This final report presents revisions to the regulatory technical standards (RTS) on resolution plans and resolvability assessments, in response to over a decade of experience in resolution planning. The changes aim to simplify and streamline resolution plans, enhance their usability, and increase flexibility in resolution planning. The goal is to improve cooperation among resolution authorities and facilitate swift…
This document is the final report of the European Banking Authority (EBA) published in 2026, entitled "Final report on amending RTS on resolution plans and resolution colleges." It is an amended regulatory technical standard (RTS) relating to the content of resolution plans, the assessment of the resolvability of financial institutions, and the operational functioning of resolution colleges within the framework of Directive 2014/59/EU (BRRD). The scope covers banking entities and cross-border groups in the European Union, with an analysis based on more than ten years of experience and lessons learned from recent crises and simulation exercises. The document comprises approximately 67 pages, of which the first 35 were provided for this synthesis.
The report concerns the revision of regulatory technical standards (RTS) governing resolution plans, the assessment of the resolvability of financial institutions, and the functioning of resolution colleges for cross-border banking groups, in accordance with Directive 2014/59/EU. This revision is based on more than a decade of practical experience and lessons from recent crises, aiming to simplify, streamline, and make resolution plans more operational, improve resolvability assessments, and optimize cooperation and processes within resolution colleges.
The main findings are that resolution plans have become too detailed, redundant, and sometimes inflexible, which hinders their use in crisis situations. Resolution college procedures are considered too complex and cumbersome, slowing decision-making.
The conclusions are that plans must be simplified by eliminating non-essential information and duplications, structured according to a logical sequence aligned with the planning process, and equipped with better articulation between the strategy chosen by authorities and the assessment of institutions' resolvability. The introduction of greater optionality, notably through the definition of variant strategies, increases flexibility in crisis scenarios. For resolution colleges, reducing the steps to reach joint decisions, allowing process adaptation to the specific needs of the college, and improving information exchange via a secure platform are recommended.
Recommendations concern the adoption of the amended RTS by the European Commission, their publication in the Official Journal, and forthcoming application. These RTS specify notably the minimum content of plans, evaluation criteria according to seven key dimensions of resolvability, and operational modalities of colleges, including emergency management and cooperation with third-country authorities. (p. 1-12)
Since the initial adoption of the RTS in 2014, the EBA has accumulated over ten years of experience in resolution planning and has drawn lessons from recent crisis cases and simulation exercises. These feedbacks highlighted limits in the structure, readability, and flexibility of resolution plans, as well as in the operational functioning of resolution colleges.
The challenges are to improve authorities' capacity to make rapid and effective decisions in crisis situations, strengthen cross-border cooperation, and ensure better operational preparedness.
The main objectives of the revision are: (i) simplification and streamlining of resolution plans to avoid redundancies and focus on essentials; (ii) operationalization of plans to facilitate practical use and rapid implementation; (iii) introduction of greater optionality, notably through the definition of variant strategies, to adapt to specific crisis circumstances; (iv) simplification of resolution college procedures to improve their efficiency and cooperation, especially in emergencies; (v) clarification of modalities for involving third-country authorities and other observers.
The scope covers institutions and banking groups subject to Directive 2014/59/EU, with particular attention to cross-border groups and entities in liquidation. Limitations include exclusion of certain aspects not covered by the Directive or not amended by this revision. (p. 6-12)
Simplification and streamlining of resolution plans:
- Plans have become excessively detailed, with duplicated information and overly long operational descriptions, which harms their readability and usefulness in crisis.
- The structure of plans is revised to follow a logical sequence aligned with the steps of the planning process: assessment of the credibility and feasibility of normal liquidation, choice of preferred resolution strategy and variants, coordination of implementation, then institution's capacity to support the strategy.
- Information related to MREL (minimum requirement for own funds and eligible liabilities) is refocused on institution- or entity-specific adjustments, avoiding redundancy of common policies.
- Resolution plans for entities in liquidation are lightened, with requirements limited to the credibility and feasibility of normal liquidation.
Operationalization and improvement of implementation:
- Plans must be more operational, with clear articulation between the strategy chosen by authorities and the assessment of institutions' resolvability according to seven key dimensions: governance, loss absorption capacity, liquidity and funding in resolution, operational continuity, information systems, communication, resolvability and restructuring.
