluded in the data provided in templates Z 07.01 as the criticality assessment should be performed with regard to the economic functions provided by the reporting entities to third parties. FINREP references are provided purely as guidance on the requested information. Taking note on the different scope of reported information, reconciliation between the corresponding data in FINREP and templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 is not obligatory.
Nevertheless, reporting entities should be aware that certain SRB data quality and validation rules (e.g. SRBDQ_0452 to SRBDQ_0497) may assess the consistency between information reported in resolution planning templates and corresponding FINREP data. While such validations do not alter the reporting scope of templates Z 07.01 or create a requirement for a full reconciliation with FINREP, differences arising from the exclusion of intragroup transactions or other scope-related considerations may need to be appropriately documented and explained. Institutions should therefore ensure that any material discrepancies can be justified in the context of the applicable validation framework and supervisory expectations.
Resolution Templates
2026_7733 · 26 Jun 2026 · BRRD Article 11(3)
We need additional guidance in Z08.02 on how to report the field Governing Law (0090) when the field 0070 is reported as owned.
Answer
If an asset is owned and not governed by a contractual arrangement, in the absence of an option allowing to report the requirement as “Not applicable”, reporting entities should report the country code of the reporting entity or, alternatively, 'GA:qx2000' All other countries.
Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2
2026_7767 · 30 Apr 2026 · BRRD Article 11
Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL2RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z08.01, column 0010 Service Type?
Answer
For the purpose of choosing the type of service in the picklist, reporting entities should prioritise the sub-categories listed in the Annex II (II.20.5) in the form of bullet points. All sub-categories are available in the picklist.
The services that should be considered as the main categories (and used only if the relevant sub-category is not available) are: ‘Human resources support’, ‘Information technology’, ‘Transaction processing, including legal transactional issues, in particular anti-money laundering’, ‘Real estate and facility provision or management and associated facilities’, ‘Legal services and compliance functions’, ‘Treasury-related services’, ‘Trading/asset management’, ‘Risk management and valuation’, ‘Accounting’, ‘Cash handling’, ‘Other Service Type’.
All the main categories mentioned in the previous paragraph are available in the picklist.
The notion of ‘one-digit identification’ and ‘two-digit identification’ is to refer to the main categories and sub-categories, respectively.
Completion of Z08.x Templates
2026_7775 · 30 Apr 2026 · BRRD Article 11
- Does the “Unique service title” in Column 0020 of Z08.01 need to be unique to every contract i.e, if we have 150 different contracts should we have 150 different “Unique service titles” or can we have multiple contracts sharing the same service title?
- If we can have multiple contracts sharing the same “Unique service title”, should the “Service identifier” in column 0005 of Z08.01 be the same for each contract having a particular “Unique service title”?
- In Z08.01 can we assign multiple “Unique service titles” (Column 0020) and multiple “Service types” (Column 0010) to the same contract?
- In Z08.02 should the “Asset identifier” in Column 0030 be unique to each asset or to each contract? By way of example, if we have two contracts for leasing of two different premises, should we assign them the same asset identifier or a different one?
- In Z08.02 Column 0120, should contracts which require us to pay for the service in advance be considered to have an “Alternative mitigating action”?
- In Z08.03 Column 0030, if we have the same role name (e.g. “analyst”) across multiple departments should that role have the same “Role ID” across all departments or should we assign one ID per department?
- In Z08.03 Column 0060, should the “Criticality” value be the same as that in Column 0120 of Z08.01?
- If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.03 can represent multiple contracts?
- In Z08.03 can we assign multiple roles to the same contract?
- If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.04 can represent multiple contracts?
- In Z08.04, can we assign multiple critical functions (Columns 0030 and 0040) to the same contract?
- If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.05 can represent multiple contracts?
- In Z08.05 can we assign multiple core business lines (Column 0030) to the same contract?
Answer
As a general remark, the starting point for the mapping of templates Z08.01 to Z08.04 should be the identification of the relevant services in accordance with the EBA/GL/2022/01. As detailed in the instructions on Z08.01,c0020, services should be identified in a targeted way, to allow a mapping exercise at granular level.
- In accordance with paragraphs 21 to 23 of the EBA Guidelines on improving resolvability for institutions and resolution authorities under articles 15 and 16 BRRD (EBA/GL/2022/01, the “Resolvability Guidelines”), institutions should have comprehensive, searchable and up-to-date MIS and databases (all together, referred as ‘service catalogue’) providing granular information in relation to the linkage to the contractual arrangements governing the relevant services. As per the Resolvability Guidelines, where several contracts fall under a master agreement, institutions may include in the service catalogue and contract repository only the master contract, provided that they can identify all contracts that are made under each master contract and that the relevant resolution authorities do not object. This approach could be mirrored for the purpose of resolution planning reporting in Z08.01.
- As per the instructions, the Service Identifier in Z08.01,c0005 refers to the service reported under c0020, and is independent of the Contract ID reported in Z08.01,c0130.
- As per the instructions, ‘Unique service titles’ and ‘Services types’ should refer to the nature of the service and the institution’s service delivery model, not to the contract. Contracts should be assigned to the relevant services, leveraging on service catalogue.
- As per the instructions, the asset identifier refers to the asset reported under Z08.02;c0050. In the example provided, each relevant premise should be allocated a unique asset identifier.
- Z08.02;c0120 requests the institution to reflect whether it has implemented alternative mitigating actions. In line with paragraphs 19 and 20 of the EBA Resolvability Guidelines, the credibility of these alternative mitigating actions is to be determined by the relevant resolution authority, on the basis of the justification provided by the institution.
