In 2020 the SRB made a request to banks for resolution reports with the aim of collecting information for drawing up and implementing resolution plans, including calibrating Minimum Required Eligible Liabilities (MREL) targets. During the collection of this data, Resolution Reports were requested from the 120 banking groups in scope of the exercise.
For 2021, the SRB once again highlights the importance of high quality, complete and timely data submissions. The ability to provide the necessary data to support the implementation of the resolution strategy, is a key resolvability issue, to be adequately considered by banks’ top management. To ensure banks meet the reporting deadlines (see timeline below), the SRB recommends that all banks implement the following measures:
- To support high quality and complete data, the resolution reports should be submitted in line with the published guidance, with validation checks performed by the bank ensuring reconciliation with its FINREP and COREP regulatory reporting requirements (where applicable). See guidance documents below.
- Banks should ensure that they have the necessary IT processes in place to facilitate a timely, controlled and robust reporting process generating consistent and reliable results.
Data quality and availability on time are key items to consider within the resolvability assessment. In this context, the SRB can consider the failure to comply with the information requirements as impediments to resolvability, potentially significant. It is therefore important that the quality of and deadlines for the resolution reporting submissions are respected.
The SRB, in collaboration with the National Resolution Authorities (NRAs), is starting its annual Resolution Reporting Data Collection exercise. During the 2021 edition, the collection will be based on data as at 31 December 2020. The process will integrate lessons learned from the previous exercises and take into account the feedback received from NRAs as well as the industry.
The scope of the reports has evolved to reflect the needs for resolution planning, while limiting the burden of reporting for the groups and entities. Nevertheless, the SRB retains the flexibility to request additional information wherever and whenever it deems necessary to do so.
As concerns the reporting perimeters, (Sub)-Consolidated views are based on the prudential scopes of consolidation, whereas Resolution Groups are to be defined by Internal Resolution Teams, in collaboration with the respective institutions.
Overview of SRB Resolution Reporting Requirements for 2021
The SRB is responsible for centralising resolution reporting for banks under its remit, before these are transferred to the European Banking Authority (EBA).
Note that the reports listed below will be collected by the SRB from NRAs exclusively in XBRL format. As was the case in previous collections, NRAs will communicate banks’ reporting requirements, as determined in collaboration with the SRB.
|EBA Template number||EBA Template code||Name of the template or group of templates||EBA Short name||SRB Replacement Report||SRB Reference||Reporting deadline|
|ENTITY INFORMATION, GROUP STRUCTURE, CONTACTS AND DEPENDENCIES|
|1||Z 01.00||Organisational structure||ORG||N/A||N/A||30/04/2021|
|INFORMATION ON ON- AND OFF-BALANCE SHEET ITEMS|
|2||Z 02.00||Liability Structure||LIAB||LDR||T 01.00||31/03/2021|
|3||Z 03.00||Own funds requirements||OWN||LDR||T 02.00||31/03/2021|
|4||Z 04.00||Intragroup financial connectedness||IFC||LDR||T 03.01-.03||31/03/2021|
|5.1||Z 05.01||Major counterparties (Liabilities)||MCP 1||N/A||N/A||30/04/2021|
|5.2||Z 05.02||Major counterparties (off-balance sheet)||MCP 2||LDR||T 12.00||31/03/2021|
|6||Z 06.00||Deposit insurance||DIS||N/A||N/A||30/04/2021|
|CORE BUSINESS LINES, CRITICAL FUNCTIONS AND RELATED INFORMATION SYSTEMS AND FINANCIAL MARKET INFRASTRUCTURES|
|Critical functions and core business lines|
|7.1||Z 07.01||Criticality assessment of economic functions||FUNC 1||CFR||T 20.01-.05,T 98.00||30/04/2021|
|7.2||Z 07.02||Mapping of critical functions to legal entities||FUNC 2||N/A||N/A||30/04/2021|
|7.3||Z 07.03||Mapping of core business lines to legal entities||FUNC 3||N/A||N/A||30/04/2021|
|7.4||Z 07.04||Mapping of critical functions to core business lines||FUNC 4||N/A||N/A||30/04/2021|
|8||Z 08.00||Critical services||SERV||N/A||N/A||30/04/2021|
|FMI services - providers and users|
|9||Z 09.00||Users, providers and users - mapping to critical functions||FMI 1||FMIR||T 30.00-T33.00||30/04/2021|
|10.1||Z 10.01||Critical Information systems (General information)||CIS 1||N/A||N/A||30/04/2021|
|10.2||Z 10.02||Mapping of information systems||CIS 2||N/A||N/A||30/04/2021|
|OTHER SRB REPORTING TEMPLATES (included in EBA 2.10 Reporting Framework)|
|Liability Data Report|
|N/A||N/A||Identification of the report||N/A||LDR||T 99.00||31/03/2021|
|N/A||N/A||Securities (Including CET1, AT1 & Tier 2 Instruments; Excluding intragroup)||N/A||LDR||T 04.00||31/03/2021|
|N/A||N/A||All Deposits (excluding intragroup)||N/A||LDR||T 05.01||31/03/2021|
|N/A||N/A||Other financial Liabilities (not included in other tabs, excluding intragroup)||N/A||LDR||T 06.01||31/03/2021|
|N/A||N/A||Secured Finance, excluding intragroup||N/A||LDR||T 08.00||31/03/2021|
|N/A||N/A||Other Non-Financial (not included in other tabs, excluding intragroup)||N/A||LDR||T 09.00||31/03/2021|
The SRB has highlighted the overlap between the EBA and the SRB reporting requirement. Where an SRB Replacement Report exists (e.g. Z 02.00 is replaced by T 01.00), ONLY the replacement report should be sent by the bank (T 01.00).