- Inclusion of a summary of key steps for coordinating the implementation of the strategy.
Optionality and flexibility of strategies:
- Explicit introduction of variant strategies to anticipate cases where the preferred strategy would not be applicable in crisis.
- Requirement for clear justification of the choice of preferred and variant strategies, with assessment of their credibility and feasibility.
Functioning of resolution colleges:
- Simplification of joint decision-making processes, reduced to four essential steps: timetable, preliminary dialogue, consultation, decision.
- Possibility to adapt processes to the specific needs of the college, including order and simultaneity of steps.
- Removal of certain administrative obligations, such as mandatory annual updating of member lists.
- Increased flexibility on holding meetings (not only in person) and frequency adapted according to group nature (e.g., groups in liquidation only).
Cooperation and information exchange:
- Strengthening active participation of all members and observers, specifying relevant topics according to their role.
- Mandatory establishment of a secure document management platform for information exchange and storage.
- Proactive notification of third-country authorities likely to be observers, facilitating their integration.
- Mandatory appointment of a college coordinator and a deputy, ensuring coordination and communication.
- Mandatory dialogue to address substantial obstacles identified to resolvability, involving all concerned authorities.
Emergency management:
- Clear definition of emergency situation triggering (e.g., application or conditions for application of early intervention measures, probable failure).
- Activation of specific procedures to ensure reinforced cooperation, rapid information exchange, and agile decision-making.
- Possibility to simultaneously conduct assessment of the need for a group resolution scheme and joint decision-making.
Testing and continuous improvement:
- Obligation of regular testing of college operating procedures, with multi-year planning considering risk profile, complexity, and synergies with other colleges.
- Proportionate exemptions for certain colleges (liquidation only, simplified obligations, European colleges without resolution entity in the EU).
These themes are detailed in the amended articles of Delegated Regulation 2016/1075, specifying plan contents, evaluation criteria, college procedures, observer management, information and coordination modalities, as well as emergency requirements. (p. 6-35)
Findings:
- Current resolution plans are too long, detailed, and redundant, which harms their readability and effectiveness in crisis situations.
- Resolution college procedures are too complex, slowing decision-making and cooperation.
- Practical experience and recent crises have shown the need for greater strategic flexibility, notably through the introduction of variant strategies.
- Cooperation with third-country authorities is essential and must be facilitated.
Assumptions:
- Simplification and streamlining of plans and procedures will improve the speed and effectiveness of decisions in crisis.
- Use of a secure platform for information exchange will strengthen confidentiality and fluidity of exchanges.
- Appointment of college coordinators will foster better organization and communication.
Interpretations:
- Clear separation between the strategy chosen by authorities and the assessment of institutions' resolvability will make plans more operational.
- Reduction of steps in the joint decision-making process will focus discussions on substance rather than procedure.
- Flexibility in holding meetings and college frequency allows better adaptation to group specificities.
Uncertainties:
- The precise impact of changes on the speed of plan implementation in real crisis remains to be observed.
- Effectiveness of new cooperation processes with third-country authorities will depend on their engagement and confidentiality regimes.
- Institutions' capacity to provide necessary operational information within required deadlines may vary.
(p. 3-12, 14-35)
The EBA recommends adopting the amended RTS aiming to:
- Simplify and streamline resolution plans by eliminating non-essential information and duplications, and structuring plans according to a logical sequence aligned with the planning process.
- Make plans more operational by clearly distinguishing the strategy chosen by authorities and the assessment of institutions' resolvability according to seven key dimensions.
- Introduce greater optionality through explicit definition of variant strategies to adapt to different crisis scenarios.
- Simplify and flexibilize resolution college procedures, notably by reducing joint decision-making steps, adapting processes to specific college needs, and relaxing administrative and meeting frequency obligations.
- Strengthen cooperation and information exchange via a secure platform, proactive participation of third-country authorities, and appointment of college coordinators.
- Provide specific procedures for emergency management, with reinforced cooperation and agile decision-making.
- Implement regular testing of college operating procedures, with a proportionate approach according to group profiles.
The report indicates that these RTS will be submitted to the European Commission for approval, then to consultation with the European Parliament and the Council before publication in the Official Journal of the European Union. The entry into force date remains to be specified. (p. 4-5, 14-35)
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