- In cases where the roles names reported in c0040 belong to different departments, different role IDs are expected.
- In Z08.03;c0060, the ‘Criticality’ value should be the same as that in Z08.01;c0120.
- In Z08.03 roles are mapped to services, not to contracts.
- In Z08.03 roles are mapped to services, not to contracts.
- In Z08.04 critical functions are mapped to services. Please refer to QA 2026_7703.
- In Z08.04 critical functions are mapped to services. Please refer to QA 2026_7703.
- In Z08.05 core business lines are mapped to services. Please refer to QA 2026_7703, by analogy.
- The reply provided to QA 2026_7703 should be applied also to Z08.05, by analogy.
Template Z08.01: Validation rules contradict ITS requirements
2026_7683 · 3 Apr 2026 · BRRD Article 11(1)
Do validation rules v6446_m and v6447_m for template Z 08.01 (Relevant services) correctly apply in all reporting situations, given that they enforce the condition {c0030} ≠ {c0050} (Service Recipient must differ from Service Provider)? Should these rules be amended or removed to correctly reflect cases of intra‑entity services, where both fields may legitimately contain the same entity name according to the IT Annex II: Instructions of EBA/ITS/2025/04?
Answer
It is confirmed that, in accordance with the instructions set out in Annex II of EBA/ITS/2025/04, for intra-entity services the Service Recipient (column 0030) and the Service Provider (column 0050) may legitimately be the same entity.
Accordingly, the severity of validation rule v6446_m will be amended from “error” to “warning”. This adjustment ensures that cases referring to intra-entity services can be appropriately identified, while still allowing the underlying pre-condition to be monitored.
As regards validation rule v6447_m, its current treatment will be maintained at this stage in order to continue verifying the relevant pre-condition. However, the rule may be further refined in future reporting cycles to enable a more automated and precise assessment of that pre-condition.
Reporting of key values for open sheet tables starting with Z 07.01
2026_7681 · 3 Apr 2026 · BRRD Article 11
We kindly ask for clarification regarding the reporting of key values in case of open sheet tables starting with Z_07.01 for the RESOL2 module. How should the information regarding the location of critical function be reported considering there are two mandatory keys?
Answer
For open sheet tables starting with Z_07.01 under the RESOL2 module, both keys LCF and LCR are mandatory and must be reported.
Regarding the LCF key, only Member State codes are expected to be provided.
In cases where regional specification is not applicable, the LCR should be filled with the value “N/A”.
In cases where regional specification is applicable, the LCF should contain the code for “Country sub-region” (eba_GA_qx2008) and the LCR should be filled with the relevant NUTS 2021 classification code.
Z 09.01 (FMI 1) - Reporting of FMI services related to payment systems under EBA 4.2.
2026_7729 · 3 Apr 2026 · BRRD Article 11(3)
According to the Annex for IT Solutions related to the ITS on resolution reporting, entities should be allowed to report “Payment systems” as a type of system in Z 09.01, c0040. However, such possibility is not allowed under the DPM table layout and data point categorization (i.e. the annotated tables). This raises a question on how should entities ensure compliance with the ITS.
Answer
In table Z09.01, where the type of system providing services to the user is ‘Payment systems’, the option ‘Not applicable’ should be chosen in the picklist available on column c0040. The value ‘Payment systems’ should then be provided in column c0220 (on Services provided by FMI/Intermediary).
When the reported FMI correspond to a payment system, the reporting entity should complete all relevant fields in the template (e.g., ‘FMI name’, ‘FMI code’, etc.), as if the option ‘Payment systems’ had been available. As a result, the warning related to validation rule v90347 should be disregarded when the warning is triggered by the payment system nature of the FMI.
Approach in case of misalignments in the taxonomy of the single data point model
2026_7730 · 3 Apr 2026 · BRRD Article 11(3)
Approach to be taken in case of misalignment in the taxonomy and the instructions provided in the single data point model.
Answer
If a potential misalignment or contradiction is identified in the technical packages conforming (i) the IT solutions and (ii) the DPM table layout and data point categorization (i.e. the annotated tables), the reporting entities are requested to raise a Q&A to confirm the existence of such misalignment or contradiction, so that it can be duly corrected or clarified accordingly in upcoming technical packages.
In the absence of a reply or formal guidance, as a general rule priority should be given to the instructions available in the DPM table layout and data point categorization (i.e. the annotated tables), as these are the documents that (i) contain the most relevant technical specifications necessary for developing IT reporting solutions and (ii) allow reporting entities and resolution authorities to perform the validation rules envisaged in Annex III of the CIR. Otherwise, reliance on the IT solutions alone would not guarantee the ability of the bank to successfully submit the report and might prevent the execution of validation rules.
Clarification of Z02.00, row 0200 (DGS liabilities)
2018_4213 · 15 Nov 2019 · BRRD Article 11(3)
What is expected to be reported in Z 02.00, row 0200 (DGS liabilities) as the instructions only refer to Article 44 (2) point g (iv) of Directive 2014/59/EU and liabilities to deposit guarantee schemes arising from contributions due in accordance with Directive 2014/49/EU?
Answer
Liabilities to deposit guarantee schemes (DGS) from contributions due in accordance with Directive 2014/49/EU (DGSD) are all liabilities to deposit guarantee schemes arising from contributions due under Article 10 of DGSD, both ordinary (in accordance with Article 10(1) as well as extraordinary (in accordance with Article 10(8) DGSD), as well as in the case of payment commitments, where the accounting treatment results in the payment commitment being fully reflected on the balance sheet (as a liability), under Article 10(3) DGSD.
Consequently, all the above should be reported in Z 02.00, row 0200.