Where no SRB Replacement Report exists (e.g. Z 10.01), then the Z report needs to be sent (if requested by the NRA/SRB from the reporting entity).
With the exception of T99.00, the "Other SRB Liability templates" should only be filled when explicitly requested by the NRA/SRB (granular reporting of POE files).
The reporting deadline for the LDR is 31/03/2021; for all other reports 30/04/2021.
Below are links to the Guidance documents for SRB-originated resolution reports:
- Guidance to the 2021 Liability Data Report – LDR v1.01
- Guidance to the 2021 Critical Functions Report - CFR v1.0
- Guidance to the 2021 Financial Market Infrastructure Report – FMIR v1.0
- 2020 Annex on Insolvency Ranking v1.0
SRB Taxonomy Extension
The SRB’s taxonomy publication represents an SRB extension to the EBA 2.10 ITS. This extension contains minor changes to the EBA taxonomy and validation rules which the SRB deems necessary to facilitate the data collection in XBRL format in 2021:
• Expand the current EBA two entry points (RESOL_Con and RESOL_Ind) to the 5 SRB entry points for LDR (ldt-con, ldt-res, ldt-ind-oth, ldt-ind-poe, ldt-con-poe), 4 entry points for CFR (cfr-con, cfr-res, cfr-ind, cfr-con-poe), 2 entry points for CIR (cir-con, cir-ind) and one entry point for FMIR (fmi-con);
• Improve data quality and data collection efficiency by expanding the list of Validation rules and modifying certain existing validation rules.
Banks are reminded that they are expected to reflect both the EBA 2.10 XBRL taxonomy (available on the EBA website) and the SRB taxonomy extension (see below) when building their XBRL reporting systems for 2021.
SRB Taxonomy extension documents:
SRB Taxonomy extension – sample XBRL instances:
The XBRL instances in the zip file below are provided as examples and fulfil the XBRL2.1 specification and ResRep 5.0.7 taxonomy (which is an extension of EBA2.10).
These files pass the Level 1 & Level 2 data validations but have not been configured to pass the Level 3 checks described in the Guidance documents.
All values stored in the XBRL facts are fictitious.
Additional Liability Data Collection (Reporting in Excel format!!)
In addition to the Commission Implementing Regulation 2018/1624 minimum requirements and SRB-specific reports outlined above, the SRB has decided to anticipate ongoing work with the EBA on MREL reporting following changes to the Banking Package.
It should be noted that this data request will not pre-empt the orientation of the MREL policy: this data request is inherent to the build-up of the policy, and has been designed to ensure the timely collection of data starting March 2021.
The data request for the Additional Liability Report is reflected in a dedicated reporting template and related Guidance to be used for the 2021 data collection:
- 2021 Template Additional Liability Data Report v1.0
- Guidance to the 2021 Additional Liability Data Report v1.0
Timeline for the 2021 Resolution Reporting data collection process
*Banks are expected to reflect both the EBA 2.10 XBRL taxonomy (available on the EBA website) and the SRB taxonomy extension (published on the SRB website) when building their XBRL reporting systems for 2021.
**QnA organised by SRB will be limited to questions on SRB-originated reports (LDR, CFR, FMIR). Questions on other CIR reporting requirements should be raised with the EBA.
***CIR – Commission Implementing Regulation 2018/1624
 As per Article 11(1) BRRD and Section B of BRRD Annex